Are you wondering how proposed tax changes affect your business strategy going forward? There are many proposals swirling around Washington these days, and while it is impossible to determine at this point where things will end one thing is certain: your business will need to have a new strategy to...
FBAR Related Charges Will Put Paul Manafort Behind Bars
While facing a slew of federal charges including conspiracy against the United States the FBAR related charges will put Paul Manafort behind bars. The charges against the former campaign manager and his aid are serious in their very nature, but it is interesting that one of the central issues associated...
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. ...
Integrated Tax Legal and Business Advisory Services More Important Than Ever
Integrated tax legal and business advisory services are more important than ever as we prepare for changes in the corporate tax code and the impact of international restructuring. Allen Barron's unique blend of comprehensive tax services, legal, business consulting and advisory and accounting expertise allows our clients to engage challenges...
Starting a New Company Requires Integrated Expertise
Starting a new company requires integrated expertise across multiple disciplines including legal, tax, business advisory and accounting services. Allen Barron seamlessly integrates these services in a start-up package for entrepreneurs working to bring their dreams into reality. Starting a new company is much more than filling out a few forms...
Unusual Non-Willful Court Decision in Pennsylvania FBAR Case
A recent case in the United States District Court for the Eastern District of Pennsylvania has turned the recent tide of IRS victories regarding "willful versus non-willful" intent in FBAR related compliance cases. The unusual non-willful court decision found the US taxpayer was not "willful" when failing to report one...
What is Willful Blindness in IRS FBAR Cases?
What is willful blindness in IRS FBAR cases and how is the IRS attempting to use this to make non-willful FBAR violators appear to be willful? Why would this matter? The legal standard of "willful or non-willful" is an important distinction, especially as it relates to FBAR violations and penalties. ...
Jan Allen Speaks on a National IRS FBAR Panel Tomorrow
Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern. The topic of the expert panel discussion is "Willfulness and the IRS Disclosure Programs. Are you Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and...
What is the State of Globalization and International Business?
The Wall Street Journal recently asked an international expert the question "What is the state of globalization and international business based upon current events?" The rise of populist nationalism in the United States and around the world caused many business leaders and market observes to be concerned about the death of...