What are willful conduct and willful blindness in IRS FBAR audits and court cases? It is important to begin with an understanding regarding IRS FBARs and when they are required. Any US taxpayer who has offshore bank or investment accounts (outside the United States) is required to prepare and file an...
Are You a Foreign National Living and Working in San Diego
Are you a foreign national living and working in San Diego? Have you come into the US on an H1-B or other Visa? It is important for all foreign nationals who reside in the US for more than a few months to understand their obligations under US tax laws. One...
US Expats a New IRS Target for FBAR Violations
What makes US expats a new IRS target for FBAR violations and undisclosed offshore assets? The IRS is instituting a new whistle-blower campaign for those who might help US expats and other US taxpayer clients. Allen Barron provides attorney-client protections for those who are working on the disclosure of foreign...
Failure to Comply with IRS FBAR Reporting Requirements Part of Manafort Indictment
The failure to comply with IRS FBAR reporting requirements was part of the recent Manafort indictment, but it doesn't just apply to the wealthy or powerful. The failure to fully and accurately disclose offshore bank accounts, investments, assets and real property is a challenge for many US taxpayers, and the...
Jan Allen Speaks on a National IRS FBAR Panel Tomorrow
Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern. The topic of the expert panel discussion is "Willfulness and the IRS Disclosure Programs. Are you Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and...
US Court of Appeals Upheld Requirement for IRS FBAR Reporting
The Sixth District of the US Court of Appeals upheld requirement for IRS FBAR reporting recently. The decision affirmed the actions of a US District Court which dismissed a complaint which challenged FATCA and the requirement to come into compliance with IRS FBAR disclosures. The lawsuit sought to prohibit...
How Can Allen Barron Better Protect You and Your FBAR Compliance
How can Allen Barron better protect you and your FBAR compliance issues with the IRS? How can Allen Barron help you come into compliance with IRS FBAR reporting requirements while keeping associated penalties and risk at a minimum? Allen Barron is uniquely positioned to provide sound counsel and comprehensive services...
The US Tax Impact of Opening a Foreign Account
What is the US tax impact of opening a foreign account for a US taxpayer including foreign nationals who live and work in the United States? The requirement for US taxpayers to report offshore accounts has been around for quite some time. In 2004, the IRS added penalties for non-willful...
Wall Street Journal Warns Offshore Account Holders to Fear the IRS
A major US financial newspaper today echoed Allen Barron's repeated warnings to offshore account holders to fear the IRS and impending IRS audits. The Wall Street Journal (WSJ) today issued a daunting warning to US taxpayers with offshore bank accounts, investment accounts and assets: "Are You Hiding Money Overseas from...