By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, December 31, 2014. If you are the owner of a business and have received any form of contact from the IRS you should view it as a red flag, and carefully read the letter they've...
Haven’t Broken The Law? Don’t Worry, The IRS Can Still Seize Your Assets
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Friday, December 5, 2014. Recently, the Internal Revenue Service has been seizing the assets of businesses and individuals who have been making deposits of less than $10,000, even though no laws have been broken. To make...
The Effects of the Foreign Account Tax Compliance Act
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Sunday, December 21, 2014. The Foreign Account Tax Compliance Act, or "FATCA" as it is known, passed in March 2010, "targets tax non-compliance by U.S. taxpayers with foreign accounts." The FATCA is concerned with reporting by...
When Are Tax Returns Confidential And Privileged From Production? (Part 1)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, December 10, 2014. California is one of the few states that holds tax returns may be privileged and not subject to discovery during civil litigation, except under certain circumstances. The privilege applies to both state...
When Are Tax Returns Confidential And Privileged From Production? (Part 2)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in California Tax on Thursday, December 11, 2014. Company Protected Against Forced Disclosure of Tax Returns In Casa W LLC v. Superior Court of Los Angeles County et al., Kyle Madison, his former wife Marjan Madison, and their friend...
US District Court Upholds Massive FBAR Pentalties Against 87 Year Old Florida Man
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, June 18, 2014. I've been shouting from the proverbial rooftop for the past several months, and a recent decision by the US District Court is an example of why: an 87 year old man has...
What is FATCA and Why is July 1 So Important This Year?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 3, 2014. FATCA (The Foreign Account Tax Compliance Act) was passed in 2010, and requires all US citizens with foreign investment or banking accounts to report them to the IRS. FATCA also requires foreign...
IRS: Who Determines Willful or Non-Willful Conduct for Offshore Account and FBAR?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, July 7, 2014. The past few months have brought several historic and dramatic developments in respect to offshore financial reporting, the IRS, and questions of whether US taxpayers have shown "willful" or "non-willful" conduct as...
Life events can cause confusion come tax time
On behalf of Janathan L. Allen, APC posted in IRS on Thursday, July 24, 2014. Over the years, so much can change in a person's life. They may get a new job. They may move, within the city they already call home or to a completely different state, or even...