Transfer pricing is a central international business tax issue. How does this affect San Diego area and California multi-national businesses? Transfer pricing is the allocation of income or loss between members of a "controlled group." From the IRS' point of view, a company is part of a controlled group when...
The Broad Powers of IRS Revenue Officers in an IRS Audit
The broad powers of IRS revenue officers in an IRS audit should be a concern for all US taxpayers. Many business professionals and individuals believe IRS agents must be experts in both accounting and tax law. In many cases, they are not expert in either discipline. This may sound shocking,...
The Rewards and Risks of International Business and Tax
Many would summarize business in the age of COVID-19 as the rewards and risks of international business and tax as global trade is re-established. The political winds weigh heavy upon the minds of many San Diego international business owners and corporate managers as they search for the best path forward....
California’s Unitary Method of Taxation Across State and National Borders
What is California's unitary method of taxation across state and national borders and how does it affect multi-state and multi-national corporations? The "unitary method" of taxation was developed to replace the "source method" strategy of taxation which would tax income based upon the geographic location where income was actually realized....
Janthan Allen Recognized by Marquis Who’s Who For Dedication to the Field of Law
Janathan Allen has been included in Marquis Who's Who for dedication to the field of law. As in all Marquis Who's Who biographical volumes, individuals profiled are selected on the basis of current reference value. Factors such as position, noteworthy accomplishments, visibility, and prominence in a field are all taken...
The Taxpayer Bill of Rights – 10 Fundamental Rights for US Taxpayers
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 fundamental rights in dealing with the Internal Revenue Service, and that IRS employees are expected to understand and apply taxpayer rights throughout their process. This applies to an IRS audit...
The Tax Danger of Personal Service Corporations
What is a Personal Service Corporation (PSC) and why is there a potential tax issue for PSCs? Many S Corporations and LLCs may be considered by the IRS to be a PSC. This could result in substantial additional business tax burdens. The IRS has again begun to examine corporations to...
IRS Revenue Officer Interviews Allow the IRS to Gain Additional Information to Use Against You
Why should you be cautious about IRS revenue officer interviews in San Diego? What are the risks to a US taxpayer in an IRS audit? If you have received a notice from the IRS regarding a tax audit you probably already realize the potential hazards you face in the immediate...
Guidance for Employers: Internal I-9 Verification Audits To Strengthen Immigration Compliance
The U.S. Immigration and Customs Enforcement provides guidelines to assist employers to voluntarily conduct internal I-9 verification audits. These audits may consist of reviewing all Forms I-9 or a sample of Forms I-9 based on neutral and non-discriminatory criteria in order to avoid the perception of discriminatory or retaliatory audits....