On behalf of Janathan L. Allen, APC posted in IRS on Thursday, January 2, 2014. One of the most frustrating aspects of tax season is that rules change, forms are altered and intricate details obtain new wrinkles that make it very difficult for the tax filer to get a grasp...
IRS Focusing In on International Audits, International Corporate Ownership Interests and Form 5471
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in International Business on Friday, November 13, 2015. The IRS recently released guidelines for its revenue officers regarding the pursuit of investigations relating to IRS Audits of US taxpayers with foreign interests. The guidelines are designed to help IRS...
IRS Warning Relating to FBAR and those with Offshore Bank Accounts and Assets
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, October 20, 2015. Last week was the deadline for US taxpayers who had requested extensions to file their tax returns. The following day the IRS issued Notice IR-2015-116 issuing a warning to US taxpayers with...
Over 100 Swiss Banks Alone Have Signed US FATCA Disclosure Agreement
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, October 19, 2015. The number of banks who have signed a disclosure agreement with the IRS expands monthly, and more than 100 Swiss banking institutions alone have been added to the IRS list of 50%...
IRS Data Exchange with Foreign Entities Affecting US Expats Overseas
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Friday, October 9, 2015. Recently, the IRS completed an initial run of data exchange with a group of countries under the agreements stemming from the passage and implementation of the Foreign Account Tax Compliance Act or...
Ohio Judge Slams Presidential Candidate on FATCA and FBAR
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Friday, October 2, 2015. Presidential Candidate Rand Paul, and six others who filed suit in an Ohio jurisdiction challenging portions of the Foreign Account Tax Compliance Act or FATCA have been handed a severe setback in their case. ...
India Taking Cues from FATCA in Search of “Black” Money
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Friday, September 11, 2015. The IRS has deployed a double prong approach under the Foreign Account Tax Compliance Act or FATCA: 1. Force foreign banking institutions, investment houses and sovereign tax authorities to provide information regarding...
IRS Continues To Increase FBAR Pressure on US Taxpayers
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Thursday, September 3, 2015. The IRS continues to increase the pressure on US taxpayers to come into full compliance with FBAR reporting, and to pay the price when they do not. The IRS recently added several...
Willful or Non-Willful Conduct with the IRS and Foreign Bank Reporting
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, August 25, 2015. The central issue relating to the Foreign Account Tax Compliance Act (FATCA) and the associated Foreign Bank and Financial Account Report (FBAR) is whether conduct on the part of the US taxpayer...