Defending Against IRS' Aggressive Offshore Oil Efforts

Law360, New York ( August 4, 2014, 10:58 AM EDT) -- The IRS continues to diligently pursue the foreign companies and the U.S. companies that hire them to perform offshore services for the oil and gas industry on the Outer Continental Shelf in the Gulf of Mexico. The IRS is using sophisticated monitoring and vessel tracking systems, such as Sea-web, Vessel Tracking Services and satellites to track the daily movement of certain vessels. The IRS contends that these foreign companies and their foreign workers have U.S. source income and should have filed U.S. income and employment tax returns and paid U.S. taxes on amounts earned from these offshore activities. Moreover, the IRS contends that the US companies that hired and paid these foreign companies should have withheld taxes out of the amounts paid. The IRS' industry directives on this initiative can be found here and here....

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