Tag Archives: international tax strategies

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.

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.


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.

Czech Republic
The Isle of Man
New Zealand
South Africa
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.).

tax planning, best tax planning, best small business tax, best small business tax planning, small business tax planning strategy, best small business tax planning strategy,

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).