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What are Willful Conduct and Willful Blindness in IRS FBAR Audits

What are willful conduct and willful blindness in IRS FBAR audits and court cases?  It is important to begin with an understanding regarding IRS FBARs and when they are required.  Any US taxpayer who has offshore bank or investment accounts (outside the United States) is required to prepare and file an...

US Expats a New IRS Target for FBAR Violations

What makes US expats a new IRS target for FBAR violations and undisclosed offshore assets?  The IRS is instituting a new whistle-blower campaign for those who might help US expats and other US taxpayer clients.  Allen Barron provides attorney-client protections for those who are working on the disclosure of foreign...

While US Administration Walks Back Independent Contractor Rules California and the EDD Increase Misclassification Audits

In recent months the current US administration has signaled a change in the position of the previous administration regarding the classification of independent contractors.  This comes at a time when California and the EDD increase misclassification audits based upon a recent decision in the California Court of Appeal, Sixth District....

Avoid the DOL and IRS Audit Focus on Independent Contractors

How can you avoid the US Department of Labor or DOL and IRS audit focus on independent contractors and 1099 workers?  What do you need to know about the new definitions of an independent contractor based upon the so-called "Darden Factors" and the "Economic Realities" standards?  Why should you be concerned...