Have you come into the San Diego area on an H1-B visa in order to work in one of our high tech or research companies? What does a professional foreign national working in San Diego need to know about the IRS, offshore account and asset reporting and FBAR compliance? Many...
Tax Implications of Offshore Corporate Ownership
Business today is often global in nature, and San Diego businesses must often be ready to integrate into the global community. How do you structure your companies to do this? What are the tax implications of offshore corporate ownership and investments? The primary questions relate to moving the booking of...
Transfer Pricing and International Business Issues
San Diego companies serving global markets often face transfer pricing and international business issues that increase risk and contingent liability. The international business and tax attorneys at Allen Barron have extensive expertise and experience in multiple aspects of international business. We are uniquely positioned to provide single-source service for those...
Lawsuit against IRS Offshore Tax Programs Dismissed
Another lawsuit challenging the IRS offshore tax programs has been dismissed. In the consolidated lawsuit, 3 plaintiffs attempted to assert that they should be able to switch to the IRS' streamlined domestic offshore procedures, which were not available when the 3 filed applications under the OVDP or Offshore Voluntary Disclosure...
Willful or Non-Willful Attempt to Avoid US Taxes?
There continues to be confusion regarding what constitutes a willful or non-willful attempt to avoid US taxes as it relates to offshore bank accounts, investments, assets and income. The IRS has purposefully failed to clarify this issue over the past 7 years. This is the first piece of evidence a...
Foreign Nationals Should Beware of PFICs
Many foreign nationals live and work in the US. For those who are permanent residents or have received their green card or other qualifying visa, it is important to understand your requirements as a US taxpayer and the impact your foreign investments may have upon the taxes you will owe...
Experienced San Diego OVDP Attorney Explains Advantages of IRS Offshore Disclosures
Why should a US taxpayer consider the Offshore Voluntary Disclosure Program or OVDP to come into compliance with IRS FBAR and offshore reporting requirements? Janathan Allen, an experienced San Diego OVDP attorney explains the advantages of IRS offshore disclosure programs, and why it is important to comply: FATCA established an...
The World is Becoming Much Smaller for Tax Evasion
It is a bitter pill to swallow. There are fewer and fewer secrets. The world is becoming much smaller for tax evasion and the authorities have broken the backs of banks and financial institutions worldwide. They have used FATCA to drag huge Swiss Banks and Cayman Island institutions into court...
Foreign Nationals Must Meet FBAR Compliance – Residing or Working in US
For those who are residing or working in the United States it is important to understand foreign nationals must meet FBAR compliance and reporting. Many professionals working under an H1-B visa, or those who are married to US citizens do not realize they must make a full disclosure of their...