Tag Archives: international tax planning

Provocative International Tax Planning News for Small Business

International tax planning is going “crazy” with the 2018 GOP tax law.  International tax avoidance has never been more legal.  The tax savings have never been so Big!  It is time for you invest money with your international tax accountant and upgrade your plan.   

International tax planning and strategy

Applying for an IRS ruling on your international tax planning will save you taxes in the long run.

Fantastic IRS International Gift Tax Plan

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. Alien’s estate tax exemption is only $60,000.

Amazing IRS Avoidance of  state income taxes  with this new IRS  designer  Nevada trust.  IRS tells how to use a Nevada trust to avoid state income taxes. Here’s what’s happeningon this link.   

New- Department of the Treasury letter to the U.K. tax authorities on U.S.  tax planning for UK and EU companiesHere is the letter from the U.S. to the U.K. 

Be an IRS tax planning wizard with our new custom Google search, on this link.  This custom search reads 300,000 pages deep inside the IRS’s website and the tax court’s website.  It is free!.  Find the answers to your tax question quickly and accurately.

18th Century Supreme Court case destroys IRS tax penalty law. Using this case, the Tax Court gave the IRS a significant 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  Supreme Court Doctrine used by the IRS to blow up an offshore life insurance plan.

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 changed much except the ‘King” takes only half.

Trusts are the most efficient tax tool. International tax planning should start with a Nevada trust to own a  foreign company.  Learn trust tax planning and asset protection in this easy to read blog post.    It has the blueprint for successful trust tax planning.   Get the IRS memo on asset protection and tax planning with an offshore trust on this blog post.

internet tax planning, saving taxes, cloud tax planning

Saving taxes with the offshore cloud computer. 

Cloud tax planning. Learn how businesses are using the cloud to avoid taxes on this link. 

E-commerce companies are avoiding state income taxes and in some cases deferring U.S. taxes.

Here is how it works.  A computer service that can provide a service (such as a tax research program) or a product (such as music, e-books, video) has special sourcing rules.  The income can be foreign source income when the computer server in a foreign country. 

Is the U.S. a tax haven for citizens of the UK, Sweden, Belgium, Canada, Luxembourg, and Austria?  Yes, says the IRS in its Publication.  Learn the magic Tax Treaty words for these lucky citizens of The UK, Sweden, Belgium, Canada, Luxembourg, Austria on this link.

International Tax CPA Prepares Form 1120F and Avoid the Branch Profits Tax

The International Tax CPA know that the branch profits tax is a sneaky beast.   It has three prongs.  One is your interest expense. Next, the amount of equity in your U.S. business,  Lastly, the reason you have equity in your U.S. business.  This tax is reported on Form 1120F.

If you kept equity in your U.S. business to avoid the branch profits tax, then you owe the branch profits tax.   Form 1120F’s balance sheet is where you study this topic.

The branch profits tax is designed after the domestic corporate tax law known as the “accumulated earnings and profits tax”.  This law is found in tax code section 531.  This key factor is the accumulation of profits to avoid paying a dividend (and thus the income tax on the dividend).

International Tax CPA and the Form 1120F

My course to the California Society of CPA’s on international tax planning included the branch profits tax.  Below is part of the course.   If you need help with your international tax planning, then contact me at [email protected]

This course was for the international tax CPA. So, you may find the video too complicated. I suggested that you forward this blog to your CPA  (if he is not an international tax CPA).

Here (this link) is more information on the branch profits tax.  The tax is tricky.

If you have paid the tax, then let us see if we can get the IRS to refund branch profits tax to you.  I can tell you one way to know if your CPA has messed up.

If your business does not have a double entry set of accounting books (called a general ledger), then the branch profits tax calculation may be wrong.

E-commerce and Mobile Commerce International Tax Planning for the Small Business

E-commerce and Mobile Commerce International Tax Planning  exists because our international tax laws were written by a man born in the 1860’s.  This is not a typo.  He grew up in the world of Pony Express and steamship commerce.

In the 1930’s he became the Chairman of the Congressional Tax Committee.  His view of commerce was the late 1800’s.  Congress has never changed our international tax laws.

These tax laws work just fine in the industrial age but  now these ancients laws create legitimate loopholes for e-commerce and cloud based businesses.

E-commerce and Mobile Commerce International Tax Planning for the Internet of Things.

We are in the age of “internet of things,” 

The  industrial age tax laws provide many unique tax savings for the e-commerce business, the contract manufacturing business, and the internet marketing business.

My easy to read book, International Taxation in America for the Entrepreneur, provides the tried and true blueprint for saving taxes for today’s E-commerce businesses.  I have the first three  chapters on this link.

The first three chapters are easy to read but are hard to believe.  I mean, is it really possible that Congress has done nothing about international tax laws since the Great Depression in the 1930s?

And there is more unbelievable events.  The designer of the tax law was born just after the Civil War.  His father served in the Confederate Army.   His parents named him after Confederate General Robert E. Lee.

And there is more.   The writer of our international tax law had only a high school education.  To him, text messaging was the telegraph.

So, get the first 25 pages, for free, of my popular book on international tax planning with an emphasis on e-commerce and cloud based products on this link.

