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. ...
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...
The US Tax Impact of Opening a Foreign Account
What is the US tax impact of opening a foreign account for a US taxpayer including foreign nationals who live and work in the United States? The requirement for US taxpayers to report offshore accounts has been around for quite some time. In 2004, the IRS added penalties for non-willful...
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...
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...