Saving taxes with an IRS approved tax plan is called a private letter ruling.
I came across the IRS audit guide for partnerships. IRS agents are not tax experts. So, the IRS has a guide to tell them what to do. Knowing how to save taxes means you will need to know the tax planning strategies discussed in this audit guide.
Just how do you save taxes if you have a partnership? I recommend that read this guide and you will become a partnership tax expert.
International tax planning strategies include the use of foreign partnerships. They are ideal for income shifting. As you will see in this guide, the section for international taxation of a foreign partnership is left “blank.” If an IRS agent audits your foreign partnership, the agent is on his own.
A word of caution, a foreign limited liability company is not treated as a domestic LLC. A foreign LLC is classified as a foreign corporation unless the owner’s make an election with the IRS. If you need help with this, then contact me.
Both the Delaware LLC Nevada LLC are popular international tax planning entities. They are so effective that the Mexico has complained to the U.S.Government.
Great tax planners guide their clients. They do more than just prepare a tax return. If your CPA is not guiding you, then find a new CPA. My firm does not prepare tax returns. However, we guide many clients.
If you need help with your tax planning, then email me, Brian Dooley, CPA, MBT [email protected]
Partnership Tax Planning with the IRS Audit Techniques Guide
This Audit Techniques Guide (ATG) is presented in several chapters. The publication/revision date of each chapter is posted in the Table of Contents below. These chapters can be accessed and then printed by following the links in the Table of Contents below.
Chapter 1 and 2 – Initial Year Return Issues (Published 12-2002) (author note – this section has many tax elections that will save you taxes).
Chapter 3 – Contributions of Property with Built-in Gain or Loss ─ IRC section 704(c) (Revised 12/2007) (Author note – here you will learn sophisticated tax planning methods for both onshore and offshore tax planning).
Chapter 4 – Distributions (Revised 12/2007) (Author note: this chapter contains the fundamentals of tax basis (tax cost) shifting).
Chapter 5 – Loss Limitations (Revised 12/2007) (Author note: loss limitations include the “at risk” tax law from 1976).
Chapter 6 – Partnership Allocations (Revised 12/2007) (Author note: for the foreign partnership this chapter is vital).
Chapter 7 – Dispositions of Partnership Interest (Revised 03-2008) (Author note: timing of income and losses is a sophisticated tax plan. Your CPA should read this)
Chapter 8 – Real Estate Issues in Partnerships (Published 12-2002)
Chapter 9 – Tax Shelters (Revised 12/2007) (Author note: read this chapter to learn what not to do).
Chapter 10 – International ─ (Reserved) (Too complicated for the IRS. If you want to brainstorm your ideas or concerns, then please give me a call for a free one-hour consultation.)
Chapter 11 – Family Partnerships (Author note: on this link your learn income shifting methods, how to avoid estate taxes and asset protection.)