The administration is planning a major speech for tomorrow to begin the national conversation on corporate tax cuts and a new tax plan for US business and personal interests. The present consensus is light on specifics and heavy on the need to deliver substantial tax cuts before the end of...
Transfer Pricing Strategies and Selection
There are several different factors which affect transfer pricing strategies and selection of the specific method which provides the greatest procedural and tax advantage while meeting the guidelines of the IRS and other sovereign tax agencies. Each situation is unique and the selection of the most appropriate and applicable transfer...
Is a Standardized Transfer Pricing Policy a Social Responsibility?
An interesting article in the New York Times recently raised the issue of a standardized transfer pricing policy as a social responsibility. In today's global economy the issue of transfer pricing has become a central focus for many governments, including the United States. The IRS recently announced the formation of...
WSJ Notes Regulatory and Technical Accounting Expertise in Short Supply
A recent article in the Wall Street Journal (WSJ) notes regulatory and technical accounting expertise is in short supply across the nation. WSJ noted US businesses were "increasingly scrambling to find regulatory experts or “technical accountants” who understand rules and ensure compliance amid accounting changes to the generally accepted accounting...
Was the Caterpillar Raid a Sign of Where Corporate Tax Battles are Headed?
Really? That was my first reaction to the news that federal agents including the IRS had raided the offices of Caterpillar, one of America's greatest traditional companies. My next reaction was a bit more harsh, trending toward disgust. Is this a sign of where corporate tax battles are really headed?...
Tax Implications of Offshore Corporate Ownership
Business today is often global in nature, and San Diego businesses must often be ready to integrate into the global community. How do you structure your companies to do this? What are the tax implications of offshore corporate ownership and investments? The primary questions relate to moving the booking of...
Transfer Pricing and International Business Issues
San Diego companies serving global markets often face transfer pricing and international business issues that increase risk and contingent liability. The international business and tax attorneys at Allen Barron have extensive expertise and experience in multiple aspects of international business. We are uniquely positioned to provide single-source service for those...
Mergers and Acquisitions In Order to Shift Corporate Taxation Offshore
There are a lot of questions around the practices made popular by Apple, Google and Microsoft regarding offshore entities and mergers and acquisitions in order to shift corporate taxation offshore to lower taxation jurisdictions. How can offshore strategies benefit small to mid-sized San Diego businesses who wish to reduce taxation...
Treasury Department and IRS Propose Changes to Offshore Business Taxes and Inversion
The US Treasury Department and the IRS to propose changes to offshore business taxes and a practice known as "Inversion." A hearing yesterday brought stiff resistance from representatives in the business community and others seeking to preserve offshore tax advantages. "Inversion" is one of the specific strategies addressed in the...