here are two sources of income tax audits in California: those initiated by the State of California Franchise Tax Board (FTB) and those based on audits conducted by another agency, such as the IRS. This second form of audit,...more
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
Are you searching for an experienced California and IRS tax attorney? When legal professionals refer to California or IRS audits or tax issues, they are usually speaking of the types of interactions that a person or business...more
Why is the statute of limitations such an essential factor in an IRS audit? Should you approve a request from the auditor for a waiver of the statute of limitations in an IRS audit? This is often a complex question, and if...more
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
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...more
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
Connelly v. Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as...more
8/12/2024
/ Business Succession ,
Buy-Sell Agreements ,
Closely Held Businesses ,
Connelly v United States ,
Estate Tax ,
Fair Market Value ,
IRS ,
Liability ,
Life Insurance ,
Redemption Agreement ,
Right of Redemption ,
SCOTUS ,
Tax Audits
It's astonishing how many business owners undervalue accounting and its profound financial impact on business operations, transactions, taxation, and profit. An effective accounting strategy captures the information required...more
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more
2/26/2024
/ Collection Action ,
Corporate Entities ,
Highly Compensated Employees ,
Income Taxes ,
Investigations ,
IRS ,
Large Business & International Division (LB&I) ,
Partnerships ,
Self Employed ,
Self-Employment Tax ,
Tax Audits ,
Tax Evasion ,
U.S. Treasury
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more
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
What are the statute of limitations on an IRS audit and a California tax audit? There is a time limit, known as the “statute of limitations“, when the IRS and/or California must complete an audit of your tax returns. It is...more