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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. ...

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...

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...