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,...
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IRS Audit Campaigns
The LB&I IRS audit campaigns are a targeted combination of resources and expertise focused upon 13 separate areas. The IRS Large Business & International Group (LB&I) has established the following teams: IRC 48C Energy Credit Campaign - This campaign ensures that only those taxpayers whose advanced energy projects were approved...
How Should You Handle a Mistake on Your IRS Tax Return
What if you've discovered errors or omissions on your IRS tax return? How should you handle a mistake on your IRS tax return and subsequent communications from the IRS? It is not uncommon for the IRS to catch a simple math error on a US tax return. In many cases,...
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...
Does the New Corporate Tax Proposal Actually Create New Tax Shelter Opportunities?
The President's new corporate tax proposal rate of 15% may actually prove to create tax shelters for US taxpayers that would extremely difficult for the IRS to detect or pierce. At issue is the proposed 35% top individual tax rate and the 15% corporate tax rate which would apply to income...
The IRS Has a Separate Team to Evaluate Transfer Pricing Transactions
The IRS has a separate team to evaluate transfer pricing transactions and cross-border business dealings for international businesses here in San Diego. If you are conducting cross-border transactions, or have multiple companies and transfer goods, services, or intangible assets between these affiliated companies you need the guidance and services of...
Would Trump’s Tax Plan Cost Californians?
Would Trump's tax plan cost Californians and raise our taxes? There are too many trial balloons and false starts coming out of Washington on the "tax" front, but we are monitoring these developments and advising clients as they navigate the complex issues facing today's business owners. The latest income tax...
High Profile Trial May Shed Light on Willful Conduct in IRS FBAR Cases
A Pennsylvania Court has denied motions by both parties to dismiss a high profile trial which may shed light on willful conduct in IRS FBAR cases for US taxpayers. The CEO of a pharmaceutical company was accused by the IRS of willful failure to disclose Swiss bank accounts on his...
IRS FBAR Compliance for Canadian and Mexican Nationals in the US
If you live or work in the United States it is your responsibility to understand tax laws. This is why Allen Barron has been a leader in IRS FBAR compliance for Canadian and Mexican nationals living and working in the US. Many foreign nationals who reside or work here in...

