A Pennsylvania Court has denied motions by both parties to dismiss a high profile trial which may shed light on willful conduct in IRS FBAR cases for US taxpayers. The CEO of a pharmaceutical company was accused by the IRS of willful failure to disclose Swiss bank accounts on his...
IRS FBAR Compliance for Canadian and Mexican Nationals in the US
If you live or work in the United States it is your responsibility to understand tax laws. This is why Allen Barron has been a leader in IRS FBAR compliance for Canadian and Mexican nationals living and working in the US. Many foreign nationals who reside or work here in...
Federal and State Tax Returns are Due Tomorrow
Well, tax day is finally here and for last minute filers there is one more day as Federal and State tax returns are due tomorrow April 18. Allen Barron provides on-going tax preparation and filing services for businesses and business owners, the self-employed and high income earners, as well as...
Amazon Savors a Huge Win Against IRS on Transfer Pricing
There has been a substantial development in the past week affecting international business as Amazon savors a huge win against the IRS on transfer pricing related tax disputes. The findings of a US Tax Court were stark: "The IRS acted in an arbitrary, capricious, and unreasonable manner when it applied...
A Reminder that IRS FBAR Reporting is Due Along with Your Tax Return This Year
Just a reminder that your IRS FBAR reporting is due along with your tax return on April 18th this year. The Foreign Bank Account Reports (referred to as FBAR) have previously been due later in the year, but 2017 marks a permanent change going forward. US taxpayers, including foreign nationals...
Owe the IRS more than $25,000? IRS Collection Efforts are Ramping Up
Do you owe the IRS more than $25,000? If so, it is time to contact Allen Barron and discuss a strategy to resolve your tax burdens as the IRS collection efforts are ramping up with external collection agencies and the threat of passport revocation. Allen Barron has successfully represented taxpayers...
Postmortem Tidbits from the Panama Papers
It's been more than a year since the international "Panama Papers" scandal hit where 11.5 million documents disclosed the true owners of more than 214,000 offshore "shell" companies. Postmortem tidbits from the Panama Papers provide insight into the genuine risks offshore investors, international businesses, US expats, and foreign nationals living...
Protecting Yourself in a San Diego IRS Audit
You should be primarily concerned about protecting yourself in a San Diego IRS audit to make sure you aren't providing additional information and leverage to the IRS. The first thing you need to know - it's not in your best interest to speak or communicate directly with the IRS. The...
IRS Large Business and International Division Targeting TEFRA Violations
The IRS Large Business and International Division (LB&I) will be targeting TEFRA violations in partnerships based upon recent changes in partnership related tax law. TEFRA (The Tax Equity and Fiscal Responsibility Act of 1982) regulations applying to partnerships created a set of consolidated IRS audit (examination), processing and judicial procedures which...