When Dealing with an IRS Audit you Need to Know Your Rights

When Dealing with an IRS Audit you Need to Know Your Rights

When dealing with an IRS audit you need to know your rights.  Managing conversations with the IRS during an audit is not only nerve racking and challenging.  It can expose you to additional tax liability and financial risk.  However, when you do have to deal with an IRS audit or agent you have rights that […]

Transfer Pricing is Key for International Business Taxation Strategies

Transfer pricing is key for international business taxation strategies.  Transfer pricing is the cost paid for goods or services exchanged between affiliated corporations.  Transfer pricing has increasingly become a target for the IRS and California state taxation agencies.  Transfer pricing is also one of the primary ingredients for many international business taxation strategies.  These transfers […]

An IRS Tax Audit Opens the Door for California Tax Agencies

Did you know that an IRS tax audit opens the door for California tax agencies?  If you receive a notification from the agency regarding an IRS audit, you have several immediate concerns.  Your tax attorney and accounting professional at Allen Barron will provide extensive guidance on what to expect from an IRS audit and prepare […]

FBAR ALERT: IRS OVDP Ends in 18 Days

The IRS OVDP ends in 18 days as the IRS ramps up to pursue tax evaders.  For all US taxpayers with unreported offshore bank accounts, deposits, investment accounts, real estate and other assets this important deadline is fast approaching.  The consequences for failure to comply with US tax laws will be severe. If you have […]

September 28 is the Deadline for US Taxpayers with Offshore Accounts

September 28 is the deadline for US taxpayers with offshore accounts to come into compliance with IRS FBAR reporting requirements through the Offshore Voluntary Disclosure Program or OVDP.  US taxpayers who have yet to declare offshore bank accounts, investment accounts and assets have just over 3 weeks to declare these to the IRS or face […]

Manafort Conviction Includes Failure to File an FBAR

The news today that the Manafort conviction includes failure to file an FBAR is an example of two crucial IRS principles: willful blindness is no excuse under the law, and, the IRS will always use the failure to file an FBAR against US taxpayers.  The IRS concept of “willful blindness” addresses a standard US taxpayer […]

Business Disputes Require Experience and Negotiation Skill

Business disputes require experience and negotiation skill to ensure the best possible outcome.  Allen Barron’s skilled dispute resolution team resolve business disputes while accomplishing your goals. The fact is most business disputes are resolved by our skilled attorneys through negotiation.  This is based upon several important factors: business realities time expense contingent liability Business realities […]

IRS Partnership Audit Process Continues to Develop

The IRS partnership audit process continues to develop.  The “centralized audit regime” fundamentally changed the way the IRS audited partnerships.  On August 9 of this year the IRS released final regulations regarding naming the partnership representative, as well as the process to remove or replace this designated representative for all IRS tax matters. The final […]

Many In San Diego Will Pay More Taxes This Year

Recent tax reforms are not going to bring tax cuts for many typical households across California.  Many in San Diego will pay more taxes this year as the majority of deductions and write-offs of the past have been eliminated.  A recent article in the Sacramento Bee noted “about 751,000 households with incomes under $250,000 probably […]

Do You Have Too Many PALs?

Do you have too many PALs or “Passive Activity Losses” due to investments or real estate?  The challenge with Passive Activity Losses is they must be used to offset Passive Income Generators or PIGs.  The strategic use of PIGs and PALs is going to be crucial for many San Diegans under the new tax system. […]

← Older posts