If you had a financial interest in a foreign financial account, or signatory or authority over one or more accounts whose aggregate value exceeded $10,000 USD at any point in 2015, you are required to file an IRS FBAR (Report of Foreign Bank and Financial Accounts). You must submit the FBAR...
What is the Offshore Voluntary Disclosure Program or OVDP in San Diego?
What do US taxpayers in San Diego need to know about the IRS Offshore Voluntary Disclosure Program or OVDP and how can it be the safest option for disclosing previously unreported offshore accounts, assets and income? The IRS Offshore Voluntary Disclosure Program is exactly what it sounds like - a...
IRS Tells Taxpayers “I Didn’t Know” Won’t Work – OVDP the Safest Option for FBAR Compliance
Many taxpayers had hoped that telling the IRS "I didn't know" and submitting a streamlined disclosure application would get them through FBAR disclosures quickly and inexpensively. After all, the streamlined options reduces penalties down to 5% is the IRS accepts the streamlined application when compared to the OVDP or the...
San Diego OVDP Attorney – Advantages of the IRS OVDP
Ask San Diego OVDP attorney Janathan Allen about the advantages of the IRS OVDP when compared with the streamlined option and not coming into compliance at all, she's likely to answer with a single word: "RISK!" The IRS OVDP option is the only path a US taxpayer can use...
Why does the IRS OVDP Reduce Risk for US Taxpayers in Offshore FBAR Disclosures?
Why is the IRS OVDP or Offshore Voluntary Disclosure Program the safest choice for US taxpayers coming into compliance with IRS FBAR disclosures? How does the OVDP reduce risk for US citizens and foreign resident nationals who are required to file US tax returns? The key issue is the IRS'...
San Diego OVDP Attorney Advises Foreign Nationals who Reside in US
At Allen Barron, we support many leading engineering, high-tech companies and other businesses who attract and employ foreign nationals based upon their unique education, expertise and skill sets. For many of these clients, it is a complete surprise that foreign nationals who are legally working in the US are still...
How to Handle an FTB or IRS Garnishment or Levy
If you receive a notice regarding an FTB or IRS garnishment or levy you have a limited time to take action that will significantly affect your financial future. The notice of a levy indicates the IRS or FTB is about to seize all of the money in one or more of...
Medtronic Beats IRS in Complex Tax Matter Involving Transfer Pricing
Medtronic PLC, a medical device manufacturer who used to have operations in Puerto Rico, has defeated the IRS in US Tax Court, resolving a $1.4 billion dispute. The key issue in the case centered on transfer pricing - transactions between different divisions or companies owned by the same corporation or...
How was the IRS Audit Window Recently Expanded from 3 Years to 6 Years?
How was the IRS audit window recently expanded from 3 years to 6 years? What changes provided the IRS with more power to go back into prior year's returns than ever before? The standard IRS statute of limitations for an IRS audit was considered to be 3 years. The key...