The IRS begins accepting 2017 tax returns as tax season is upon us. Allen Barron is uniquely structured to prepare and file your international, domestic, business and personal tax returns. Our tax attorneys are supported by Allen Barron's accounting professionals as we work toward this year's deadline of April 17. ...
IRS Establishes an Enforcement Initiative for Cryptocurrencies
Those who have invested in Bitcoin and other virtual currencies should take heed as the IRS establishes an enforcement initiative for cryptocurrencies and how US taxpayers report these on all tax returns. The IRS believes millions of transactions involving US taxpayers have occurred with exchanges such as Coinbase, and is...
Ignorance of IRS FBAR Reporting is Not a Defense
Our offices have handled many cases recently of foreign nationals and spouses with offshore accounts and assets who were not aware of their IRS FBAR reporting requirements. Unfortunately ignorance of IRS FBAR reporting is not a defense and the IRS is ruthlessly pursuing huge penalties and interest for those who...
What are Willful Conduct and Willful Blindness in IRS FBAR Audits
What are willful conduct and willful blindness in IRS FBAR audits and court cases? It is important to begin with an understanding regarding IRS FBARs and when they are required. Any US taxpayer who has offshore bank or investment accounts (outside the United States) is required to prepare and file an...
Two US Canadian Taxpayers Fail to File FBARs
The US Court of Federal Claims found two US Canadian taxpayers fail to file FBARs resulting in summary judgment for the IRS. The couple's defense was primarily based upon the fact they had engaged a "professional tax adviser" to prepare their returns and failed to review them. The court rejected...
What is an IRS Field Audit and What Should You Do?
What is an IRS field audit and what should you do if you receive notification from the IRS regarding their intention to conduct a field audit? An IRS field audit is an examination in your home, business or your accountant/attorney's office. An IRS field audit usually involves an examination of...
US Expats a New IRS Target for FBAR Violations
What makes US expats a new IRS target for FBAR violations and undisclosed offshore assets? The IRS is instituting a new whistle-blower campaign for those who might help US expats and other US taxpayer clients. Allen Barron provides attorney-client protections for those who are working on the disclosure of foreign...
Failure to Comply with IRS FBAR Reporting Requirements Part of Manafort Indictment
The failure to comply with IRS FBAR reporting requirements was part of the recent Manafort indictment, but it doesn't just apply to the wealthy or powerful. The failure to fully and accurately disclose offshore bank accounts, investments, assets and real property is a challenge for many US taxpayers, and the...
FBAR Related Charges Will Put Paul Manafort Behind Bars
While facing a slew of federal charges including conspiracy against the United States the FBAR related charges will put Paul Manafort behind bars. The charges against the former campaign manager and his aid are serious in their very nature, but it is interesting that one of the central issues associated...