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...
International Business Tax Returns Require Detailed Knowledge
There are many businesses with global interests here in San Diego. Tax time can be especially challenging as international business tax returns require detailed knowledge and experience. The international business and tax attorneys at Allen Barron provide a comprehensive palette of services including tax, accounting, legal and tax return preparation...
The Value of Integrated Services to an International Business Strategy
What is the value of integrated services to an international business strategy? Allen Barron provides integrated legal, tax, business advisory and accounting services to local, regional, national and international businesses. The integration of these services reduces the cost paid to separate vendors while providing a higher-level broader perspective to problem...
Costly Facts About IRS PFIC Rules US Taxpayers Should Know
What are some other unfortunate and costly facts you must know about IRS PFIC rules and your investments? There has been a growing issue with Passive Foreign Investment Company or PFIC designations by the IRS. US taxpayers are consistently surprised to learn that their investment qualifies under IRS PFIC rules....