Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...more
7/18/2025
/ Business Taxes ,
California ,
Enforcement Actions ,
Foreign Financial Institutions (FFI) ,
Income Taxes ,
IRS ,
Penalties ,
State Taxes ,
Tax Audits ,
Tax Liability ,
Tax Returns
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
6/17/2025
/ California ,
Expatriates ,
Government Agencies ,
Income Taxes ,
IRS ,
Penalties ,
State Taxes ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
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
Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more
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
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
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
Don't stick your head in the sand and miss important business or personal tax deadlines...more
1/28/2025
/ Business Taxes ,
California ,
Corporate Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
State Taxes ,
Tax Planning ,
Tax Returns
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
Are you above the age of 50? Do you and/or your spouse have a 401(k)? Are you interested in reducing the amount you will have to pay in 2025 income taxes while increasing the amount of money you receive after retirement?...more
11/25/2024
/ 401k ,
Adjusted Gross Income ,
Employee Benefits ,
Employee Contributions ,
Income Taxes ,
Investment ,
IRS ,
Retirement Plan ,
Tax Credits ,
Tax Incentives ,
Tax Planning
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
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
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
The IRS extension deadline is in one week, Tuesday, October 15, 2024. This is the last date for most U.S. taxpayers with extensions to file their 2023 federal income tax return without incurring late filing fees and other...more
We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and...more
What is the step-up benefit of a revocable trust from the perspective of the beneficiaries? How can a revocable trust not only pass money and assets to your beneficiaries but save a substantial amount of tax in the process? ...more
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
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
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 are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more
5/17/2024
/ Beneficial Owner ,
Expatriates ,
FACTA ,
Foreign Financial Institutions (FFI) ,
GAAP ,
Income Taxes ,
Investment ,
IRS ,
Mutual Funds ,
Offshore Funds ,
Passive Foreign Investment Company
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