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,...
The IRS Has a Separate Team to Evaluate Transfer Pricing Transactions
The IRS has a separate team to evaluate transfer pricing transactions and cross-border business dealings for international businesses here in San Diego. If you are conducting cross-border transactions, or have multiple companies and transfer goods, services, or intangible assets between these affiliated companies you need the guidance and services of...
Amazon Savors a Huge Win Against IRS on Transfer Pricing
There has been a substantial development in the past week affecting international business as Amazon savors a huge win against the IRS on transfer pricing related tax disputes. The findings of a US Tax Court were stark: "The IRS acted in an arbitrary, capricious, and unreasonable manner when it applied...
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...
Recent International Business Developments Generate Cautious Optimism for Some
Several recent international business developments generate cautious optimism for some San Diego business owners. While we await the work the US Congress intends to do on corporate taxes and transfer pricing issues, news out of Mexico today regarding a historic memorandum between the Mexican Senate and the San Diego Regional...
IRS Focusing on Transfer Pricing and Offshore Earnings says Wall Street Journal
In a recent article the Wall Street Journal warned that the IRS had released information about 13 "campaigns" to target high-value tax returns for IRS audit. The IRS intends to focus upon and international businesses transfer pricing and offshore earnings and the compliance with IRS FBAR reporting and offshore account...
How will International Business Change in the Coming Months?
The question of the hour for many multi-national conglomerates and San Diego businesses with international distribution and supply channels is "How will international business change in the coming months?" The answer is surrounded in a cloud of Washington posturing and floated proposals. One thing seems certain: The United States Government...
Caterpillar an Example of IRS Focus on International Business
Caterpillar has become an example of the IRS focus on international business and the aggressive tax planning strategies employed by multinationals in an attempt to shield income from US taxation. Just last week, the President loudly proclaimed "I love Caterpillar!" This week, their headquarters were raided by federal agents looking...
Global Transfer Pricing Standards Released by OECD
The Organization for Economic Cooperation and Development or OECD is comprised of representatives of 34 member governments and market economies, and advises standards for members and more than 70 non-member countries to promote sustainable economic development, growth and prosperity. The OECD has released global transfer pricing standards designed to reduce...