Medtronic PLC, a medical device manufacturer who used to have operations in Puerto Rico, has defeated the IRS in US Tax Court, resolving a $1.4 billion dispute. The key issue in the case centered on transfer pricing - transactions between different divisions or companies owned by the same corporation or...
Trust Disputes in San Diego Require a Seasoned Attorney
Trust disputes in San Diego require a seasoned attorney with expertise not only in California trust law, but accounting and tax expertise as well. The attorneys at Allen Barron, led by Janathan Allen are uniquely positioned to provide insight into your concerns, and provide a comprehensive financial, legal and tax...
How was the IRS Audit Window Recently Expanded from 3 Years to 6 Years?
How was the IRS audit window recently expanded from 3 years to 6 years? What changes provided the IRS with more power to go back into prior year's returns than ever before? The standard IRS statute of limitations for an IRS audit was considered to be 3 years. The key...
IRS FBAR Submission is Due June 30 – Come Into FBAR Compliance
If you are a US expatriate or a taxpayer with offshore accounts, investments, assets or income you should be aware your IRS FBAR submission is due June 30 of this year. Starting next year, FBAR reporting will coincide with the normal IRS deadline of April 15. The FBAR or IRS Foreign Bank...
Once Contacted by the IRS – You Cannot File OVDP or other FBAR Compliance
The IRS Offshore Audits Have Begun The IRS has begun the first round of offshore income, asset and bank account reporting audits, and once contacted by the IRS a taxpayer cannot file OVDP or other FBAR compliance paperwork or applications. At this point the only alternative is to contact the...
Why do You Need a Trust in San Diego?
Why do you need a trust in San Diego and how can it save you a substantial amount of money? A trust provides protection for your assets, investments and accounts and provides an additional layer of separation between an individual and any creditor seeking to collect against a liability or...
Starting a New Company in San Diego Requires an Experienced Attorney
Starting a new company in San Diego requires an experienced attorney who can provide sound counsel and advice based upon years of advising other businesses. Learn from their experiences, and put yourself in a stronger position to compete right from the start. Downloaded business formation documents or copying contracts off the...
What to do if You Receive an IRS Audit Notice in San Diego
What should you do if you receive an IRS audit notice in San Diego and how can you best protect your interests? The first step is to download our free white paper "What to Expect from an IRS Audit." This helpful guide takes you through the process of an IRS...
Is the IRS Offshore Voluntary Disclosure Program or OVDP the Right Alternative for FBAR Compliance?
FATCA has completely changed the international financial landscape - from FBAR crackdowns to the "Panama Papers." Recently, many people have asked "Is the IRS Offshore Voluntary Disclosure Program or OVDP the right alternative for FBAR compliance or should I/we consider the streamlined application? The central question from the perspective of...