The IRS FBAR audits and prosecutions have begun and the clock is ticking for those who have yet to come into full FBAR compliance with the IRS. A Connecticut man recently plead guilty to the offshore scheme he used to conceal income from the IRS. The man, a duty-free importer...
Texas Case Shows a Piece of IRS Offshore Willful Analysis Strategy
Earlier this year the IRS, with the help of a US Bankruptcy Judge, successfully pierced a complex strategy by two Texas brothers Sam and Charles Wyly. The Wyly brothers were accused by the IRS of tax fraud related to the funneling of money and assets to offshore banks through a comprehensive series...
Offshore Accounts Tax Evasion and the IRS OVDP
The subject of hiding income and assets in secret offshore bank accounts has gone from a somewhat glamorous endeavor to reduce the amount of taxes one would pay to the IRS to a practice that is denounced world-wide as evidenced by convictions against major Swiss banks and financial institutions and...
San Jose Indian Foreign National Given Six Month Prison Term for Hiding Offshore Accounts from the IRS
We have advised foreign nationals living and working in the United States to come into compliance with IRS FBAR requirements for quite some time. One recent example of the risks faced by failing to come into FBAR compliance is a six month prison sentence to an Indian foreign national who...
Should You Report Previous Offshore Income Through an FBAR Voluntary Disclosure
A storm is on the horizon for those who fail to report offshore financial activity to the IRS. We are often asked by clients, especially foreign nationals who live and work here in the San Diego area, if they should report previous offshore income to the IRS through an FBAR...
Lawsuit against IRS Offshore Tax Programs Dismissed
Another lawsuit challenging the IRS offshore tax programs has been dismissed. In the consolidated lawsuit, 3 plaintiffs attempted to assert that they should be able to switch to the IRS' streamlined domestic offshore procedures, which were not available when the 3 filed applications under the OVDP or Offshore Voluntary Disclosure...
Willful or Non-Willful Attempt to Avoid US Taxes?
There continues to be confusion regarding what constitutes a willful or non-willful attempt to avoid US taxes as it relates to offshore bank accounts, investments, assets and income. The IRS has purposefully failed to clarify this issue over the past 7 years. This is the first piece of evidence a...
Can Foreign Nationals in the US Become FBAR Compliant with a Streamlined Application?
The experienced international tax attorneys at Allen Barron will work with you to develop the most effective strategy to disclose offshore bank accounts, investments, assets and income to the IRS. My name is Janathan Allen, and many foreign nationals in the US become FBAR compliant with my assistance. They are unaware...
Experienced San Diego OVDP Attorney Explains Advantages of IRS Offshore Disclosures
Why should a US taxpayer consider the Offshore Voluntary Disclosure Program or OVDP to come into compliance with IRS FBAR and offshore reporting requirements? Janathan Allen, an experienced San Diego OVDP attorney explains the advantages of IRS offshore disclosure programs, and why it is important to comply: FATCA established an...