It is important to understand why the attorney client privilege matters in IRS issues involving foreign assets. The attorney-client privilege is a solid legal protection that allows a client to discuss the details of foreign accounts and assets with our experienced tax attorney Janathan Allen without concern of disclosure to...
What Constitutes Willful Conduct From the Perspective of the IRS
What is it that constitutes willful conduct from the perspective of the IRS as it relates to offshore financial activities and the FBAR? This question is at the heart of compliance for US taxpayers with offshore accounts and assets. The difference in that legal distinction represents an exponential difference in...
San Diego FBAR Lawyer Helps Foreign Nationals Comply with the IRS
Janathan Allen, our San Diego FBAR lawyer helps foreign nationals comply with the IRS and fulfill offshore financial disclosures. The penalties for US taxpayers including resident foreign nationals are quite high. Ignorance of the law is no excuse before the IRS, so the international tax attorneys at Janathan L. Allen,...
FBAR Requirements if You Are Listed on an Offshore Account
What are your FBAR requirements if you are listed on an offshore account or investment? The penalties associated with non-compliance with the reporting of offshore accounts, assets and income to the IRS continue to escalate. Many US taxpayers including resident foreign nationals are not aware there are FBAR requirements if...
Investment in a Foreign Trust Creates Complex Reporting Requirements
The IRS has clearly identified legitimate reasons why "US Persons" would establish or maintain ownership in a foreign trust. However, there are significant and complex tax reporting requirements associated with US taxpayers who are beneficiaries with an investment in a foreign trust. There are specific transactional reporting requirements for those...
The Challenges of Offshore Investment Accounts
US taxpayers must be aware of the challenges of offshore investment accounts as they relate to tax liability and the ramifications of FATCA and compliance with IRS FBAR reporting. The greatest risk to US taxpayers with offshore investment accounts may be the complex accounting and legal distinctions regarding foreign investments...
FBAR Preparation and Filing to Ensure Compliance
Allen Barron provides extensive tax expertise and assistance with FBAR preparation and filing to ensure compliance with all IRS requirements. If you have offshore bank accounts, investments, assets or own or control a portion of a foreign corporation you must be in full compliance with the IRS or face a...
How Will Marrying a Non-US Citizen Affect Your Taxes?
How will marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS and California tax agencies may raise in an audit? The United States is one of the few countries who tax worldwide income. US taxpayers and expatriates must report all foreign bank...
Failure to Make a Full Disclosure of Offshore Accounts to the IRS
What are the risks and penalties of the failure to make a full disclosure of offshore accounts to the IRS? What happens if you have not included all of your offshore bank accounts, assets, investments, foreign trust and foreign corporate ownership interests to the IRS via FBAR or associated IRS...