Featured post

Provocative International Tax News

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.  Learn how small international business are avoiding taxes with my book, International Taxation in America for the Entrepreneur.

International tax planning

Small business are now reaping big tax savings.  Importers, exporters and e-commerce business can use the same loopholes as big business. I wrote my book to teach you these loopholes in an easy two hour read.

But, I did more.  I had an audiobook created.  It downloads onto your smartphone so that you can listen while you are commuting.   Get the 2016 edition of  International Taxation in America for the Entrepreneur for $9.50 at Amazon on this link.  

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.

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 use by the IRS to blow up this offshore plan.

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.   Here you will learn the legitimate foreign tax plans that Congress likes. 

offshore trust, foreign trust, nevada trust, estate planning trust, esbt,      Since the Middle Ages, the wealthy have capitalized on trusts to avoid paying taxes. During the Great Crusades, upon the death of a knight, his entire estate went to the king. 

Nine hundred years later, things have not change much except the ‘king” takes only half.

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 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 400,000 pages deep inside the IRS’s web site and the tax court’s web site.

California Franchise Tax Board Free and Best Tax Research and PLanning

I purchased CCH’s California tax publication. Talk about a waste of money!!

So, I contacted Google and here is the great result. Not only does it have all of the tax law and FTB regulations, it also has its legal rulings.

I solved my tax issue in a few minutes.   I used quotation marks around the special words.  When I had too many results, I used the negative sign (-), to eliminate some of them.  For example, I was researching simple trust and the throwback rule.   I placed “simple trust” in quotes. To remove the results involving form 199, I type -199.


21st Century Tax Planning and Strategy for E-commerce and the Internet Cloud Business

Using last Century's infrastructure is fatal to you business. Using last Century's tax strategy is also fatal to your business.

Using last Century’s infrastructure is fatal to you business. Using last Century’s tax strategy is also fatal to your business.

Here is the problem with small business tax planning.  Your CPA is using the same tax plan as when your computer used Window’s XP.  You have updated your infrastructure for your business but not your tax plan.

Take British Airways for an example.  I was at the Nice, France airport two days after the terrorist attack that killed 84 people.  I had previously scheduled a British Airways flight to England.  I was next in line to check in and, well this picture tells the story.  British Airways XP style computer crashed, Worldwide.

Congress reported that business that legitimately undertake tax plans are taxed at 14%.  And there is more.  Half of those business paid legally paid almost no tax.  My question to you: “Are you paying more than your fair share in taxes?”

Here are four indicator that your CPA is stuck in the 1900’s XP tax planning:

  1.  He does year end tax planning.  Great tax planning is designed for years in advance focusing on each of your sources of income.
  2. He talks about deducting the cost of new equipment as if he has saved you money.  Spending money on new equipment is not a tax plan.  It is money lost unless you need the equipment. Then, it is an investment in growth and not a tax plan.
  3. He has you in an IRA plan.   Present value math models show that a 401K plan does not save taxes.  IRA plans dramatically increases your taxable income after age 70 causing a net after tax loss.
  4. He never mentions a Nevada trust.   Not only does a Nevada trust eliminate income taxes, it protects your assets (just in case we have another Great Recession).

Internet web based and e-commerce businesses are saving taxes by using the internet to shift income to a low tax state or even a tax haven.  Spend six minutes and listen to  first few chapters of my book, below, to learn how the cloud based and e-commerce businesses are paying less in taxes.

Internet marketing businesses and app businesses can easily shift their income to a no tax state, such as Nevada, or a no tax e-commerce country such as Canada.

Court Bust Management / Consulting Fee Tax Planning, Again

tax planning, saving taxes, how to save taxes, tax court

Tax Court explains great tax planning in this case.

Weekend Warrior Trailers, Inc., Et Al., Petitioners V Commissioner of Internal Revenue, Respondent  is an example of what not to do.  The Tax Court  was assessed every tax penalty on the books.

Many advisors use the “management fee” to shift income onshore and offshore.   The tax court and the IRS blasted this taxpayer for this naive and improper method of tax planning because the foreign corporation did not provide any services.

The tax court describes the taxpayer’s tax team as follows:

“Before 2002 Weekend Warrior engaged the services of attorney John Dana Mitchellweiler (Mr. Mitchellweiler), a partner at Smith, Mitchellweiler in Riverside, California. Mr. Mitchellweiler described himself as an outside general counsel to Weekend Warrior.

