Transfer pricing is a central international business tax issue. How does this affect San Diego area and California multi-national businesses? Transfer pricing is the allocation of income or loss between members of a "controlled group." From the IRS' point of view, a company is part of a controlled group when...
International Business Tax Returns Require Detailed Knowledge
There are many businesses with global interests here in San Diego. Tax time can be especially challenging as international business tax returns require detailed knowledge and experience. The international business and tax attorneys at Allen Barron provide a comprehensive palette of services including tax, accounting, legal and tax return preparation...
Transfer Pricing is Key for International Business Taxation Strategies
Transfer pricing is key for international business taxation strategies. Transfer pricing is the cost paid for goods or services exchanged between affiliated corporations. Transfer pricing has increasingly become a target for the IRS and California state taxation agencies. Transfer pricing is also one of the primary ingredients for many international...
Changes to Accounting Rules Affect Realization of Income for Public Corporations
Recent changes to accounting rules affect realization of income for public corporations to take effect December 15 of this year. The new accounting standard will have an impact on the details companies must capture affecting everything from corporate financials to domestic and international tax accounting. The new rules replace virtually...
Transfer Pricing Audits Focus on International Businesses
IRS transfer pricing audits focus on international businesses and the transfer of goods and/or services between affiliated companies. The IRS recently established a new Large Business & International (LB&I) audit team specifically tasked with reviewing US businesses and multinational corporations with exchanges between companies within the same constellation of corporate entities. ...
Transfer Pricing Strategies and Selection
There are several different factors which affect transfer pricing strategies and selection of the specific method which provides the greatest procedural and tax advantage while meeting the guidelines of the IRS and other sovereign tax agencies. Each situation is unique and the selection of the most appropriate and applicable transfer...
Is a Standardized Transfer Pricing Policy a Social Responsibility?
An interesting article in the New York Times recently raised the issue of a standardized transfer pricing policy as a social responsibility. In today's global economy the issue of transfer pricing has become a central focus for many governments, including the United States. The IRS recently announced the formation of...
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,...
The IRS Has a Separate Team to Evaluate Transfer Pricing Transactions
The IRS has a separate team to evaluate transfer pricing transactions and cross-border business dealings for international businesses here in San Diego. If you are conducting cross-border transactions, or have multiple companies and transfer goods, services, or intangible assets between these affiliated companies you need the guidance and services of...