By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Thursday, November 13, 2014. We recently had a client that we were successfully able to shift from the regular IRS OVDP program to the streamlined domestic offshore procedures resulting in a substantial savings (and a very...
The IRS Modified 2014 OVDP Program Provides Closure to Statutes of Limitations, Streamlined Procedures Do Not
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, November 26, 2014. Many US taxpayers are being advised to jump into the streamlined domestic offshore procedures relating to offshore investment income and assets. The streamlined program offers significantly lower penalties and interest, and may be...
What’s the Big Deal? So I’ve Hidden Some Money Overseas Instead of Keeping it Here in San Diego
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Thursday, November 6, 2014. Ok, so maybe I've been hiding money or assets offshore instead of keeping them here in San Diego. Yes, I have probably failed to report it on my FBARs. I hear I...
IRS Adds More Swiss Banks to Automatic 50% OVDP Penalty List
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 9, 2015. The IRS has added severl new Swiss banks to the list of institutions that carry a mandatory 50% penalty instead of the 27.5% penalty provided in most OVDP filings. It doesn't matter...
Filing for OVDP Streamlined Domestic Offshore Procedures Could Reduce Your Penalty from 50% to 5% – a Large Sum for Any US Taxpayer
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, July 4, 2014. The new Streamlined Domestic Offshore Procedures within OVDP represent a tremendous opportunity for any US taxpayer with foreign accounts and assets to come into compliance with the IRS, and reduce their penalties...
New OVDP Streamlined Domestic Offshore Procedures Do Not Provide Civil or Criminal Protection
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, July 18, 2014. The recent release of the OVDP Streamlined Domestic Offshore Procedures (with a deadline of August 4th) was greeted with excitement in many quarters. Who wouldn't want to reduce penalties from 27.5% down...
How Will Information Obtained by the IRS from Foreign Banks Trigger Audits for San Diego and Southern California Taxpayers?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Sunday, September 28, 2014. The IRS recently obtained a windfall (from the IRS' perspective) of financial information relating to foreign accounts and assets specifically tied to US taxpayers or entities. Pressure brought upon foreign institutions by...
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...
Your Offshore Bank and the IRS are Both Warning You – Come Into Compliance Immediately
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, October 30, 2015. US taxpayers have received stern warnings from the IRS recently regarding FBAR compliance and disclosure of all offshore bank accounts, income, investments, assets and real property. Recently, many foreign banks are sending...