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...
How was the IRS Audit Window Recently Expanded from 3 Years to 6 Years?
How was the IRS audit window recently expanded from 3 years to 6 years? What changes provided the IRS with more power to go back into prior year's returns than ever before? The standard IRS statute of limitations for an IRS audit was considered to be 3 years. The key...
IRS FBAR Submission is Due June 30 – Come Into FBAR Compliance
If you are a US expatriate or a taxpayer with offshore accounts, investments, assets or income you should be aware your IRS FBAR submission is due June 30 of this year. Starting next year, FBAR reporting will coincide with the normal IRS deadline of April 15. The FBAR or IRS Foreign Bank...
Once Contacted by the IRS – You Cannot File OVDP or other FBAR Compliance
The IRS Offshore Audits Have Begun The IRS has begun the first round of offshore income, asset and bank account reporting audits, and once contacted by the IRS a taxpayer cannot file OVDP or other FBAR compliance paperwork or applications. At this point the only alternative is to contact the...
Is the IRS Offshore Voluntary Disclosure Program or OVDP the Right Alternative for FBAR Compliance?
FATCA has completely changed the international financial landscape - from FBAR crackdowns to the "Panama Papers." Recently, many people have asked "Is the IRS Offshore Voluntary Disclosure Program or OVDP the right alternative for FBAR compliance or should I/we consider the streamlined application? The central question from the perspective of...
Don’t Let IRS Impeachment Hearings Fool You – The IRS Offshore and FBAR Audits Aren’t Going Anywhere but Up
Don't be distracted by the US House of Representatives hearings where they are attempting to impeach IRS Commissioner John Koskinen. The commissioner stands accused of many allegations including lying to congress, abuse of power and other acts that diminish confidence in one of the US Government's most powerful agencies. Meanwhile,...
International or Foreign Trusts May Cause More Problems Than They Solve
We have seen several recent examples of people who were convinced to set up international or foreign trusts in order to "shield income and assets" from needless taxation. No, these aren't foreign citizens with foreign interests, they are US taxpayers who have been convinced to open a foreign trust which...
San Diego FBAR Attorneys Guide Offshore Compliance with IRS
If you have offshore accounts, investments or assets and have not come into compliance with the IRS, you should contact the San Diego FBAR attorneys at Allen Barron, who will provide guidance and insight into your options and help to ensure the best outcome in your case. Which voluntary disclosure...
700 New IRS Auditors to Target Small Business and Self Employed
The Wall Street Journal recently examined plans for 700 new IRS auditors who will be added to the IRS department that specifically monitors small business and the self-employed. IRS Commissioner John Koskinen claims the new money was found as a result of retirements, internal turnover, and other "efficiencies." Lawmakers are...