If you have offshore accounts, investments or assets and have not come into compliance with the IRS, you should contact the San Diego FBAR attorneys at Allen Barron, who will provide guidance and insight into your options and help to ensure the best outcome in your case. Which voluntary disclosure...
US Justice Department Wins First FATCA Legal Victory – Shell Company and Its Nominees
Last week, the US Justice Department announced its first FATCA Legal Victory when it announced that Gregg R. Mulholland, owner of an offshore investment management company based out of Panama and Belize has plead guilty to money laundering and conspiracy. The firm was accused of fraudulent behavior, manipulating the value of...
IRS Hires 700 New Auditors
The IRS hires 700 new auditors raising the ire of republican watchdogs and raising new questions about Commissioner John Koskinen's previous testimony regarding budget cuts and the need for an increase in the budget for the IRS. The Chairman of the House Oversight and Reform Committee responded sharply: "Now, less than...
IRS Wins Case Against Taxpayer Outed by Swiss Bank UBS Group Who Claimed “Innocent Error”
For all US taxpayers who have been watching developments in FATCA, FBAR reporting and the IRS Offshore Voluntary Disclosure Program or OVDP, last week's court case was striking in it's message: The IRS will not accept taxpayer claims of "innocent error" or related claims such as "ignorance to the law"...
Court Dismisses Case Against $1.4M IRS Offshore Penalty
A Texas court has dismissed a lawsuit against the IRS asserting that the IRS burden of proof to assess a $1.4M IRS offshore penalty had not been met. The IRS originally asserted that the plaintiff's failure to file an FBAR for his offshore accounts, assets and investments in 2008 was...
US Taxpayers Identified in Panama Papers Should Immediately File OVDP
One thing is clear about the massive release of additional documents in the "Panama Papers" scandal yesterday: It's only a matter of time. There are several US taxpayers identified in yesterday's information release who should seriously consider their position and immediately file OVDP application to avoid potential criminal exposure for tax...
The Swiss Are Providing the IRS with Direct Feeds on US Taxpayer Accounts
There are very few safe tax havens left in the world, and the vast majority of the Swiss financial houses, banks and investment management companies are providing the IRS with direct feeds on US taxpayer accounts. This information includes account information, balances, and transactional data. The Swiss institutions have agreed to...
How Has the IRS FBAR Definition of “Non-Willful” Changed?
Why has the IRS questioned or outright rejected many of the applications under the Streamlined Domestic Offshore procedures? How has the IRS FBAR definition of "non-willful" changed? Previously the forms associated with the streamlined domestic offshore procedures (IRS Forms 14653 and 14654) simply asked the taxpayer to "provide specific reasons...
FATCA Rules May Make a US Trust Taxable as a Foreign Trust
Is it possible that a trust established under the laws of a US State such as California, with a US agent serving as its trustee could be forced to file taxes as a foreign trust? Yes, Under the Foreign Account Tax Compliance Act or FATCA rules and federal law if...