What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...
Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?
Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in this area based upon a significantly improved ability to process data...
How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful? If you have accounts with any Foreign Financial Institutions...
What to do if You Receive an IRS Audit Notification Letter
What should you do if you receive an IRS audit notification letter? Why should you consider engaging experienced IRS audit and tax attorney Janathan Allen, who represents U.S. taxpayers facing an IRS audit or any other federal or state tax issue. There are several things you should know if you...
You Sign Every Tax Return Under The Penalties of Perjury
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that they had examined the return and underlying schedules. The "Sign Here" block...
Selling items Online? Is the IRS Watching?
Are you selling items online or receiving payment for goods and/or services on platforms such as PayPal, Venmo, eBay, Zelle, Etsy, or Cash App? Online platforms are the preferred method of shopping for most Americans. These platforms also support the gig economy and, what has to date been, the potential...
What is the “Abusive Use of Partnerships” and Why does the IRS Care?
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using sophisticated tax-free transactions that lack economic substance” to avoid paying taxes. . The IRS continues to...
What is an FBAR and What Foreign Financial Information Are You Required to Report?
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and assets, as well as the exchange of financial information between the IRS and Foreign...
Are you Thinking of Moving to Another Country – A Few Things to Consider
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to become a U.S. expatriate. The European Union, through its official...