IRS transfer pricing audits focus on international businesses and the transfer of goods and/or services between affiliated companies. The IRS recently established a new Large Business & International (LB&I) audit team specifically tasked with reviewing US businesses and multinational corporations with exchanges between companies within the same constellation of corporate entities. ...
Starting a New Company Requires Integrated Expertise
Starting a new company requires integrated expertise across multiple disciplines including legal, tax, business advisory and accounting services. Allen Barron seamlessly integrates these services in a start-up package for entrepreneurs working to bring their dreams into reality. Starting a new company is much more than filling out a few forms...
Unusual Non-Willful Court Decision in Pennsylvania FBAR Case
A recent case in the United States District Court for the Eastern District of Pennsylvania has turned the recent tide of IRS victories regarding "willful versus non-willful" intent in FBAR related compliance cases. The unusual non-willful court decision found the US taxpayer was not "willful" when failing to report one...
Jan Allen Speaks on a National IRS FBAR Panel Tomorrow
Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern. The topic of the expert panel discussion is "Willfulness and the IRS Disclosure Programs. Are you Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and...
What is the State of Globalization and International Business?
The Wall Street Journal recently asked an international expert the question "What is the state of globalization and international business based upon current events?" The rise of populist nationalism in the United States and around the world caused many business leaders and market observes to be concerned about the death of...
Initial Analysis of the Proposed Corporate Tax Plan on International Business and S Corporations
Our initial analysis of the proposed corporate tax plan on international business and S Corporations shows a mixed bag of moving pieces. Generally speaking, the plan calls for a corporate tax cut from the present rate of 35% to 20%. One interesting component is the replacement on the tax of...
The IRS Will Never Know About My Offshore Financial Accounts
We often hear clients say "The IRS will never know about my offshore financial accounts and assets," with conviction as if they are wishing it to be true. Unfortunately, the reality of today's world is much different. The truth of the matter is shocking to many people: The IRS is...
How Should a Couple Take Title to Their Home
How should a couple take title to their home if they intend to keep it? How is the asset to be taxed after both spouses pass? Many couples keep the asset in "Joint Tenancy" which allows the asset to avoid probate upon the death of one of the spouses. Upon...
New Tax Proposal Includes a 25% Pass Through Corporate Tax
While it is far too soon to draw conclusions on Washington's proposed tax reforms, the impact on LLC and S Corporations looks to be significant. The new tax proposal includes a 25% pass through corporate tax which could affect the majority of American business owners. Pass through profits are presently...