Other Company in Philadelphia, Pennsylvania - Person changed phones and they call me

The person they seek changed phones and they call me all the time even after I told them this telephone number does not belong to the person.

Do creditor should continue to torture the people who own the new telephone number. Then they have the nerve to be nasty when you answer the phone. I would like to find out where I can sue them. I have had two heart attacks and a stoke and I do not need the aggravation of these people calling my number.

Of course, I know they have the ability to tell that the telephone number does not belong to the person they are calling.

We are in the middle of a recession anyways. What if my number was a cell phone and I had to pay for these off hours call.

The country and world are going through a financial crisis. Most of the time now these grave robbers - that is what I call debt collectors - These people don't have jobs and are homeless.

Debt collectors should be disarmed.

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Philadelphia, Pennsylvania
Review #132848 is a subjective opinion of PissedConsumer132848.

Other Company in Las Vegas, Nevada - Household goods were held ransom for cash

I would strongly advise against using this mover.

1. Owner breached payment term agreement, payment in full via credit card upon delivery, allowing the accumulation of frequent flier mileage.

2. Owner is a very dishonest.

3. Owner would not load the truck until partial payment of either cash or check was provided.

4. Household goods were held hostage for cash.

5. Only because we were able to write a check at pick up and our ability to satisfy the cash demand upon delivery was the owner willing and able to meet the scheduled delivery dates.

6. Owner issued a not to exceed contract based on weight.Truck was not weighed prior to or after loading.

7. Owner denies any wrong doings.

8. Owner refused to resolve dispute even through the Better Business Bureau.

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Las Vegas, Nevada
Review #132812 is a subjective opinion of PissedConsumer132812.

Other Company in Reston, Virginia - Late Charges

I have paid my bill on time, and they still charged me with late fees saying I was a month behind on my card. ALso would not work with me on paying my bill.

I didn't give them my account info as they took money out before without me okaying it. They charged 1,000 dollars of late fees on my card. I haven't used the card in a long time. Anyone have any suggestions?

I trying telling them I have a lawyer but that didn't help either.

Would like to make a deal with them thanks.

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Reston, Virginia
Review #132719 is a subjective opinion of PissedConsumer132719.

Other Company in Bellevue, Nebraska - I did not receive my overpaid mortgage amount of $1500.00

When I paid off my mortgage loan, there was recorded refund of $1500.00 that was never paid to me. I called the office here in Omaha, NE and they said that the amount was applied to interest.

The closing document showed that the $1500.00 was paid but I never received anything. I recently checked with the treasures department here in Nebraska for unclaimed property and I was not listed as being owed any unclaimed property.

From reading the listed complaints I can see that there has been many complaints against this company; therefore I would not recomend this company as a good company with which to do business.

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Bellevue, Nebraska
Review #132678 is a subjective opinion of PissedConsumer132678.

Other Company in Tampa, Florida - Were is this company heading?

What is going on with this company, im really concerned, Are we talking about lay offs store closeings, I have been with this company for a very long time.Please email me at wwenzel4@tampabay.rr.com cc ed martell, ron white, tim, anyone. My hours are being cut, and its not to do with job performance, trust me, I would appreciate a response from someone.sorry it had to come to this but there is no comunication with upper management with lower level emplyees.like I sais I have been with this company for a very long time, and I want to continue to be with this company for a very long time.I cant imagine doing anything else, just keep me informed about whats going on.

thank you


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Tampa, Florida
Review #132634 is a subjective opinion of PissedConsumer132634.
1 comment

Unprofessional and they overbill

Our company has used the accounting services of Christopher, Smith, Leonard, Bristow & Stannell, CS&L, for many years due to a contract for services through our 401K. Over the past 3 years the 401K company cut their fees and they are now coming after their clients to make up the difference through undocumented and unsupported fee structure and fee billing.

When questioned, they become defensive, uncommunicative, unresponsive and then bill you for the time to discuss their bills. They are completely unwilling to provide reasonable documentation to support their billing.

Do not use this accounting firm and we are moving our 401K just to get away from this company.

