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
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more
A well-structured trust is often a central estate planning tool for small businesses and closely held family business owners when passing a business or wealth to your children. This includes heirs, beneficiaries, and future...more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
1/29/2025
/ Double Taxation ,
FBAR ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Foreign Tax Credits ,
Income Taxes ,
Investors ,
IRS ,
Mutual Funds ,
Offshore Banks ,
PFIC ,
Tax Credits ,
Tax Planning
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
1/23/2025
/ Anti-Money Laundering ,
Beneficiaries ,
Compliance ,
FACTA ,
FBAR ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Foreign Trusts ,
Grantor Trusts ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Trusts
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
11/27/2024
/ Compliance ,
Duty to Report ,
FBAR ,
Filing Requirements ,
FinCEN ,
Income Taxes ,
Investigations ,
IRS ,
Reporting Requirements ,
Tax Audits ,
Tax Avoidance ,
Tax Evasion ,
Tax Penalties ,
Tax Returns ,
Transparency ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
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
In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
7/16/2024
/ Artificial Intelligence ,
Cryptocurrency ,
Disclosure Requirements ,
FBAR ,
Foreign Bank Accounts ,
Foreign Financial Institutions (FFI) ,
IRS ,
Negligence ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Returns ,
Taxable Income ,
Willful Misconduct ,
Willful Violations
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
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
5/31/2024
/ Bank Accounts ,
Capital Gains Tax ,
Conflicts of Interest ,
Criminal Prosecution ,
Cryptocurrency ,
EU ,
Expatriates ,
FACTA ,
FBAR ,
FinCEN ,
Fines ,
Foreign Financial Institutions (FFI) ,
Income Taxes ,
International Financial Reporting Standards ,
International Tax Issues ,
Investment ,
IRS ,
Penalties ,
Reporting Requirements ,
Tax Evasion
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
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
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
What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more
5/13/2024
/ Amended Tax Returns ,
Artificial Intelligence ,
FBAR ,
Financial Institutions ,
IRS ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Code ,
Tax Evasion ,
Tax Returns ,
Voluntary Disclosure
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
4/30/2024
/ Disclosure Requirements ,
Failure-to-File ,
FBAR ,
Financial Crimes ,
FinCEN ,
Income Taxes ,
Investment ,
IRS ,
Money Laundering ,
Mutual Funds ,
Noncompliance ,
Offshore Banks ,
Penalties ,
Popular ,
Terrorism Funding
In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...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
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
2/27/2024
/ Child Tax Credit ,
Expatriates ,
FBAR ,
Filing Deadlines ,
Foreign Earned Income ,
Income Taxes ,
IRS ,
Offshore Tax Informant Program (OTIP) ,
Settlement ,
Statute of Limitations ,
Tax Levy ,
Tax Returns
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
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
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
11/16/2023
/ Advance Health Care Directive ,
Alternate Investment Vehicles (AIVs) ,
Beneficiaries ,
Capital Gains Tax ,
Compliance ,
Documentation ,
Estate Planning ,
Expatriates ,
FBAR ,
FinCEN ,
Foreign Banks ,
Foreign Financial Accounts ,
Grantors ,
Income Taxes ,
Investment Portfolios ,
IRS ,
Life Insurance ,
Living Will ,
Mutual Funds ,
Passive Investments ,
Power of Attorney ,
Probate ,
Property Owners ,
Retirement Plan ,
Risk Mitigation ,
Tax Deductions ,
Tax Planning ,
Trusts
Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more
10/31/2023
/ FBAR ,
Foreign Trusts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
OVDP ,
Passive Foreign Investment Company ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Rates