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The IRS Has a Separate Team to Evaluate Transfer Pricing Transactions

The IRS has a separate team to evaluate transfer pricing transactions and cross-border business dealings for international businesses here in San Diego.  If you are conducting cross-border transactions, or have multiple companies and transfer goods, services, or intangible assets between these affiliated companies you need the guidance and services of...

IRS Large Business and International Division Targeting TEFRA Violations

The IRS Large Business and International Division (LB&I) will be targeting TEFRA violations in partnerships based upon recent changes in partnership related tax law.  TEFRA (The Tax Equity and Fiscal Responsibility Act of 1982) regulations applying to partnerships created a set of consolidated IRS audit (examination), processing and judicial procedures which...

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...