Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
5/30/2025
/ Appeals ,
Audits ,
Cryptocurrency ,
Filing Deadlines ,
FinCEN ,
Foreign Investment ,
Income Taxes ,
IRS ,
Litigation Strategies ,
Penalties ,
Tax Appeals ,
Tax Liability ,
Tax Planning
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
4/25/2025
/ Attorney-Client Privilege ,
Audits ,
Business Ownership ,
California ,
Estate Planning ,
FBAR ,
Foreign Investment ,
International Tax Issues ,
IRS ,
Offshore Banks ,
Tax Liability ,
Tax Planning
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more
We are often asked how to prepare for an IRS audit. The first and most important thing to know is that speaking directly with the IRS is not in your best interest. IRS Revenue Officers (auditors) are skilled interrogators....more
11/22/2024
/ Algorithms ,
Attorney-Client Privilege ,
Audits ,
CPAs ,
Financial Adviser ,
Interrogations ,
IRS ,
Statute of Limitations ,
Tax Avoidance ,
Tax Credits ,
Tax Deductions ,
Tax Revenues
Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more
11/20/2024
/ Amended Tax Returns ,
Artificial Intelligence ,
Attorney-Client Privilege ,
Audits ,
Compliance ,
Constitutional Safeguards ,
Criminal Prosecution ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
FBAR ,
Fees ,
FinCEN ,
Fines ,
Foreign Financial Institutions (FFI) ,
Immunity ,
Income Taxes ,
Investigations ,
IRS ,
Offshore Funds ,
Penalties ,
Tax Evasion ,
Transparency ,
Voluntary Disclosure ,
Willful Misconduct
What is the action cryptocurrency investors need to take immediately? What has changed, and why should any digital asset holder or investor pay attention to this game-changing development?
Here is the short answer: If you...more
10/22/2024
/ Audits ,
Brokers ,
Cryptocurrency ,
Digital Assets ,
Financial Records ,
Infrastructure Investment and Jobs Act (IIJA) ,
Investigations ,
Investors ,
IRS ,
Penalties ,
Popular ,
Reporting Requirements ,
Safe Harbors ,
Tax Evasion ,
Trading Platforms ,
U.S. Treasury
What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more
10/15/2024
/ Audits ,
Compliance ,
Cryptocurrency ,
Disclosure Requirements ,
Filing Requirements ,
Income Taxes ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Penalties ,
Voluntary Disclosure
What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit?
How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more
9/25/2024
/ Audits ,
Capital Gains Tax ,
Compliance ,
Fees ,
Filing Requirements ,
FinCEN ,
IRS ,
Liability ,
Statute of Limitations ,
Tax Penalties ,
Tax Returns
What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more
6/28/2024
/ Artificial Intelligence ,
Audits ,
Business Ownership ,
FBAR ,
FinCEN ,
Foreign Investment ,
IRS ,
Partnerships ,
Perjury ,
S-Corporation ,
Tax Forms ,
Tax Returns
It is important to understand the step doctrine and how it applies to IRS audits and state tax investigations, including California tax audits. The "step doctrine" is a concept not directly found in federal or California...more
6/26/2024
/ Appeals ,
Artificial Intelligence ,
Audits ,
Buy-Out Agreements ,
California ,
FACTA ,
Federal Taxes ,
Foreign Financial Institutions (FFI) ,
Investigations ,
IRS ,
Liquidation ,
State Taxes
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more
6/19/2024
/ Audits ,
Compliance ,
Enforcement ,
Inflation Reduction Act (IRA) ,
IRS ,
New Guidance ,
Partnerships ,
S-Corporation ,
Tax Deductions ,
Tax Loopholes ,
Tax Rates ,
Tax Returns ,
Transfer of Assets
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more
5/30/2024
/ Audits ,
Compliance ,
FACTA ,
FBAR ,
Foreign Financial Institutions (FFI) ,
Income Taxes ,
IRS ,
Offshore Funds ,
Personal Information ,
Social Security Numbers ,
Voluntary Disclosure
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more
5/16/2024
/ Artificial Intelligence ,
Audits ,
FACTA ,
FBAR ,
Filing Requirements ,
FinCEN ,
Foreign Bank Accounts ,
IRS ,
Offshore Banks ,
Offshore Funds ,
Penalties ,
Voluntary Disclosure
An IRS audit doesn’t have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
3/27/2024
/ Audits ,
Bank Accounts ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
FBAR ,
Financial Institutions ,
FinCEN ,
Fines ,
Foreign Assets ,
Foreign Nationals ,
GAAP ,
Investment ,
IRS ,
Offshore Banks ,
Penalties ,
Real Estate Investments ,
Swiss Banks
The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply?
The IRS Offshore Voluntary Disclosure...more
2/21/2024
/ Audits ,
Cooperation ,
Criminal Prosecution ,
Disclosure Requirements ,
Financial Institutions ,
Financial Reporting ,
Fines ,
Good Faith ,
Investment ,
IRS ,
Offshore Funds ,
Penalties ,
Tax Avoidance ,
Tax Crimes ,
Tax Evasion ,
Voluntary Disclosure
Janathan Allen discusses what a tax attorney brings to the table that many other don’t. Ms. Allen notes that many attorneys don’t like numbers and yet there is so much in the business world that focuses upon the numbers...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS?
In...more
12/13/2023
/ Artificial Intelligence ,
Audits ,
Compliance ,
Cryptocurrency ,
Data Collection ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FATCA ,
FBAR ,
FinCEN ,
Fines ,
Foreign Entities ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Partnerships ,
Swiss Banks ,
Tax Fraud ,
Tax Returns
We are often asked if one has to pay taxes when selling goods or services online. That question became even more relevant this week when the IRS postponed the new “$600 Rule.” This is a particular relief for those wo receive...more
11/30/2023
/ American Rescue Plan Act of 2021 ,
Audits ,
E-Commerce ,
Internet Retailers ,
IRS ,
Online Payments ,
PayPal ,
Popular ,
Reporting Requirements ,
Sales & Use Tax ,
Third Party Payments ,
Threshold Requirements ,
Venmo
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
11/28/2023
/ Audits ,
Automated Systems ,
Business Losses ,
Compliance ,
Cryptocurrency ,
Data Collection ,
Data Processors ,
E-Filing ,
FATCA ,
FBAR ,
Financial Institutions ,
FinCEN ,
Investors ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Penalties ,
Perjury ,
Reporting Requirements ,
Retirement ,
S-Corporation ,
Software ,
Tax Credits ,
Tax Deductions ,
Tax Fraud ,
Tax Preparers ,
Tax Returns ,
U.S. Treasury
New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules. The IRS has formally given notice that it intends to...more
10/27/2023
/ Audits ,
Business Taxes ,
C-Corporation ,
Enforcement Actions ,
High Net-Worth ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Partnerships ,
Reporting Requirements ,
S-Corporation ,
U.S. Treasury
In a recently released bulletin, IR-2023-59, the IRS warns of shady tax preparers and increased audit risk as part of their “Dirty Dozen” series. The IRS provided some common “warning signs” including tax preparers who base...more