Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United States, your business model requires a level of sophistication that is much different from managing...
International Business and Offshore Investment and Banking Create Genuine IRS Risk
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise red flags with the IRS. The past several years have brought rapid change in FATCA compliance, and the...
The Potential Tax Impact of Foreign Investments for U.S. Taxpayers
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys to maximizing the advantages of offshore investment involves management of the effects of taxation...
Foreign Corporate Ownership and Investments
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments, and bank accounts need an experienced U.S. international tax attorney as well as integrative business, legal, and accounting services. ...
When to Consider the IRS Streamlined Procedures
What are the IRS streamlined filing compliance procedures (known more commonly as the “streamlined procedures”), and when should a US taxpayer consider the IRS streamlined procedures to come into compliance with IRS reporting requirements? US taxpayers have been required to disclose offshore accounts and foreign financial activities to the IRS...
Part 2 – International Tax Primer for US Taxpayers and Expatriates
Common Forms Associated with Foreign Asset and Income Reporting to the IRS We continue with Part 2 - International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified Foreign...
Is a PFIC Still a Good Investment Strategy
We are often asked "Is a PFIC still a good investment strategy based upon IRS taxation and recent offshore developments?" The answer is simple: the income it generates must be substantial enough to pay a heavy tax which the IRS levies on PFICs. The Passive Foreign Investment Company or PFIC...
Failure to Make a Full Disclosure of Offshore Accounts to the IRS
What are the risks and penalties of the failure to make a full disclosure of offshore accounts to the IRS? What happens if you have not included all of your offshore bank accounts, assets, investments, foreign trust and foreign corporate ownership interests to the IRS via FBAR or associated IRS...
Transfer Pricing is a Central International Business Tax Issue
Transfer pricing is a central international business tax issue. How does this affect San Diego area and California multi-national businesses? Transfer pricing is the allocation of income or loss between members of a "controlled group." From the IRS' point of view, a company is part of a controlled group when...