Most acquisition agreements such as an asset purchase agreement are going to have representations and warranties made by both or all parties to the agreement…

Many business acquisition agreements such as a stock purchase agreement or asset purchase agreement have language and clauses regarding an indemnification…

If an asset purchase agreement or stock purchase agreement has net working capital built into the purchase price, it is likely that the agreement also calls…

Owing payroll taxes or employment taxes to the IRS are serious matters, but is owing payroll taxes to the IRS criminal? Whether owing payroll taxes is a…

The term “Ordinary Course of Business” is used in many business contracts including an asset purchase agreement and other business acquisition agreements. But…

A Mexican AFORE is effectively a private pension product in Mexico. US Persons who have a Mexican AFORE may be required to report that account on their FBAR,…

Form 5471 is used to report a US persons ownership or interest in shares of a foreign corporation. Certain US persons, defined as U.S. shareholders, are…

When the IRS is considering which individuals to assess the trust fund recovery penalty to, the revenue officer conducts an investigation of the business and…

OVDP stands for the “Offshore Voluntary Compliance Program”. This program was used for US individuals who failed to report foreign financial assets to the IRS…

When a business owes payroll taxes or employment taxes to the IRS, the IRS can personally assess one or more individuals the trust fund portion of the payroll…