By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Saturday, May 17, 2014. The IRS has developed the Offshore Voluntary Disclosure Program (OVDP) to allow taxpayers who have failed to disclose any offshore asset or financial account through mandatory FBARs to petition the IRS for...
The Immediate IRS Challenge for US Expatriates Isn’t Income Tax, It’s FBAR
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, May 7, 2014. Many US expatriates focus on the amount of income that is excluded from US federal income taxes, and the thresholds for reporting and taxation. However, the most immediate threat to US expats...
A Simple Offshore Rental Property Can Create Substantial Issues with the IRS
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Saturday, June 14, 2014. If you have any income producing property in a country outside of the US it is important to report it properly to the IRS. As sources of potential revenue have dropped over...
IMPORTANT NEWS UPDATE: IRS Announces New “Streamlined Domestic Offshore Procedures”
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Friday, June 20, 2014. As Part of the Offshore Voluntary Disclosure Program or OVDP the IRS has provided new "Streamlined Domestic Offshore Procedures" for "non-willful" conduct that is in violation of FBAR and FATCA related reporting....
IRS Commissioner Hints that Changes in the OVDP May Be In the Works
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Sunday, June 22, 2014. IRS Commissioner John A. Koskinen made a startling revelation at a recent tax conference that the IRS was considering changing the existing OVDP to make things "more fair and equitable." Mr. Koskinen's...
Which IRS Program is Best for Those Who Have Issues with FBARs?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, December 29, 2014. The IRS has two main options for those who have either under-reported or failed to report foreign accounts or assets on the FBARs associated with their returns. The first option is the...
US District Court Upholds Massive FBAR Pentalties Against 87 Year Old Florida Man
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, June 18, 2014. I've been shouting from the proverbial rooftop for the past several months, and a recent decision by the US District Court is an example of why: an 87 year old man has...
IRS: Who Determines Willful or Non-Willful Conduct for Offshore Account and FBAR?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, July 7, 2014. The past few months have brought several historic and dramatic developments in respect to offshore financial reporting, the IRS, and questions of whether US taxpayers have shown "willful" or "non-willful" conduct as...
If the IRS has the Information, They Don’t Need You to Provide It
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Monday, June 9, 2014. On July 1 the IRS will gain access to information from foreign nations, banks, and institutions that previously has been kept secret (or at least out of the reach of the IRS)....