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
What do you need to know if you intend to sell your business? It is essential to have integrated tax and legal advice when selling your business to ensure maximum net profit and minimize contingent liability. Look for a...more
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more
5/27/2025
/ Business Entities ,
Disclosure Requirements ,
Filing Requirements ,
Foreign Corporations ,
International Tax Issues ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Tax Evasion ,
Tax Liability ,
Trusts
Have you been asked to be a trustee or executor? A trustee or executor has substantial financial and legal liability, and the trust or estate will pay an attorney to guide them through the process....more
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
How often should you review your trust and estate plan? Is there a regular cycle to these reviews, or should they be driven by significant events in your life or the lives of your beneficiaries and executor or trustee? How...more
2/26/2025
/ Alternative Minimum Tax ,
Asset Protection ,
Beneficiaries ,
Estate Planning ,
Estate Tax ,
Federal Taxes ,
Income Taxes ,
Probate ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Trust Administration ,
Trusts
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
Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year? A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more
2/12/2025
/ 1099s ,
eBay ,
Financial Transactions ,
FinTech ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Lyft ,
Mobile Apps ,
Mobile Payments ,
PayPal ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Uber ,
Venmo
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
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
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
11/14/2024
/ Appeals ,
Applications ,
Double Taxation ,
Expatriates ,
Foreign Tax Credits ,
France ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Investment Income ,
NIIT ,
Tax Liability ,
Tax Refunds ,
Tax Treaty
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers?
The value of many...more
3/19/2024
/ Cryptocurrency ,
Digital Assets ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
What does the recent OTA ruling tell you about a California tax audit? What can we learn from the results of an investigation by the Office of Tax Appeals (OTA) into the practices of a California tax agency? Why do you need...more
1/31/2024
/ Bank Deposits ,
California ,
EDD ,
Franchise Tax Board ,
GAAP ,
Income Taxes ,
Notice of Determination (NODs) ,
Sales ,
Tax Appeals ,
Tax Audits ,
Tax Liability ,
Tax Returns
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
In this podcast about Domestic Tax Planning, Janathan Allen discusses the importance of the process of domestic tax planning. Many people don’t think to consider tax planning by assuming, “I’m a W2 employee, how can domestic...more
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
We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more
8/28/2023
/ Expatriates ,
FBAR ,
Filing Requirements ,
FinCEN ,
Foreign Assets ,
Income Taxes ,
International Tax Issues ,
IRS ,
PFIC ,
Required Forms ,
Tax Liability ,
Tax Planning
Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more
8/24/2023
/ Bank Secrecy Act ,
Expatriates ,
FATCA ,
FBAR ,
Filing Requirements ,
FinCEN ,
Foreign Assets ,
Income Taxes ,
International Tax Issues ,
IRS ,
Popular ,
Required Forms ,
Tax Liability ,
Tax Planning
What is a Non-Fungible Token or NFT and what are the IRS and California tax issues associated with Non-Fungible Tokens or NFTs which might apply to you? NFTs are unique tokens based in and recorded within a blockchain that...more
8/4/2023
/ California ,
Capital Gains ,
Cryptocurrency ,
Digital Assets ,
Federal Taxes ,
Financial Services Industry ,
FinTech ,
Internal Revenue Code (IRC) ,
Investment Opportunities ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Smart Contracts ,
State Taxes ,
Tax Liability ,
Token Sales
The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income...more