Did you file an application under the IRS Streamlined Domestic (Foreign) Offshore Procedures? What happens if the IRS rejects your FBAR streamlined application and claims of non-willful conduct? What actions have been taken by the IRS that concern the attorneys at Allen Barron? Let's begin with the last question first....
Should You Report Previous Offshore Income Through an FBAR Voluntary Disclosure
A storm is on the horizon for those who fail to report offshore financial activity to the IRS. We are often asked by clients, especially foreign nationals who live and work here in the San Diego area, if they should report previous offshore income to the IRS through an FBAR...
Why Should a Foreign National Working or Residing in the US Care about FBAR Compliance
Why should a foreign national working or residing in the US care about IRS FBAR compliance? "None of my friends or associates are aware of this or worried about it..." is a sentiment we often hear. Unfortunately, the IRS isn't interested in what a foreign national working or residing in...
Appeal of FBAR Willful Violation Civil Penalty to 5th Circuit
In a technical legal move Bernhard Gubser, a dual US / Swiss citizen, asked the 5th Circuit Court to hear an appeal of his case against the IRS regarding a $1.4 Million FBAR willful violation civil penalty case which was tossed out by a lower court earlier this year. Mr....
Willful or Non-Willful Attempt to Avoid US Taxes?
There continues to be confusion regarding what constitutes a willful or non-willful attempt to avoid US taxes as it relates to offshore bank accounts, investments, assets and income. The IRS has purposefully failed to clarify this issue over the past 7 years. This is the first piece of evidence a...
Non-Resident Indians or NRIs Face IRS Offshore Scrutiny
Citizens and former residents of India face genuine tax issues while they live and work in the United States. Many Non-Resident Indians or NRIs face IRS offshore scrutiny and FBAR compliance issues. Many have come to the US to work, and are unaware of tax obligations that have developed as...
Has the IRS Decided to Stop Accepting Streamlined Applications for FBAR Compliance?
Has the IRS decided to shut down the application process for the Streamlined Domestic Offshore Procedures under FBAR? Streamlined applications for FBAR compliance used to be submitted to the IRS via facsimile. The IRS has recently stopped access to fax submission of streamlined applications, and this may be a sign...
Can Foreign Nationals in the US Become FBAR Compliant with a Streamlined Application?
The experienced international tax attorneys at Allen Barron will work with you to develop the most effective strategy to disclose offshore bank accounts, investments, assets and income to the IRS. My name is Janathan Allen, and many foreign nationals in the US become FBAR compliant with my assistance. They are unaware...
Are Foreign Nationals US Residents for IRS Tax Purposes?
Many foreign nationals come to the US each year, often under an H1-B visa, in order to live and work. It is important for you to understand US tax laws as a resident of the United States - even if you have not yet received a green card or other permanent...