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...
Did Facebook Undervalue Transfer Pricing of Assets in 2010 Ireland Transfer?
The IRS has decided to sue Facebook. The central issue is the IRS belief that Ernst & Young, Facebook's accounting firm, purposefully understated value in the transfer pricing of assets transferred to Facebook's Irish corporate entity. Transfer pricing may be the central legal and accounting issue that determines millions if...
FBAR Electronic Filing Due June 30 – No Extensions
If you had a financial interest in a foreign financial account, or signatory or authority over one or more accounts whose aggregate value exceeded $10,000 USD at any point in 2015, you are required to file an IRS FBAR (Report of Foreign Bank and Financial Accounts). You must submit the FBAR...
Medtronic Beats IRS in Complex Tax Matter Involving Transfer Pricing
Medtronic PLC, a medical device manufacturer who used to have operations in Puerto Rico, has defeated the IRS in US Tax Court, resolving a $1.4 billion dispute. The key issue in the case centered on transfer pricing - transactions between different divisions or companies owned by the same corporation or...
Expert Tax Preparation in Rancho Bernardo and San Diego
Are you looking for expert tax preparation in Rancho Bernardo or San Diego? Do you face complex taxation issues such as offshore income or investments, business ownership, or high income? The experienced and seasoned tax preparation team at Allen Barron are uniquely positioned to review your unique circumstances and provide...
Effective Contracts are Key to Supply Chain Management
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Business & Contracts on Wednesday, November 11, 2015. Effective business contracts are one of the keys to supply chain management. Most mid-sized to large businesses understand the critical nature of controlling costs associated with your supply chain and...