Transfer pricing is key for international business taxation strategies. Transfer pricing is the cost paid for goods or services exchanged between affiliated corporations. Transfer pricing has increasingly become a target for the IRS and California state taxation agencies. Transfer pricing is also one of the primary ingredients for many international...
Could the New Tax Bill Allow Repatriation of Offshore Funds
Could the new tax bill allow repatriation of offshore funds at a lower tax rate? It is believed that US non-financial companies have almost $2 Trillion (yes, Trillion with a "T") and 70% of that money is located overseas as US corporations structured companies and transactions to move income to...
Transfer Pricing Audits Focus on International Businesses
IRS transfer pricing audits focus on international businesses and the transfer of goods and/or services between affiliated companies. The IRS recently established a new Large Business & International (LB&I) audit team specifically tasked with reviewing US businesses and multinational corporations with exchanges between companies within the same constellation of corporate entities. ...
What is the State of Globalization and International Business?
The Wall Street Journal recently asked an international expert the question "What is the state of globalization and international business based upon current events?" The rise of populist nationalism in the United States and around the world caused many business leaders and market observes to be concerned about the death of...
Transfer Pricing Strategies and Selection
There are several different factors which affect transfer pricing strategies and selection of the specific method which provides the greatest procedural and tax advantage while meeting the guidelines of the IRS and other sovereign tax agencies. Each situation is unique and the selection of the most appropriate and applicable transfer...
Many Working in the US on an H1-B Visa Need to Understand IRS PFIC Taxation
Many professionals and scientists working in the US on an H1-B visa need to understand IRS PFIC taxation and the implications of continuing many offshore investments. What are PFICs and why would high income professionals in the US on an H1-B visa need to understand IRS PFIC taxation rules? The challenge...
Is the US the New Tax Haven
Is the US the new tax haven now that the world is following international disclosure laws? After pushing FATCA and international banking reporting requirements on more than 110 nations worldwide, the US is ironically resisting global disclosure standards. This is much to the dismay of many former Swiss and european...
Is a Standardized Transfer Pricing Policy a Social Responsibility?
An interesting article in the New York Times recently raised the issue of a standardized transfer pricing policy as a social responsibility. In today's global economy the issue of transfer pricing has become a central focus for many governments, including the United States. The IRS recently announced the formation of...
Planning for the Risks of a Cross Border Business in San Diego
These are volatile times and planning for the risks of a cross border business in San Diego has never been more important. Signals from Washington have been mixed, yet the probability of a border tax continues to loom for US based businesses here in San Diego. How will future developments...