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Plainview, New York, United States #614220

International tax, transfer pricing, FBAR


April 24, 2012 By Lance Wallach, CLU, CHFC


International Tax, Transfer Pricing, FBAR problems

Transfer Pricing FBAR International Tax Problems

By Lance Wallach

The IRS dedicates enormous resources toward dealing with taxpayers who are involved with any form of transfer pricing. The transfer pricing provisions of IRC 482 address four general types of transactions between commonly owned or controlled parties.

1- Use or transfer of tangible property

2- Services

3- Loans

4- Use or transfer of intangible property (especially cost sharing arrangements)

Use of tangible property: When one member of a controlled group rents or leases property to another member of the group, the price paid for use of such property must be appropriate for an arm’s length amount. Per Treas. Reg. 1.482-2(c)(2)(i), the arm’s length amount is determined by reference to the amount that would have been charged between independent parties for use of the same or similar property under similar circumstances.

Determination of what is arm’s length for fair rental value transactions:

a) Period of use

b) Location of use

c) Owner’s investment in property or rent paid

d) Expenses of maintaining the property

e) Type of property

f) Condition of property

Transfer of tangible property: When sales or transfers of tangible property are made between related parties (sales of goods), the arm’s length price generally is the price that an unrelated party would pay for similar property under similar circumstances.

Determination of what is arm’s length for inter-company sales: The regulations specify six methods used to determine whether an arm’s length amount has been charged between members of a controlled group. Treas. Reg.1.482-3(a), states that the “best method" should be used to determine arm’s length price. The IRS views the “best method" as the method that produces the most reliable results based on facts and circumstances. The IRS is well aware of the fact that many transfer-pricing studies are prepared with the intention to validate year-end inter-company cost of sales regardless of whether they are arm’s length just to avoid the IRC 6662 penalties taxpayers would be best served if transfer-pricing studies were prepared by knowledgeable experts in the field.

Inter-company Services: When one member performs services for another member of a controlled group, an arm’s length price is necessary. This includes services such as marketing, management, technical services, or any other type of service. Such services can be provided by one party for the joint benefit of all members, or can be provided between two members of the controlled group.

Determination of what is arm’s length for inter-company services: The arm’s length standard for services between related parties is found in Treas. Reg. 1.482-2(b)(3) which states, “ an arm’s length charge for services rendered shall be the amount which was charged or would have been charged for the same or similar services in independent transactions with or between unrelated parties under similar circumstances considering all relevant facts." The arm’s length charge for services between related parties will depend upon the facts related to the services provided. The pricing rules fall within three categories:

1) An arm’s length charge will be based on the amount that would have been charged by an unrelated party. This generally means that the price should be based on reimbursement of cost, plus a mark-up for profit.

2) An arm’s length charge may be based on only the costs incurred, provided that certain criteria are met.

3) No charge is necessary, if certain criteria are met.

The area that concerns the IRS most with these types of transactions is technical services with regard provided by larger U.S corporations to their foreign CPC’s, which are not charged for these services. In regards to smaller cases, the IRS typically examines management fees in detail to ensure they are arm’s length.

Inter-company Loans: In the context of IRC 482, most of the areas of conflict in this area revolve around interest. When loans are made between members of a controlled group, interest rates charged do not always meet the required arm’s length standard.

Determination of what is arm’s length for inter-company loans: The arm’s length standard for loans between related parties is found in Treas. Reg. 1.482-2(a)(2) which states that “ an arm’s length rate of interest shall be a rate of interest which was charged, or would have been charged, at the time the indebtedness arose, in independent transactions with or between unrelated parties under similar circumstances."

Factors that are listed in Treas. Reg. 1.482-2(a)(2) that should be considered in determining arm’s length interest are:

a) The principle amount and duration of the loan.

b) The security involved

c) The credit standing of the borrower

d) The prevailing interest rate where the loan was made

The regulations provide further guidance in the following areas:

a) Safe harbor rules

b) Ordering rules

c) Determination of bona fide indebtedness

d) Period for which interest is charged

Transfers of intangible properties: When transfers of intangible property are made between controlled parties, the arm’s length price is often difficult to determine, in part because the property’s value derives from intellectual capital such as ideas, the outcome of research and development or creation of software.

