A recent case in the United States District Court for the Eastern District of Pennsylvania has turned the recent tide of IRS victories regarding "willful versus non-willful" intent in FBAR related compliance cases. The unusual non-willful court decision found the US taxpayer was not "willful" when failing to report one...
Jan Allen Speaks on a National IRS FBAR Panel Tomorrow
Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern. The topic of the expert panel discussion is "Willfulness and the IRS Disclosure Programs. Are you Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and...
The IRS Will Never Know About My Offshore Financial Accounts
We often hear clients say "The IRS will never know about my offshore financial accounts and assets," with conviction as if they are wishing it to be true. Unfortunately, the reality of today's world is much different. The truth of the matter is shocking to many people: The IRS is...
Does Your Domestic Entity Have Foreign Assets
Does your domestic entity have foreign assets which must be reported on the IRS Form 8938? The Foreign Account Tax Compliance Act or FATCA requires many US corporations, LLCs, trusts and partnerships which hold foreign investments or financial assets to disclose them on the form 8938. If a US trust...
US Court of Appeals Upheld Requirement for IRS FBAR Reporting
The Sixth District of the US Court of Appeals upheld requirement for IRS FBAR reporting recently. The decision affirmed the actions of a US District Court which dismissed a complaint which challenged FATCA and the requirement to come into compliance with IRS FBAR disclosures. The lawsuit sought to prohibit...
How Can Allen Barron Better Protect You and Your FBAR Compliance
How can Allen Barron better protect you and your FBAR compliance issues with the IRS? How can Allen Barron help you come into compliance with IRS FBAR reporting requirements while keeping associated penalties and risk at a minimum? Allen Barron is uniquely positioned to provide sound counsel and comprehensive services...
Tax Extension Due Dates for Corporate and Personal Returns Approaching
The tax extension due dates for corporate and personal returns is approaching quickly. Important deadlines for many corporate tax returns in September (originally due in March) and October (for personal filers originally due in April) will come to pass in the next 45 days. September 15 is not only the...
IRS is Closing In on US Taxpayers with Offshore Accounts
The IRS is closing in on US taxpayers with offshore accounts thanks to the global exchange of information which has been a by-product of FATCA and the Justice Department's pursuit of Swiss banking and financial interests. The deal between the IRS and Swiss institutions ultimately led to an agreement to...
Is the IRS Use of Social Media to Establish Audit Targets Legal
A Washington State University (WSU) professor has asked an interesting question in the Vanderbilt Journal of Entertainment and Technology Law: Is the IRS use of social media to establish IRS audit targets legal or does it violate established law? Revelations that the IRS researches social media and other large data...