Or buy the book at Amazon for $9.50, on this link.   By the way, Amazon has a seven day return policy.  So, if you don’t like the book, just send it back (which is easy to do as a Kindle book0

Now, if you want to take your international tax planning to the next lever, then contact me, Brian Dooley, CPA, MBT  at [email protected]

This link has another blog in saving taxes in the e-Commerce and virtual computer world.

 

Cloud Continues to Disrupt Business – 1,000s of Robots Laid Off

International tax planning compares last century's tax laws to this century's business. Then , it exploits the differences.

International tax planning compares last Century’s tax laws to this Century’s business. Then, it exploits the differences.

Cloud ecommerce tax planning changes as technology changes. The U.S. Senate reported that businesses that update their tax plan are taxed at only 14%..

You have to compete with the future. Blockbuster’s demise is old news from the beginning of this century.   Just ten years later, the killer of Blockbuster is dying.   Redbox has closed (laid off) 1,000s of it robotic DVD rental kiosks in the U.S.

 In 2015, it closed all of its DVD rental kiosks in Canada.   Netflix and other video streamers are slaying the king of the DVD rental kiosks. Redbox’s $1 a night became too expensive. Netflix is $10 a month, and you can watch as many hours as you want with 50,000 choices.   With Redbox, you had to rush to the kiosks to return the DVD.

American international tax laws were written and were designed for a 1930 economy.

Offshore tax planning compares the out of date concepts in our tax laws to 21st Century business. Then, it exploits the differences.  Your tax planner must forget last century’s tax planning and learn this century’s.  Even the first ten years of this century is partly obsolete.  

If this was 2005, you would not have a smartphone. Yep, no apps.  I don’t know about you, but I use my iPhone and iPad for business more than I use my landline and my computer combined.   

With the iPhone came the  streaming of music.  If the computer server hosting the music was located in the Cayman Islands, the income would be foreign source income and not U.S. source regardless of the location of the customer.

Cloud ecommerce tax planning changes as technology changes- Look at Banking

Great tax planning sees the trends and changes.

Look at banking.   Are ATM’s the next to be laid off?  Do you want to deposit your checks like this,  in the dark watching over your shoulder?

Internet businesses can decide who is going to tax them just by using the cloud.

Internet businesses can decide who is going to tax them just by using the cloud.

Or like this- At home with a smartphone app where it is safe. By changing your business, you not only survive, but you can also completely shift your tax profile.

For example, if you distribute a product, spend some time learning about 3D printing or using a fulfillment center.   If you have an e-commerce business,  consider streaming your product versus providing a mp3 file or a pdf file.  Internet tax planning starts with shifting the source of the income.

For some, it is merely a move to Nevada or Texas to escape California or New York taxation.  For others, it is outside of the U.S., such as Canada (yes, it is an internet tax haven) or Ireland.  By the way, California tax planning and New York tax planning just became more important.  State income taxes are no longer deductible. 

if you need help with your international tax planning, then contact me at [email protected]

Saving Taxes in the E-commerce & the Cloud (Virtual) Computer World

cloud computer tax, tax planning, saving taxes, international tax planning,

E-commerce businesses are saving taxes with cloud computer tax planning.

E-commerce tax planning and Cloud tax planning uses unique tax laws.  As a result, saving taxes in this century’s cross-border business environment is easier than ever.  

Small businesses are saving taxes with eCommerce tax planning and cloud computer tax planning.  

The cloud has level the playing field between small business and big business.  Amazon is leading the way.

 Small businesses can benefit from cloud computer tax planning.  

Cloud tax planning allows big state and federal tax savings.  A popular term for this is “third wave” tax planning.  The second wave was most of last century and a little of the 1800s.  The first wave is from  10,000 BC to the late 1800s.  This explains the loophole.  Our tax laws were designed in the early 1900s.  While the laws are more complicated, the basis framework is unchanged.

We all have heard people say that things are not what they used to be.  This is particularly true in American business.  In 1910, electricity was not in the White House.  Cars were laughed at with jokes like “Get a horse!” 

Phones were rare, and there was no air travel.  U.S. E-commerce tax laws are written for last century’s business.  E-commerce tax planning provides significant tax savings.   Here is what has gone wrong for the Government and good for small business.

  Who is this man?    He is Robert Lee Doughton.   He was the powerful chairman of the U.S. Congressional committee that writes the tax laws.

This man designed and wrote our international tax laws. His education was only high school. His father fought with General Robert E. Lee (General of the Confederate States of America).  He was named after the General.  He was born in 1863. His view of international commerce was via steamship

In 1939, he wrote the international tax laws that govern today’s international taxation in America.[1]  Most of the congressional representatives who wrote the 1939 tax code were born before 1900.    Their view of the world was what you see in many silent movies … and so was their tax law.

Their idea of technology was steamships and the telegraph.  It is this world vision that governs how the U.S. taxes international business and investment today.

On this link, you can view my forty-minute of my presentation of the California Society of Certified Public Accountants on profiting from Congress’s failure to innovate.

Successful E-commerce international tax planning revolves around a major flaw in American tax law caused by the speed of change (more on this link).  

If you need to up the quality of your tax planning, then contact me, Brian Dooley, CPA, MBT, at [email protected]

[1] Congress renamed the tax code in 1986 to the “Internal Revenue Code of 1986.” As I wrote this, I realize that 1986 was just at the end the “second wave” of business. The tax consequences of leaving the economics of the second wave and moving into the economics of the third wave are discussed in this video.