Featured post

Provocative International Tax News

international tax, international tax planning,

International Tax Planning for the Entrepreneur is easy to read and understand.

You are in good company reading this blog with 50,000 other smart viewers  (from more than fifty countries).

Making you wealthy with innovative tax planning is the mission of this blog. Wealth is not created by your tax deductions. Spending a dollar to save forty cents in taxes will not make you wealthy. Wealth is created by good business including innovative and, in some cases, provocative tax plans.

Get my 2014 edition of International Taxation in America for the Entrepreneur at Amazon.  You will learn the tried and true methods of international tax planning for the business owner and real estate investor.  The Kindle is only $9.50 on this link.

Want to brainstorm your tax idea?   Then, please call me, Brian Dooley, CPA, MBT at 949-939-3414 for a free brainstorming consultation.

id theft, identity theft IRS refund, IRS refund, brian dooley,

Tax planning and saving taxes does not work when you IRS deposits are stolen. Use the “Safe Lock” to protect yourself.

Protect your tax refund from ID thieves with the free “Safe Lockon this link.  Until the Obama’s Attorney General Holder was robbed twice, the Administration did little.  Then they got Michelle’s Obama’s social security number.

Local drug gangs have turned into tax refunds thieves.   60 Minutes reported that they have “laptop parties” where they get together and chit chat as they steel your money.   Often they have a friend or a mole working at a doctors office. The mole gets your information.

If you are a victim and the IRS has frozen your refund,  call your Congressman.   He or she has a dedicated staff that works with the IRS.

images

American firms are finding England a great low tax haven.  Pfizer Pharmaceutical move to London, has let the “cat out of the bag.” Here is how it is done if you are a small business.  If you are going to invert your headquarters outside the U.S., do it quickly.  Congress is panic and plans to have an “exit tax” (just like the Soviets back in the hey days of the USSR).

Best Country for Tax Inversion and Starting an Offshore Business? I looked at tax rates,  the type of commercial laws and supply of English speaking well educated work force.  Here is where save taxes and enjoy life.

saving taxes, how to save taxes, tax planning,

i Saving taxes with an IRS approved tax plan is called a private letter ruling.

New IRS internal legal memo gives tax breaks to the “check the box” foreign company incurring losses.  Here are the tax saving IRS rules.

  • Avoiding state income taxes this new IRS  designer  Nevada trust.  IRS tells how to use your Nevada corporation as your trustee to legally stop paying state taxes on your investment income. Here’s what’s happeningon this link.

IRS blazes provocative tax savings for the foreign investor in U.S. real estate, on this link.

New 2014 IRS discloses the best business structure for the entrepreneur.  Designed to allow you to pay less taxes now and to get the best refund during the next recession.  Here is what is happening.

Tax planning,  with the Supreme Court common tax laws

Tax planning with Supreme Court common tax laws

18th Century Supreme Court case destroys IRS tax penalty law. Using this case, the Tax Court gave the IRS a big defeat.  Here is what happen.   The Supreme Court is the “law of the Land”.  It rules over the IRS and Congress.   

It works both ways.  The blog on this link explains the most missed Supreme Court Doctrine in this offshore plan blown away by the IRS.

international tax planning, international, tax, planning,

International tax planning and international tax savings with this Treasury Department report.

The U.S. Department of the Treasury (a branch of the White House) issued an report on tax savings international tax plans that the IRS cannot stop.   They reported the successful foreign tax plans of international businesses. We have obtain a copy.  It is on this link.  

If you have a business in a foreign country, this report will save your taxes.  The international income tax planning strategies in this Government report are the trade secrets of offshore tax planners.   

offshore trust, foreign trust, nevada trust, estate planning trust, esbt, Since the Middle Ages, the wealthy have capitalized on trusts to avoid paying taxes.

Trust are the most effective tax tool. International tax planning should start with a Nevada trust to own the foreign company.

This easy to read blog post has the blueprint for successful trust tax planning. International Tax Planning should start with a trust to own the foreign companies. Besides avoiding state income taxes, the trust can move onshore or offshore at any time.   Surprisingly, an internal IRS memo disclosures how to protect assets and save taxes with an offshore trust.  In this blog post, I discuss offshore tax planning and provide the IRS memo. 

internet tax planning, saving taxes, cloud tax planning ,

Saving taxes with the cloud based

Learn how businesses are using the cloud to save taxes on this link.  E-commerce businesses are avoiding state income taxes and in some cases deferring U.S. taxes.

Be an IRS tax wizard with our new custom Google search, below .  I personally programmed this custom Google app to read 500,000 pages deep inside the IRS’s web site and the tax court’s web site. 

Loading

Pre-Immigration Planning and the IRS Checkmate with the Check the Box Election

Seminars can be the worst place for your  tax planner.

I have been to many, of course.  CPAs and attorneys are required to go.  We hear speakers review their Power Points.. as if they are the Bible. But, in reality, most Power Points are a copy of someone else’s Power Point.  And so it is with courses on pre-immigration tax planning because of a little known IRS regulation issued six  years after this tax plan became popular, in 1997.

We are have egos and love to show off to our clients  a quick fix to a complex problem.  So, when we hear a speaker (without knowing that most speakers are selected because they do not charge for their time) with an great looking Power Point saying “check the box” is the greatest pre-immigration tax planning, we think.. yes!

And we never do the research ourselves.  Well some  people never do their own research.  Here on this blog, every article is researched by me.  Anyway back to the issue.  For many and maybe most non-resident aliens, the check the box election will not work.  To make matters worst.. it is an IRS tax time bomb exploding the day you become a U.S. person (which means your subject to U.S. tax on your worldwide income.

Here’s what is happening.

Mr. Smith is an U.K. citizen and U.K. tax resident. He is  successful and owns quite a few UK companies with business in the UK and the EU . Mr, and Mrs. Smith decide to move the U.S.to expand their businesses.  They  move to the U.S. after obtaining a Green Card.

Their tax planners had been to many international tax seminars.  They even took the PDF file of the material.  Mr. Smith was told that tax planning was complicated and he need to make what the Americans’ call “check the box” election.   He was thrilled… what an easy fix to a complicated tax problem.

The tax planners prepared the Form 8832. Since it did not effect UK tax law, Mr. Smith was told that he could file the Form at any time.  A few weeks later, the Smiths singed the Form and it was filed with the IRS.

A few months latter, the Smith family arrived in Florida at their seaside home.  They promptly had $9,000,000 of US taxable income.  When they filed the Form 8832, the UK company was not “relevant” to the IRS.  However, when the Smith arrived in America, they had an obligation to file Form 5471 (the tax return for a controlled foreign corporation).  The check the box election is effective  the day they arrived (and not when the Form was filed).

The value of their UK companies was $10,000,000.  Their tax cost was their capital investment, $1,000,000.  The $9,000,000 gain is the $10,000,000 minus the $1,000,000.

You can find the little known IRS regulation that causes this terrible result  on this link

If you would like to brainstorm your international tax planning, then please call me, Brian Dooley, CPA, MBT at 949-939-3414 for a complimentary consultation.