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IRS Tells Taxpayers “I Didn’t Know” Won’t Work – OVDP the Safest Option for FBAR Compliance

Many taxpayers had hoped that telling the IRS "I didn't know" and submitting a streamlined disclosure application would get them through FBAR disclosures quickly and inexpensively.  After all, the streamlined options reduces penalties down to 5% is the IRS accepts the streamlined application when compared to the OVDP or the...

How Successful Will Your New San Diego Company Be? Look at Your Business Contracts

How successful will your new San Diego company be?  The clearest forecast of any new business is the quality of their business contracts and the clarity they bring to all aspects of running a company such as: Employment Agreements Corporate Policies and Procedures Contracts with Suppliers and Vendors Sales Agreements...

Why does the IRS OVDP Reduce Risk for US Taxpayers in Offshore FBAR Disclosures?

Why is the IRS OVDP or Offshore Voluntary Disclosure Program the safest choice for US taxpayers coming into compliance with IRS FBAR disclosures?  How does the OVDP reduce risk for US citizens and foreign resident nationals who are required to file US tax returns?  The key issue is the IRS'...

San Diego OVDP Attorney Advises Foreign Nationals who Reside in US

At Allen Barron, we support many leading engineering, high-tech companies and other businesses who attract and employ foreign nationals based upon their unique education, expertise and skill sets.  For many of these clients, it is a complete surprise that foreign nationals who are legally working in the US are still...

Medtronic Beats IRS in Complex Tax Matter Involving Transfer Pricing

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...