By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Tuesday, September 22, 2015. The IRS and the US Treasury have issued temporary guidelines that affect the taxation of individuals and corporations who move goods and services between associated entities. Transfer pricing is generally defined as...
IRS FBAR Penalties for Willful and Non-Willful Conduct
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, October 21, 2015. If you have a combined total of more than $10,000 in offshore bank accounts, assets or investments you are required to file an FBAR or Foreign Bank Account Report with the IRS...
What is “Willful” Versus “Non-Willful” Conduct to the IRS and How Does That Affect FBAR Taxpayers?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, July 2, 2014. The difference between a determination of "willful" versus "non-willful" conduct by the IRS is the difference between a 50% penalty calculation and potentially a 5% penalty for FBAR violations. There are thousands...
Living abroad? Understand your tax obligations
On behalf of Janathan L. Allen, APC posted in IRS on Friday, January 24, 2014. Americans who live outside of the United States are still required to follow strict tax laws. These tax laws can be very complex and difficult to navigate but it is very important for Americans living...
New tax preparer rule by IRS gets knocked down
On behalf of Janathan L. Allen, APC posted in IRS on Friday, February 21, 2014. A couple of weeks ago, we talked about the limited nature of the Internal Revenue Service this year because of sequestration in late 2013. In that post, we raised a few questions about the IRS...
Sequestration limits IRS this tax season, so be careful
On behalf of Janathan L. Allen, APC posted in IRS on Wednesday, February 5, 2014. Most Americans heard about the sequestration episode from late last year, where the government was shut down for weeks, thus affecting a wide array of federal departments. The Internal Revenue Service was one of these...
California Swiss Account Holders Will Be Required to Update FBARs with Previously Undisclosed Account Data
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Friday, May 16, 2014. Californians who have previously not reported assets and accounts they had secreted in Swiss institutions will be required to file amended Foreign Bank Account Reports, or FBARs with the IRS. The deadline...
U.S. Expatriates Should Read IRS Publication 54 – Tax Guide for U.S. Citizens and Resident Aliens Abroad
U.S. expatriates should read IRS Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad. This is a beneficial article published by the agency itself, detailing the unique and specific tax reporting requirements and rules when reporting offshore or "foreign-earned" income to the Internal Revenue Service. 3 Important...
Why Is This Any Different for the IRS and FBARs and Foreign Accounts than at Any Time in History?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Saturday, July 5, 2014. The IRS has gained access to the vast majority of offshore account and property information. This data ties those accounts and assets to specific US social security numbers and Federal Taxpayer IDs,...