By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 8, 2015. The IRS announced that it has contacted several potential vendors about a $130 million RFP to develop its own suite of identity verification services. This strategy is not part of the existing...
26 Swiss Banks Added to IRS 50% OVDP Penalty List … So Far
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, July 6, 2015. The IRS has identified 26 Swiss banks who they believe have made specific efforts to help US taxpayers to evade income taxes. The mandatory penalty for these institutions will be 50%, instead...
IRS Can Collect Back Tax Debt for Years – In One Recent Case 30 Years
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 22, 2015. The IRS has tremendous powers when it comes to the collection of back tax debt. The standard limitations The IRS usually has 10 years from the point an "assessment" is made to...
IRS Shortening Taxpayer Response Times in Audits?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Friday, June 19, 2015. A recent report out of South Dakota asserted that the IRS has shortened the amount of time it allows US taxpayers for responding to requests from the IRS during an audit. The...
Judge Agrees to Hearing in IRS verus Microsoft Case
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Thursday, June 18, 2015. Microsoft has challenged the IRS' authority to bring in a private, outside attorney to advise the agency on their deep and complex audit of Microsoft. The central question involves the ability of...
IRS Updates FBAR Penalty Guidelines and Willful Conduct Parameters
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 10, 2015. There has been a lot of confusion over what will constitute "willful" versus "non-willful" conduct in terms of FBAR reporting of foreign bank acounts and associated penalties for under-reporting them. The IRS...
IRS Under Fire for Using External Firm for Audit of Microsofts Offshore Investment Activities
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 1, 2015. The IRS is taking substantial heat from the US Senate regarding its decision to hire an outside law firm to assist with an investigation into Microsoft's alleged activities to shift profits offshore...
The IRS “Speed Up” Audit Tactics Can Harm US Taxpayers
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Wednesday, May 27, 2015. Recent budget cuts and substantial new congressional regulations have resulted in a new tactic by the IRS: the "Speed Up" audit. The IRS has limited resources and is pushing them to complete...
How is FATCA Affecting Worldwide Banking and Tax Change?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, May 25, 2015. The US Foreign Account Tax Compliance Act, or FATCA, has wrought significant and I believe historical change in the transparency of international banking and resulting US taxation. With the capitulation of Union...