IRS revenue agents and auditors create many unnecessary challenges for multinational businesses who utilize internal transfers to gain a tax advantage. This presents major obstacles during an IRS audit involving transfer pricing and other international tax related issues. The experienced international tax and business attorneys at Allen Barron, supported by...
California FTB or IRS Levy or Garnishment in San Diego
Allen Barron is uniquely positioned to help those who face a California FTB or IRS levy or garnishment in San Diego or southern California. Our IRS tax attorneys have specific strategies to deal with California and IRS tax collection efforts. If you owe the IRS more than $25,000 it is...
Why Shouldn’t You Try to Handle an IRS Audit Yourself and Call an Attorney Later if Things Don’t Go Well?
Have you received notification of an IRS audit? Will it be a field audit or office audit? Why shouldn't you try to handle an IRS audit yourself and call an attorney later if things don't go well? The simple answer is it will be too late to do anything about...
Would You Prefer to Write a Large Check during an IRS Audit …
Or write a much smaller check that will reduce the cost of the audit? If you have been contacted by the IRS for a field audit or office audit it is important to understand they have already developed a strategy for your audit. They have a revenue target associated with...
If You are an Executor in San Diego You Need an Attorney
You were honored when your close friend or family member asked you serve as the executor of their estate. You did not realize the amount of the work associated with the task. You also didn't realize you were personally financially liable for your actions as an executor. If you are...
The California Waters Edge Election
What is the California Waters Edge Election and how does that affect taxation for certain taxpayers with offshore business income and assets? The California water's edge election was established in 1986 and was designed to restrict California's "application of the worldwide combined reporting method of determining income from California sources." Instead...
US Treasury and IRS Update Guidance on PFICs and CFC Investments
Recently the US Treasury Department and the Internal Revenue Service (IRS) released new guidance on PFICs and CFC investments for a Regulated Investment Company (RIC). Under US tax law a corporation can qualify as a Regulated Investment Company for a given tax year only when 90% or more of...
Brazilian FATCA Offshore Disclosures Net $4 Billion US
The deadline for Brazil's offshore account, income and asset reporting passed last week. The Brazilian Federal Revenue Secretariat (SRF) - Brazil's equivalent of the IRS - claims more than $4 Billion (US) in revenues from voluntary disclosures much like the US Offshore Voluntary Disclosure Program or OVDP. The Brazilian FATCA offshore...
Argentina’s Aggressive Offshore Tax Strategy Results in Threat to Account Holders of Major US Bank
The implementation of global forms of the US FATCA tax initiative, often referred to as GATCA (Global FATCA) continue to gain steam in Central and South America. This week a major US bank threatened to close the accounts of Argentinians with "undeclared funds." JP Morgan announced this week that "all funds...