While new international corporate tax discussions unfold in the US Congress, American businesses brace for a tax scheme that could change some of the fundamentals of international business and associated Effective Tax Rates or ETRs. The majority party in Congress favors a "destination-based cash flow tax." Are we really moving...
Challenges with an IRS Audit Involving Transfer Pricing
IRS revenue agents and auditors create many unnecessary challenges for multinational businesses who utilize internal transfers to gain a tax advantage. This presents major obstacles during an IRS audit involving transfer pricing and other international tax related issues. The experienced international tax and business attorneys at Allen Barron, supported by...
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...
International Challenges Facing San Diego Businesses
Allen Barron is uniquely positioned to support and advise international San Diego business owners and corporations. There are substantial international challenges facing San Diego businesses as well as those who wish to bring their business opportunities to the United States. San Diego is home to a large number of H1-B...
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...
Mergers and Acquisitions In Order to Shift Corporate Taxation Offshore
There are a lot of questions around the practices made popular by Apple, Google and Microsoft regarding offshore entities and mergers and acquisitions in order to shift corporate taxation offshore to lower taxation jurisdictions. How can offshore strategies benefit small to mid-sized San Diego businesses who wish to reduce taxation...
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...
Medtronic Beats IRS in Complex Tax Matter Involving Transfer Pricing
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...