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...
International Business and Offshore Investment and Banking Create Genuine Risk with the IRS
International business and offshore investment and banking create genuine risk with the IRS. This extends to the ownership of real estate outside of the US 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...
International Business Dealings Require Strong Tax Legal and Accounting Support
Why do international business dealings require strong tax, legal and accounting support? International business deals require a level of sophistication that is much different from managing a business locally or regionally. International business dealings involve transactions that require insight from several perspectives including: The legal structures that allow you to partner...
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...
The Tax Implications of Offshore Bank Accounts and Investment
What are the tax implications of offshore bank accounts and investments as well as foreign corporate ownership? Allen Barron is uniquely positioned to provide proven international tax advice, as well as legal counsel and supporting accounting services. Tax, legal and accounting in a single source vendor. The IRS and California's...
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...
The Rewards and Risks of International Business and Tax
Many would summarize business in the age of COVID-19 as the rewards and risks of international business and tax as global trade is re-established. The political winds weigh heavy upon the minds of many San Diego international business owners and corporate managers as they search for the best path forward....