My Company Is Regularly Audited However, The IRS Has Never Asked About Our Transfer Pricing. We Have Significant Intercompany Transactions...

Asked in California, United States

0 0 Audits

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Can We Claim My Wife's Family (Mexican Citizens) As Dependents On Our US Federal And California State Taxes If We've Sent Them Money...

Asked in California, United States

0 0 Dependents Individual Mexico

Waiting For An Answer Comments (1) Follow The Question

What Is The Best Way To Allocate Headquarter Expenses To The Subsidiaries Outside The U.S.A.?

Asked in California, United States

0 0 Allocation of Expenses Expenses Foreign Subsidiaries

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Can I Charge An Interest Rate On Intercompany Loans That Is Different From The Safe Harbor Rate?

Asked in California, United States

0 0 Corporate Intercompany Loans Interest Rates Safe Harbor Rates

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How Can I Replace One Transfer Pricing System With Another System Without Raising Red Flags?

Asked in California, United States

0 0 Transfer Pricing

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The Field Audit Team Has Proposed A Transfer Pricing Adjustment. What Are My Options To Fight The Adjustments?

Asked in California, United States

0 0 Adjustments Audit Transfer Pricing

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Under What Circumstances Will The Sale Of Intellectual Property ("IP") By A Controlled Foreign Corporation ("CFC") Give...

Asked in California, United States

0 0 Controlled Foreign Corporation Intellectual Property Subpart F Income

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Are There Any Transaction Structures That Can Be Utilized By A US Corporation To Repatriate Low-taxed Offshore Cash In The Context Of The...

Asked in California, United States

0 0 Acquisitions Repatriation Transaction Structures

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Does Liability Assumption Reduce The Amount Of Gain Recognized Under Section 356(a)(1) In The Same Manner As It Does Under Section 301?

Asked in California, United States

0 0 Liability Assumption Section 301 Section 356 (a)(1)

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What Must Be Done To Obtain Hedging Treatment For US Federal Income Tax Purposes, And What Is The Benefit Of Obtaining Hedging Treatment?

Asked in California, United States

0 0 Hedging Treatment US Federal Income

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What Are The Estimated Tax And Tax Return Filing Requirements For Taxpayers Earning Income As An Independent Contractor And Should I...

Asked in California, United States

0 0 Estimated Taxes Independent Contractor Limited Liability Corporation (LLC)

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My Corporation Is Expanding Into Asia And Europe. What Type Of Holding Company And Entity Structure Will Result In The Lowest Possible...

Asked in California, United States

0 0 GAAP Holding Company Worldwide Effective Tax Rate

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If I Have Bank Accounts Or Other Property Outside The U.S., What U.S. Reporting Is Required To Be Fully Compliant With All U.S. Laws?

Asked in California, United States

1 0 Bank Accounts Property U.S. Reporting

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How Long Can I Stay In The U.S. And How Much Income Can I Earn In The U.S. Before I Have To Pay U.S. Taxes And File U.S. Tax Returns? How...

Asked in California, United States

0 0 Double Taxation Expatriate Inpatriate US Income

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My Company Purchased An Office Building About 45 Years Ago For $5,000. The Company Is A Sub-chapter S Corp So Everything Flows Through To...

Asked in California, United States

0 0 Capital Gains Real Estate Tax Subchapter-S

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