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,...