Determination of what is arm’s length for transfer of intangible property: The regulations specify four methods to determine whether an arm’s length amount has been charged between the members of a controlled group with respect to the transfer or use of intangible property. Treas.Reg.1.482-4 (a) states that the “best method" should be used to determine the arm’s length price between related parties. Controlled parties may enter into a qualified cost sharing arrangements to share costs related to developing intangibles. They may also contribute existing intangibles for use in further development or for use in developing new and distinct intangibles.

The following general rules of Treas.Reg.1.482-7 (a) and (b) apply to qualified cost sharing arrangements:

a) Two or more controlled participants agree to share the costs of developing intangibles.

b) Costs are shared based on each participant’s share of reasonably anticipated benefits from the intangibles to be developed.

c) A “buy-in" must be paid to the participant that contributes pre-existing intangible property to the qualified cost sharing arrangement.

As with transfer pricing reports, cost-sharing agreements should be prepared by qualified experts who are knowledgeable in this area. The ideal candidate would probably be someone with decades of experience preferably with the IRS in the international taxation area. Said ideal candidate should also of course be a CPA. If examined by the IRS, the cost sharing agreement will be reviewed in detail. For further guidance refer to the Coordinated Issue Paper utilized as a guideline for the IRS personnel dated June 5th 2009.

Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio’s “All Things Considered” and others. Lance has written numerous books including “Protecting Clients from Fraud, Incompetence and Scams,” published by John Wiley and Sons, Bisk Education’s “CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation,” as well as the AICPA best-selling books, including “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.” He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxadvisorexpert.com.

The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

Knoxville, Tennessee
Review #132611 is a subjective opinion of poster.

Other Company in Phoenix, Arizona - Charged me interest and late payment on a :"0" balance

I paid my small balance in full. They said it got there two days late and charged me $29.00. I called and asked to have it removed and they refused.

I then left a v/m and never received an answer and now they billed me another $25.00 plus $1.00 interest.

I keep asking for a dispute form and the customer service idiots keep telling me it is a legal charge.

The last phone call where they were finally going to transfer me to the dispute center, disconnected me.

What an underhanded bank!

I am going to report them to the proper government agency that oversees charge cards.

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Phoenix, Arizona
Review #132575 is a subjective opinion of PissedConsumer132575.
1 comment

Company does not allow me to accept calls anymore Why?

My husband is in jail and up until recently we have had absolutely no problems, but now when he tries to call he cannot even get through. What is going on?

Does the jail get charged for that or do i? I also recieved the phone bill but none of the collect calls were even on the bill. I would really appreciate if someone could answer these questions for me or even better just resolve the problem all together. I am really not happy with the service the evercom company has provided.

As i stated previously only up until about two weeks ago i never encountered any problems i just want a solution.

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:cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry :cry

Washington, District Of Columbia
Review #132560 is a subjective opinion of PissedConsumer132560.

Other Company in Wichita Falls, Texas - Has charged my credit card and never recieved what I ordered.Are you for real?

I ordered some medication though your company, and money was taken from my credit card,never recieved the medication, Maybe theBBB will like to here about your business practices. I see now that this is a scam from all the other complaints I have read.

I want my money back if you are full of ***.

My brother is an attorney and he said if you took my money with no intention of giving me my merchandise, we will find out where you are and make sure no one else is ripped off. Times are tough now,and I don't have money to give away

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Wichita Falls, Texas
Review #132552 is a subjective opinion of PissedConsumer132552.

Other Company in Gleason, Tennessee - Your new channel lineup does not include the tvguide channel.

You lied, we were told over and over that if we had cable already we didn't have to worry.

I have cable and now no tvguide channel-which is needed.

No I don't want digital or dish or whatever.I'm in an apartment complex that won't allow it.

I'm really pissed and not the only one. Wanted to put my complaint in.

Yes I checked all channels, its not available. I have basic and extended basic. Very disappointed!

I hope you reconsider adding this channel back for

us. The paper and tvguide from the stores don't include daytime listings.

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Gleason, Tennessee
Review #132551 is a subjective opinion of PissedConsumer132551.