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.

Now in Audiobook Kindle and paper. E-commerce and cloud businesses are reaping big tax savings. Get the 2015 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.

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..


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 move 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 to save taxes and enjoy life.

saving taxes, how to save taxes, tax planning,

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

International Gift Tax Plans with this IRS internal letter on this link. Fantastic legal tax avoidance for the foreign person with family in the U.S. is explained in this letter.

  • 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.

New- Saving international taxes with this letter from the U.S. Department of the Treasury letter to the U.K. tax authorities on tax planning in the U.S. for UK and EU companies.

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 a secret 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.   

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.  Learn trust tax planning and asset protection on this easy to read blog post.    It has  the blueprint for successful trust tax planning.

IRS memo on  assets protection and tax planning with an offshore trust.  Get it now on n this blog post

internet tax planning, saving taxes, cloud tax planning ,

Saving taxes with the cloud based

Cloud tax planning: 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 800,000 pages deep inside the IRS’s web site and the tax court’s web site. 

Here is How to Avoid Tax and Live in the Caribbean form Puerto Rico to the Virgin Islands

Offshore Trust International Tax Strategy and Planning  is a sophisticated concept used by the wealthy.    Learn more in my book, International Taxation in America, available at Amazon.

Offshore Trust International Tax Strategy and Planning is a sophisticated concept used by the wealthy. Learn more in my book, International Taxation in America, available at Amazon.

Both Puerto Rico and the United States Virgin Islands provide tax incentives for American.  Puerto Rico capts the tax at a 4% rate.   While Saint Thomas (USVI) will rebate up to 90% of your taxes.

Once you are in these territories, you can stop filing returns with the IRS… with proper tax planning. But as my wife asked me, how much time do we have to spend there?   The Caribbean is nice but not during hurricane season.

And how about healthcare or seeing grandchildren?   The courts have given the IRS some big defeats.  So, the IRS is using its administrative authority to write a tax law.   So, if you follow these rules, the IRS will be happy with you.  

The new rules are below in blue. 
Section 937(a) provides that an individual is a bona fide resident
of a U.S. territory if the individual meets a presence test, a tax home
test, and a closer connection test. In order to satisfy the presence
test, an individual must be present in the U.S. territory for at least
183 days during the taxable year (183-day rule), unless otherwise
provided in regulations.

Section 1.937-1 provides several alternatives to the 183-day rule.
An individual who does not satisfy the 183-day rule nevertheless meets
the presence test if the individual satisfies one of four alternative

(1) The individual is present in the relevant U.S. territory for
at least 549 days during the three-year period consisting of the
current taxable year and the two immediately preceding taxable years,
provided the individual is present in the U.S. territory for at least
60 days during each taxable year of the period; (Author note: 549 days
is 183 days time three.  Thus, during the three years, you can come and
go as you want as long as you have a total of 549 days).

(2) the individual is present no more than 90 days in the United States during the taxable year;  (Author note:  This is nice for the dual citizen American with family 
in other countries or for one that just likes to travel).

(3) the individual has no more than $3,000 of earned income from
U.S. sources and is present for more days in the U.S. territory than in
the United States during the taxable year; or

(4) the individual has no significant connection to the United States during the taxable year.  The term “significant connection” is generally defined as a permanent
home, voter registration, spouse, or minor child in the United States.
See Sec. 1.937-1(c)(5).

Section 1.937-1 also provides that certain days count as days of presence in the relevant U.S. territory for  purposes of the presence test, even if the individual is not physically  present in the U.S. territory (constructive presence).  

IRS Explanation of Provisions

Following the original issuance of Sec. 1.937-1, the Department of
the Treasury (Treasury Department) and the Internal Revenue Service
(IRS) received comments requesting that the presence test be revisited
to make it more flexible. These comments included a proposal to allow
days of constructive presence for business or personal travel outside
of the relevant U.S. territory. The Treasury Department and the IRS
have concluded that it would be appropriate to allow additional days of
constructive presence subject to certain limitations. Accordingly,
these proposed regulations provide an additional rule for calculating
days of presence in the relevant U.S. territory for purposes of the
presence test in Sec. 1.937-1(c)(1).
Under the proposed amendment, an individual would be considered to
be present in the relevant U.S. territory for up to 30 days during
which the individual is outside of both the United States and the
relevant U.S. territory. The proposed amendment would not apply,
however, if the number of days that the individual is considered to be
present in the United States during the taxable year equals or exceeds
the number of days that the individual is considered to be present in
the relevant U.S. territory during the taxable year, determined without
taking into account any days for which the individual would be treated
as present in the U.S. territory under this proposed amendment.

Furthermore, the 30-day constructive presence rule would not apply for
purposes of calculating the minimum 60 days of presence in the relevant
U.S. territory that is required for the 549-day test under Sec. 1.937-
1(c)(1)(ii). Therefore, an individual invoking Sec. 1.937-1(c)(1)(ii)
must otherwise be considered to have been present at least 60 days in
the relevant U.S. territory in each of the three years in order to
benefit from the 30-day constructive presence rule.