San Diego businesses face increased IRS scrutiny of cross-border transfer pricing issues thanks to a new IRS LB&I audit campaign. The IRS has mobilized several specialists with extensive international business expertise into a team under their Large Business and International (LB&I) audit division. This IRS audit team is targeting small, mid-size and large business entities with cross-border business with “related” associated or affiliated entities. When you transfer goods, services or products between related or affiliated business entities you must conduct the transactions at “arm’s length” as if the two were not related in any way. This is known as “transfer pricing” and is supposed to preclude either party from gaining a tax advantage from the transaction.
The experienced international tax attorneys and accountants at Allen Barron have some good news for you:
You can substantially reduce or eliminate the likelihood of an IRS audit and the associated steep penalties and interest on transfer pricing violations.
The increased IRS scrutiny of cross-border transfer pricing issues requires a new strategy. In effect, we can help you to establish your own “transfer pricing standards” instead of having the IRS arbitrarily apply one to your companies. Allen Barron structures transfer pricing documentation for the IRS which details the specific relationship(s) between your company and any related or affiliated entity with whom you do business. This allows us to manage all transfers in a manner which maximizes the tax advantage for your interests as a whole, while complying with IRS transfer pricing requirements.
Allen Barron’s extensive international tax, accounting and legal expertise informs every aspect of your business, accounting and tax strategy while reducing costs by leveraging economies of scale. You receive the benefit of counsel which is informed by multiple disciplines, providing insight from a much higher and broader perspective. Learn about the potential for reducing costs, maximizing tax advantages and increasing profits through a relationship with Allen Barron. We invite you to contact us for a free consultation at 866-631-3470.