What is the difference between a hobby and a business from a tax perspective? When does a hobby become a business in the eyes of the IRS? If the IRS disputes your "business deductions" as a hobby it could trigger an IRS audit and result in a substantial payment to...
IRS is Targeting Small Business Owners for Audit
An expert recently testified before a house sub-committee documenting the fact that the IRS is targeting small business owners for audit in disproportionate numbers. The IRS allegedly believes many small businesses receive much of their income in cash which is hard to track. The IRS would obviously usually make more...
University Professor Pays a $100 Million FBAR Penalty to the IRS
The University of Rochester has gained unexpected notoriety recently as one of it's professors faces sentencing in a criminal tax evasion scheme. The University professor pays a $100 Million FBAR penalty to the IRS for failure to disclose Swiss accounts while awaiting his sentence in February that may contain additional...
IRS Targets Bitcoin Transactions in Federal Case Here in California
There is an interesting case which has been filed in a California Federal Court. Concerns are mounting as the IRS targets bitcoin transactions through Coinbase, a bitcoin exchange, through the strategy of a "John Doe Summons." The IRS has used this strategy in the past in an attempt to force...
Challenges with an IRS Audit Involving Transfer Pricing
IRS revenue agents and auditors create many unnecessary challenges for multinational businesses who utilize internal transfers to gain a tax advantage. This presents major obstacles during an IRS audit involving transfer pricing and other international tax related issues. The experienced international tax and business attorneys at Allen Barron, supported by...
California FTB or IRS Levy or Garnishment in San Diego
Allen Barron is uniquely positioned to help those who face a California FTB or IRS levy or garnishment in San Diego or southern California. Our IRS tax attorneys have specific strategies to deal with California and IRS tax collection efforts. If you owe the IRS more than $25,000 it is...
US Treasury and IRS Update Guidance on PFICs and CFC Investments
Recently the US Treasury Department and the Internal Revenue Service (IRS) released new guidance on PFICs and CFC investments for a Regulated Investment Company (RIC). Under US tax law a corporation can qualify as a Regulated Investment Company for a given tax year only when 90% or more of...
Brazilian FATCA Offshore Disclosures Net $4 Billion US
The deadline for Brazil's offshore account, income and asset reporting passed last week. The Brazilian Federal Revenue Secretariat (SRF) - Brazil's equivalent of the IRS - claims more than $4 Billion (US) in revenues from voluntary disclosures much like the US Offshore Voluntary Disclosure Program or OVDP. The Brazilian FATCA offshore...
CRS GATCA and the OECD – The Impact of FATCA
There are a lot of new acronyms in the world of international taxation. What do CRS GATCA and the OECD have to do with FATCA and offshore bank accounts? What impact has FATCA had upon other sovereign entities around the world? If are a US taxpayer and you have offshore...