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...
Can Lawsuit by Presidential Candidate Stop Impact of FATCA on the Swiss and Others?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, July 27, 2015. One of the sitting US Senators who is running for President, Rand Paul, sued the IRS and the US Justice department recently over the impact of FATCA and IRS Foreign Bank Account...
I Submitted an Application under the IRS OVDP – Why is My Penalty 50%?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Tuesday, July 14, 2015. There is some confusion regarding a list of banks that the IRS has determined to be actively involved in helping US taxpayers to avoid income tax. The ongoing list represents institutions who...
IRS Contracting to Lock the Barn Now that Horses Have Been Stolen?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 8, 2015. The IRS announced that it has contacted several potential vendors about a $130 million RFP to develop its own suite of identity verification services. This strategy is not part of the existing...
26 Swiss Banks Added to IRS 50% OVDP Penalty List … So Far
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, July 6, 2015. The IRS has identified 26 Swiss banks who they believe have made specific efforts to help US taxpayers to evade income taxes. The mandatory penalty for these institutions will be 50%, instead...
Do you have Swiss Accounts in Rothschild Bank AG or Banca Credinvest SA?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Friday, June 12, 2015. San Diego and southern California residents with accounts in Rothschild Bank AG or Banca Credinvest SA should know that both Swiss banks recently entered into agreements with the US Department of Justice...
FATCA and the IRS FBAR Have US Taxpayers and Foreign Banks in a Perfect Crossfire
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Thursday, June 11, 2015. The US Department of Justice (DOJ) and the IRS have worked for the past several years to establish the perfect crossfire scenario: foreign banks and US citizens forced to provide information on...
IRS Updates FBAR Penalty Guidelines and Willful Conduct Parameters
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 10, 2015. There has been a lot of confusion over what will constitute "willful" versus "non-willful" conduct in terms of FBAR reporting of foreign bank acounts and associated penalties for under-reporting them. The IRS...