How does a multistate or multinational corporation approach the question of the California unitary method or waters edge election for tax calculation purposes? The integrated tax, accounting, legal and business service at Allen Barron allow you to receive a more comprehensive answer from a broader perspective, yet detailed as we...
While US Administration Walks Back Independent Contractor Rules California and the EDD Increase Misclassification Audits
In recent months the current US administration has signaled a change in the position of the previous administration regarding the classification of independent contractors. This comes at a time when California and the EDD increase misclassification audits based upon a recent decision in the California Court of Appeal, Sixth District....
Transfer Pricing Strategies and Selection
There are several different factors which affect transfer pricing strategies and selection of the specific method which provides the greatest procedural and tax advantage while meeting the guidelines of the IRS and other sovereign tax agencies. Each situation is unique and the selection of the most appropriate and applicable transfer...
The Strategy of an IRS Audit and the Statute of Limitations
Why do you need an attorney if you are facing an IRS audit? What is the strategy of an IRS audit and the statute of limitations which arises during many audits? Allen Barron provides sound advice and experienced representation for US taxpayers facing an audit. The first piece of strategy...
IRS FBAR Reporting Notes and Caution Regarding Streamlined Application Filings
Recently released IRS FBAR reporting notes detailed some interesting facts regarding FBAR filings since the program's inception in 2007. In 2007 the IRS received 332,000 FBARs compared to more than 1 million FBAR reports for tax year 2015. The IRS noted it has charged hundreds with tax evasion and willful...
Business Advisory Services for Buying or Selling a Business in San Diego
Allen Barron's business advisory services for buying or selling a business in San Diego provide clients with access to proven in-depth experience and expertise, supported by legal, tax and accounting services. You should always be prepared to sell your business, even though you have no present plans to let go...
IRS FBAR Audits are Heating Up as Offshore Banking Information Pours In
IRS FBAR audits are heating up as offshore banking and taxpayer information pours into the IRS from offshore banks, financial institutions, investment houses and foreign sovereign tax agencies. The IRS formed agreements with most of the nations around the world as well as hundreds of thousands of banks, investment houses...
The Due Diligence of a San Diego Asset Purchase
The due diligence of a San Diego asset purchase is quite often given less priority and attention than it must warrant. An asset purchase transaction is actually legally quite complex. The buyer agrees to purchase the specific assets and associated liabilities the asset purchase contract specifies will be acquired and/or...
Changes to Partnerships and LLCs Required by IRS
There are substantial changes to partnerships and LLCs required by the IRS as part of the Bipartisan Budget Act (BBA) which are scheduled to take effect January 1, 2018. The US Treasury Department issued new rules in January of this year which will substantially impact tax matters for partnerships as...