Mr. Mitchellweiler practiced law in the business and estates areas. As of the date of trial Mr. Mitchellweiler had practiced law for 15 years.”

“In August 2002 Mr. Mitchellweiler introduced Mr. Warmoth to William R. Lindsey (Mr. Lindsey). Mr. Lindsey was a financial adviser with 27 years of financial planning experience and was formerly employed by New York Life. Mr. Lindsey holds a master’s degree in financial services and certificates in business succession and executive compensation and is an accredited estate planner. Mr. Lindsey was a part of an “architectural team of designers” for clients’ estate planning, investment, and life insurance needs.”

“Mr. Warmoth hired Mr. Lindsey to prepare an overall plan for him. Mr. Lindsey’s firm prepared an outline of Mr. Warmoth’s goals that summarized Mr. Warmoth’s financial philosophy. The goals included developing an investment strategy, achieving financial independence, establishing an estate plan, and other objectives. Mr. Warmoth also sought general advice as to how to handle the company’s rapid growth.”

“On the basis of Mr. Warmoth’s needs, Mr. Lindsey put together a team of advisers — Mr. Lindsey and his pension administration firm; Mr. Mitchellweiler; Greg Siegler, a certified public accountant from the accounting firm Crabtree & Associates; Steve Tweedlie, an auditor from Crabtree & Associates; Ken Baily (Mr. Baily), a valuation analyst; Curt McCombs from Comerica; and Roland Attenborough, an attorney from Reish & Luftman.9

Mr. Lindsey coordinated the team members and the document preparation. In the last quarter of 2002 the team members met several times to discuss various options.”

What was the client’s tax planners thinking when they create  “management fee”?  Here is part of the tax court opinion (if you want the full case, please contact me).

With regards to the management fees… here is part of the case.

“Whether the fees were reasonable and necessary depends on what services Leading Edge actually performed (as opposed to what the management agreement provided it would perform). The record, however, is sparse as to the details of the parties’ actual relationship.

Leading Edge issued no invoices to Weekend Warrior for 2003 and 2004. Of the four invoices that Leading Edge issued for 2002, two predate the incorporation of Leading Edge, raising questions regarding the genuineness of the other two invoices as well.

“The invoices contain only a general description “Management Fee”. The record is also sparse regarding the identity of the persons who allegedly supplied services on behalf of Leading Edge under the management agreement.”

Big Big Tax Penalties

If you have a Great Tax Team  and they make a legitimate goof, the IRS cannot charge you negligence tax penalties. 

Here the tax court notes:
“Petitioners contend that they sought professional tax advice in connection with the structuring of the businesses and the preparation of the Federal income tax returns. Petitioners state that they had a team of competent professional advisers on whom they relied heavily and in good faith.

After examining the tax team, the tax court rejects the team and states:

“Petitioners have failed to carry their burden of proving that there was reasonable cause for, and that they acted in good faith with respect to, any portion of the underpayment in tax for each year at issue. We sustain respondent’s determinations of the accuracy-related penalties.”

If you want discuss your tax planning, then email me, Brian Dooley, CPA, MBT, at brian@intltaxcounselors.com.

Trump- “I try very hard to pay as little tax as possible ”. So, why aren’t you?

Small Business Tax Planning. Try very hard to pay the least in taxes

Small Business Tax Planning. It is time for you “To Get Tough” on taxes.  

In a recent report, Congress blamed Americans for paying too much tax.  Congress reported that the average tax rate of tax planning businesses is 14% (more on this link).   Matter of fact most tax planning businesses  paid no  income taxes.  

  For decades fools bought  tax shelters.  They “invest” their money   and  are told that the investment will give them deductions or a tax      credit. These fools do no work hard to pay the as little taxes as  possible.  They just wrote a check.

 This is not what Billionaires do.  Billionaires work hard to pay  less taxes. 

They avoid taxes by structuring their business deals in what is known as a “tax efficient strategy“.    This allows all of their profit to be used for growth or for saving for that “rainy  day”.  

So, why is the small business owner not taxed at 14%?
– Are they too busy for tax planning?
– Can’t find the right CPA or attorney?
– Don’t want to spend money on professional fees?

Congress’s report has some answers.

Continue reading