A request for public comment reveals the IRS is considering updates to the Voluntary Disclosure practice. The agency states its “commitment to improve its processes, and to further incentivize non-compliant taxpayers to come into compliance.” Key Takeaways Now That the IRS is Considering Updates to the Voluntary Disclosure Practice: The...
Is it Time to Rethink Your Offshore PFIC Investment(s)?
Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer? A Passive Foreign Investment Company or PFIC is a foreign corporation...
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...
An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2
Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are required to report all sources of income, worldwide, not just income...
ABCast Episode 18 – International Tax Strategies and Forms
ABCast Episode 18 - International Tax Strategies and Forms provides insights for any US taxpayer with offshore interests, and any international person or expat with US interests. Jan begins the conversation with an interesting observation: "I think the perception is that Americans don't realize that once they leave our shores and...
ABCast Episode 9 – International Tax Planning
Our Firm's podcast ABCast is pleased to release Episode 9 - International Tax Planning which as an overview of many legal and tax issues associated with international business, investments, financial accounts and assets. International tax planning is essential to protect your assets while minimizing the impact of taxation. The reporting...
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...
Cryptocurrency Can Lead to an Increased IRS Audit Risk
Did you know cryptocurrency can lead to an increased IRS audit risk? The IRS has taken a hard look at cryptocurrencies such as Bitcoin and now demands to know about any transactions you've conducted. The failure to report cryptocurrency holdings and transactions substantially increases your risk of an IRS audit....
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. ...