Tag Archives: international tax strategies

Provocative International Tax News

offshore tax planning, offshore tax strategies, controlled foreign corporation,

Tax Planning Small Business Are Taxed at 14%

Government Report Shames Businesses Paying More than 14% in Taxes.    Hard to believe that Senator Bernie Sanders  (who paid tax at 13%) released the report.  It states that a business that plans its taxes are taxed at 14%. Here’s what’s going on.   

International tax planning for the Contract Manufactuere

International tax planning for the Contract Manufacturer

Fantastic tax savings for importers of contracted manufacturer of their products.  This new IRS law gives tax savings to small businesses.  Learn more on this link and send it to your CPA.

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

International tax planning

Buy at Amazon for only $9.50.

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 2017 edition of  International Taxation in America for the Entrepreneur for $9.50 at Amazon on this link.

 

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 foreign 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 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 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 secret report on tax savings international tax plans that the IRS cannot stop was issued by the U.S. Department of the Treasury (a branch of the White House).

They reported the successful foreign tax plans of international businesses. We have obtained 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 changed much except the ‘King” takes only half.

Trust are the most efficient tax tool. International tax planning should start with a Nevada trust to own the 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.   IRS memo on asset 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 avoid taxes on this link.  E-commerce companies are avoiding state income taxes and in some cases deferring U.S. taxes.

Be an IRS tax wizard with our new custom Google search, on this link.  This custom Google app to read 400,000 pages deep inside the IRS’s website and the tax court’s website.

International Tax Planning for Electronic Commerce, Foreign Trade and E-commerce

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.

These tax laws work just fine in the industrial age.

But we are in the age of “internet of things,” the cloud and Amazon and these 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 few chapters in this six-minute video below.

Want to take your tax planning to the next level, then contact me, Brian Dooley, CPA, MBT [email protected] for a free consultation.

Meanwhile, please spend six minutes and listen to the first three chapters.

IRS Computer Connects with 34 Countries to Exchange International Tax Information

Oh, the IRS National Office and the Department of Treasury have been busy tracking Americans.  I came across this list of countries that have network their computer systems with the IRS’s.

The exchange of tax information is automatic.   Yep, before the IRS computer processes your tax return, the computer knows your offshore activities.     If you are not American, be aware that the information goes both ways.

How to protect yourself from the IRS Big Brother Computer?  The “Wealthy” uses irrevocable non-grantor trusts discretionary trusts.   These trusts have a separate IRS tax number.  They are a legal tax person.  The trust files a tax return that is separate from yours.  

If you wish to brainstorm trust tax planning, then call me, Brian Dooley, CPA, MBT at 949-939-3414.  (Learn more about the IRS Big Brother computer on this link).

Here is the list of countries that are connected to the IRS computer system.

Australia
Brazil
Canada
Czech Republic
Denmark
Estonia
Finland
France
Germany
Gibraltar
Guernsey
Hungary
Iceland
India
Ireland
The Isle of Man
Italy
Jersey
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Mauritius
Mexico
Netherlands
New Zealand
Norway
Poland
Slovenia
South Africa
Spain
Sweden
United Kingdom

Best International Tax Structure for Doing Business in the United States

International Tax Planning:  Best international tax strategy for doing businesses in the United States.

I start this post with some bad tax news:  Code Section 163(j) denies corporations an interest deduction for interest paid to related persons when the related persons are not taxable by the U.S. on the interest received.[1]  The purpose of this law is to punish the foreign business that establishes a domestic corporation with money from a related foreign corporation.

To avoid this bad law, you use a different type of business entity.   This blog will explain this to you.

The section applies to any corporation that has the following two characteristics:

(1) the interest that exceeds 50 percent of the corporation’s adjusted taxable income, plus the amount of any excess limitation carryforward; and
(2) the corporation’s debt/equity ratio exceeds 1.5:1.

The ratio of debt to equity is the ratio of the corporation’s total debt to the sum of its net assets.  In determining the amount of the corporation’s assets, non-cash assets are taken into account at their adjusted bases.[2] For example,  you fund your corporation with $1,000 of capital.  You also loan the the corporation $4,000.  This law applies and your interest expense deduction is limited.

Okay, now some foreign tax planning for the small business.

The best tax structure for the privately owned international business doing business in the U.S. is a limited liability company owned by the entrepreneur and a Nevada trust.  In the diagram below, the LLC on the top would be belonging to a Nevada trust and the entrepreneur.  The irrevocable discretionary trust can avoid the U.S. death tax (about 45% of the value of assets in the U.S.).

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

For the best tax structure to own U.S. real estate, please see our article our this link.

[1] This law applies to interest on loans from unrelated parties if the loan is generating interest to a related party that is not subject to U.S. taxation and there is no gross-basis tax imposed by the United States on the interest paid.

[2] Code Section 163(j)(2)(C)(i).

Learn the tried and true strategy with my easy to read book (in Kindle, paper and audio).