What is a "statute of limitations" and how does it apply to debts you to the IRS? If you are a target of IRS collections, how long does the IRS have to collect a valid tax debt? Is it possible for the IRS statute of limitations on collections to be...
IRS Audit Brings Many Challenges
An IRS audit brings many challenges to a US taxpayer. Here in San Diego, the IRS revenue officers or auditors are extremely aggressive. The first challenge for our clients is to remain calm. The IRS Notification of Audit letter is sure to make most hearts miss a beat. However, 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...
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...