In a recent article the Wall Street Journal warned that the IRS had released information about 13 “campaigns” to target high-value tax returns for IRS audit. The IRS intends to focus upon and international businesses transfer pricing and offshore earnings and the compliance with IRS FBAR reporting and offshore account and income disclosures. Allen Barron is uniquely positioned to serve and protect businesses and individuals in both of these complex legal and tax matters. We provide a single-source solution for our clients that provides a much deeper and more comprehensive insight and perspective on all issues facing international businesses and clients with international bank and investment accounts.
Transfer pricing and offshore earnings are controversial issues and have often been raised by the new administration as a reason behind corporate tax reform. The IRS believes American businesses are shielding offshore income from US taxation through transfer pricing strategies and processing of goods, services and revenues through a complex web of offshore corporate entities. One of the new IRS campaigns focuses squarely on business entities with transfer pricing components within their corporate tax returns. IRS auditors will be searching for related party transactions between commonly owned or controlled entities and the transfer of funds between corporations and pass-through entities or shareholders.
The IRS is also focusing audits on those who filed for the Offshore Voluntary Disclosure Program or OVDP and either withdrew voluntarily or were denied by the IRS. The OVDP is designed to allow US taxpayers with previously undisclosed offshore bank accounts, investments and income to come into compliance through updated FBAR reporting while paying 27.5% to 50% penalties based upon the OVDP program and the extent to which a bank or financial institution has been labeled by the IRS.
Are you concerned about the new IRS focus upon transfer pricing and offshore earnings for international businesses and those with offshore bank and financial accounts? Allen Barron provides international tax, corporate and international business law and accounting services as well as IRS and California tax preparation and representation in tax audits and collection matters. We invite you to contact us or call 866-631-3470 for a free consultation to discuss your international business, corporate taxes, personal income taxes or offshore tax reporting through FBAR and the IRS OVDP or Streamlined Application process. Learn about the unique protections of the attorney-client privilege and the economies of scale of integrating the disciplines of corporate attorneys, tax attorneys, CPAs and accounting, tax preparation and international business advisory and consultation under a single vendor.
