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
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
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
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more
A reader recently sent in the following questions: Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...more
Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more