What is the value of integrated consulting, legal, tax, and accounting services? Just before the millennium, a group of prominent professional service companies was known as “The Big Eight.” The Big Eight included Arthur Anderson, Arthur Young (now known as simply AY), Coopers & Lybrand, Deloitte Haskins and Sells (now...
Connelly v. Internal Revenue Service is a Game Changing Decision for every U.S. Privately Held Company
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 from a personal estate planning point of view. The core issue of the case focused on the corporate contractual requirement...
How Did Moore v. United States Change U.S. Tax Law?
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 whether income could be taxed before it is “realized.” The Court avoided this...
Preparing to Sell Your Business
There are several steps to follow when preparing to sell your business. It is important to allow plenty of time for planning and organization, as the process will usually require many months to a year or more. Why does it take so long to prepare your business for sale? The...
The Step-Up Benefit of a Revocable Trust
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? The answer lies in an understanding of the short-term and long-term...
ABCast Episode 25 – US Expatriate Tax Planning – Part 2
In ABCast Episode 25 - US Expatriate Tax Planning - Part 2, we pick up the conversation regarding tax and legal issue U.S. expatriates might face and how Allen Barron can help. The discussion turns to real estate matters, and the issue of moving money from the United States to...
How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful? If you have accounts with any Foreign Financial Institutions...
What to do if You Receive an IRS Audit Notification Letter
What should you do if you receive an IRS audit notification letter? Why should you consider engaging experienced IRS audit and tax attorney Janathan Allen, who represents U.S. taxpayers facing an IRS audit or any other federal or state tax issue. There are several things you should know if you...
Remarriage and a Blended Family – It’s Time for a New or Updated Estate Plan
Are you considering remarriage? Do you and/or your spouse have children from a previous marriage? If so, remarriage and a blended family are excellent reasons for a new or updated estate plan. Blended families are quickly becoming the "norm" here in San Diego and across the U.S. What do you...