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IRS Audits Focused Upon OVDP Declines and Withdrawls

A new IRS Large Business & International (LB&I) campaign targets US taxpayers for IRS audits focused upon OVDP declines and withdrawls from the FBAR related program.  Once the IRS implemented FATCA based regulations and the associated Foreign Bank Account Reporting (FBAR) requirements US taxpayers were required to disclose all offshore...

Increased IRS Scrutiny of Cross-Border Transfer Pricing Issues

San Diego businesses face increased IRS scrutiny of cross-border transfer pricing issues thanks to a new IRS LB&I audit campaign.  The IRS has mobilized several specialists with extensive international business expertise into a team under their Large Business and International (LB&I) audit division.  This IRS audit team is targeting small,...

Jan Allen to Speak on IRS FBAR and Willfulness

On October 11, 2017 from noon to 2:00 pm pacific time, Jan Allen will speak on IRS FBAR and willfulness during a live webcast entitled: "Willfulness and the IRS Disclosure Programs: Are You Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and work...