Should you be concerned about an IRS Revenue Officer interview? If you have received notice of an "IRS Revenue Officer Interview" take heed - you are heading into a period of great potential risk, and you should be represented by an experienced and proven tax attorney. An IRS Revenue Officer...
Is a PFIC Still a Good Investment Strategy
We are often asked "Is a PFIC still a good investment strategy based upon IRS taxation and recent offshore developments?" The answer is simple: the income it generates must be substantial enough to pay a heavy tax which the IRS levies on PFICs. The Passive Foreign Investment Company or PFIC...
How Long Do You Need to Keep Tax Files
We are often asked “How long do you need to keep tax files as a business?” With most businesses, files pile up fast and storage may run low. As an experienced San Diego business and tax attorney we’ve developed a guide to legal files that you should hold onto, as...
Why the Attorney Client Privilege Matters in IRS Issues Involving Foreign Assets
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...
Many Penalties Accrue When You Fail to File Taxes
Did you know that many penalties accrue when you fail to file taxes? Imagine that you are filing your taxes, and during the course of filing these taxes you discover that you will actually owe the Internal Revenue Service some money. No refund for you -- instead, you have yourself...
Is it Easy to Get the IRS to Agree to an Offer in Compromise
Is it easy to get the IRS to agree to an offer in compromise? The IRS is not in the business of settling tax debt for pennies on the dollar. In fact, the idea promoted on the TV and radio that it is easy to complete an IRS offer in...
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...
Should a Taxpayer Contact the IRS if They Receive an Audit Notification?
Should a taxpayer contact the IRS if they receive an audit notification? Quite simply - it isn't in your financial or legal interest to contact the IRS directly. Most citizens think that cooperating with the IRS is the best policy. They go out of their way to be courteous to...
How Can We Help Taxpayers to Receive IRS Penalty Abatement
How can Allen Barron help US, California and San Diego taxpayers to receive IRS penalty abatement? How can IRS penalty abatement substantially reduce what you owe to the IRS? There are several reasons why you should not have to pay the draconian penalties the IRS adds to many US taxpayer's...