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IRS Audits Focused Upon OVDP Declines and Withdrawls

A new IRS Large Business & International (LB&I) campaign targets US taxpayers for IRS audits focused upon OVDP declines and withdrawls from the FBAR related program.  Once the IRS implemented FATCA based regulations and the associated Foreign Bank Account Reporting (FBAR) requirements US taxpayers were required to disclose all offshore...

Increased IRS Scrutiny of Cross-Border Transfer Pricing Issues

San Diego businesses face increased IRS scrutiny of cross-border transfer pricing issues thanks to a new IRS LB&I audit campaign.  The IRS has mobilized several specialists with extensive international business expertise into a team under their Large Business and International (LB&I) audit division.  This IRS audit team is targeting small,...

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...