By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Friday, September 18, 2015. With the completion of a 5 year IRS tax audit, the agency has notified Coca-Cola that it owes $3.3 Billion in back taxes and interest following an IRS audit of tax years...
The US Department of Labor Weighs In on “Employee v. Independent Contractor”
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, September 14, 2015. The US Department of Labor has issued an update to it's own six factor test for whether to classify a person as an "employee" or an "independent contractor." This is a hotly...
India Taking Cues from FATCA in Search of “Black” Money
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Friday, September 11, 2015. The IRS has deployed a double prong approach under the Foreign Account Tax Compliance Act or FATCA: 1. Force foreign banking institutions, investment houses and sovereign tax authorities to provide information regarding...
Do Legitimate Deductions for Research and Development and Conservation Increase IRS Audit Risk?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Thursday, September 10, 2015. Recent reports have placed the IRS at odds with the will of Congress and the legitiimate deductions businesses and individuals may claim on their tax returns. The two areas of concern include:...
What Began as a Transfer Pricing Audit has become a Brawl Between Microsoft and the IRS
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Wednesday, September 9, 2015. It seemed simple enough: The IRS sends Microsoft a notice about an intent to audit transfer pricing between Microsoft and several offshore affiliates. However, the IRS used an external law firm to...
IRS Continues To Increase FBAR Pressure on US Taxpayers
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Thursday, September 3, 2015. The IRS continues to increase the pressure on US taxpayers to come into full compliance with FBAR reporting, and to pay the price when they do not. The IRS recently added several...
IRS Takes in $114 Million From the Sale of Seized Assets
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, September 2, 2015. The IRS has brought in $114 Million dollars from the sale of the seized assets of US taxpayers from 2011 to 2014. When the IRS seizes an asset through a levy, it...
Treasury Inspector General says IRS Failing to Send Some Levy Notices
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, August 26, 2015. The US Treasury Inspector General has released a recent report detailing the failure of the IRS to send appropriate Notification of Intent to Levy in over 40% of automated cases studied. When...
Willful or Non-Willful Conduct with the IRS and Foreign Bank Reporting
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, August 25, 2015. The central issue relating to the Foreign Account Tax Compliance Act (FATCA) and the associated Foreign Bank and Financial Account Report (FBAR) is whether conduct on the part of the US taxpayer...