By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 3, 2015. Do you really need to be concerned with how you submit your application to the Offshore Voluntary Disclosure Program (OVDP) or the streamlined option within it? The IRS will simply accept a...
Is Your Foreign Bank on the IRS List of Banks that Trigger a 50% OVDP Penalty?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 2, 2015. The IRS maintains a list of international banks that trigger an automatic 50% Offshore Voluntary Disclosure Program (OVDP) penalty instead of the standard 27.5% for those that file under the program. The...
IRS Under Fire for Using External Firm for Audit of Microsofts Offshore Investment Activities
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 1, 2015. The IRS is taking substantial heat from the US Senate regarding its decision to hire an outside law firm to assist with an investigation into Microsoft's alleged activities to shift profits offshore...
How is FATCA Affecting Worldwide Banking and Tax Change?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, May 25, 2015. The US Foreign Account Tax Compliance Act, or FATCA, has wrought significant and I believe historical change in the transparency of international banking and resulting US taxation. With the capitulation of Union...
Do I Have to Report a Single Foreign Bank Account With a Low Balance on an FBAR?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, May 11, 2015. We are often asked by US expatriates and US citizens with foreign abroad about the amount of the bank account balance that triggers the need to report it on an IRS Foreign...
Why US and California Taxpayers Need Help with the IRS Now More than Ever
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Tuesday, April 28, 2015. "It looks to me like you're purposely harming taxpayers," Rep. Kristi Noem of South Dakota told IRS Commissioner John Koskinen at a recent hearing. Mr. Koskinen was reporting that over 8 million...
Why Do So Many FBAR Taxpayers Want to Rely on Hope?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Thursday, April 23, 2015. There is a concerning trend we're seeing with FBAR taxpayers who are placing too much hope on the streamlined domestic offshore procedures option within OVDP. The core issue is what the IRS...
Why Did the US Invest All the Time and Money to Enact and Defend FATCA?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, April 22, 2015. Why did the US legislature pass FATCA? Why did the US Justice Department spend years and millions of taxpayer dollars pursuing foreign banks and investment houses in international courts? Why did a...
Major FATCA and FBAR Developments in Africa and the Middle East
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, February 18, 2015. There were major recent developments relating to FATCA in Africa and the Middle East, especially as they relate to South Africa and the South African Revenue Services (SARS). SARS and the IRS...