What is a PFIC and how could your offshore investments actually lead to a higher taxation rate on earned income? A Passive Foreign Investment Company or PFIC is classified by the IRS in two ways: 75% or more of the income from the foreign corporation is classified as "passive income,"...
Streamlined Domestic Offshore Procedures Still a Viable Option for Foreign Nationals
The offshore focus of the US Treasury Department and the IRS is well documented, and many questions remain for those who have either yet to take action to come into compliance with IRS FBAR and offshore reporting or for foreign nationals who may not have realized the requirements. Our office...
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...
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...
The IRS has Begun Data Mining for Offshore FBAR Audit Targets
It's official. The FBAR audit warnings and IRS data mining you've been reading about in this space for the past several years have been confirmed by the Wall Street Journal (WSJ): U.S. Mining Swiss Bank Data to Find Tax Cheats It wasn't a question of "if" it was a question...
How Can an Experienced San Diego IRS Audit Attorney Help You?
One of the first questions a taxpayer will ask themselves after receiving a "Letter of Notification" from the IRS regarding an audit is "Do I need an attorney?" How can an experienced San Diego IRS audit attorney help you, and is it worth the money it may cost? The first...
What Impact will the Inspector General’s Report Have on the OVDP and Offshore IRS Violators?
The Inspector General's office recently released a scathing report accusing the IRS of missing more than $39 Million in uncollected offshore tax revenues. The report harshly criticized the IRS' complete failure to follow up on rejected OVDP and offshore IRS violators as well as internal assignment of personnel based upon...
IRS Missed $39 Million in OVDP Penalties
The US Treasury Department's Inspector General for Tax Administration has determined that the IRS missed an opportunity to collect over $39 Million in OVDP penalties from taxpayers who were either rejected or withdrew their application to the OVDP or Offshore Voluntary Disclosure Program. In a press release, Inspector General J....
IRS to Retire PIN System – How to Protect Your Business Information
The IRS announced plans to retire the automated PIN system for filing returns electronically, due to extensive hacking and compromised personal and business information of more than half a million US taxpayers. Despite its best efforts the IRS has not been able to protect your business information or your personal...