The contract attorneys at Allen Barron provide extensive business contract creation and review services. The business contract is the basis of all fundamental business here in San Diego, and the quality of your business contracts will ultimately determine the success or failure of your company. Unfortunately, many small business owners and...
What is a PFIC and How Do Offshore Investments Lead to Higher Taxation?
What is a PFIC and how could your offshore investments actually lead to a higher taxation rate on earned income? A Passive Foreign Investment Company or PFIC is classified by the IRS in two ways: 75% or more of the income from the foreign corporation is classified as "passive income,"...
Streamlined Domestic Offshore Procedures Still a Viable Option for Foreign Nationals
The offshore focus of the US Treasury Department and the IRS is well documented, and many questions remain for those who have either yet to take action to come into compliance with IRS FBAR and offshore reporting or for foreign nationals who may not have realized the requirements. Our office...
US Offshore Taxpayers FBAR and FATCA Still Great Concern for IRS Watchdog
A leading IRS National Taxpayer Advocate has issued her mid-year findings for 2016 last week. The report is very critical on the agency's support of US offshore taxpayers and expatriates, and focused upon the IRS' goals for the rest of 2016. The number one area of focus continues to be...
A Revocable Trust is the Best Option After Reform of Medi-Cal Estate Recovery SB 833
The recent implementation of California SB 833 and the reform of Medi-Cal estate recovery will have a significant impact on estate planning for many Californians. The new law essentially limits the ability of Medi-Cal to pursue the estate of a deceased patient in order to recover costs of their treatment. ...
How Does New Medi-Cal Legislation Change Your Estate Plan?
Governor Jerry Brown recently signed new Medi-Cal legislation SB 833 into law, and it will take effect for those who pass away after January 1, 2017. The new Medi-Cal legislation reduces the State's ability to go after the assets of deceased Californians who required "specific medical assistance" including permanent nursing...
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...
Treasury Department and IRS Propose Changes to Offshore Business Taxes and Inversion
The US Treasury Department and the IRS to propose changes to offshore business taxes and a practice known as "Inversion." A hearing yesterday brought stiff resistance from representatives in the business community and others seeking to preserve offshore tax advantages. "Inversion" is one of the specific strategies addressed in 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...