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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 using their own contract manufacturing company.  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.

IRS is Gunning for Small International Businesses with Bad Bookkeeping

International tax planning and strategy

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

IRS National Office international tax specialist, Anne P. Shelburne, Esq. knows her stuff.  She knows that the Achilles’ heel for small business is that they go “cheap” on bookkeeping.

The best international tax plan crumbles without “books and records” (the term used in the tax law) to support the plan.

This is great for her because, as you will read below, she informs the IRS auditors and special agents that all income is U.S. source unless the taxpayer can prove the amount is foreign source.  That is right.  You lose and they (the IRS wins).  In America, when it comes to civil tax audits, you are guilty!  You have the burden to prove your innocence.

There are other reasons for good bookkeeping.  Here are a two:
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IRS Updates its LLC Web Page- Special Rules for Foreign LLC’s

The IRS has updated its web site for limited liability companies (LLC).   Different tax laws apply to a foreign LLC and a domestic LLC.

 A foreign LLC is taxed as a foreign corporation.  You can elect to have the foreign LLC to be disregarded or to be a partnership (if it has more than one member).  There is more on this at the end of this blog. 

A domestic LLC is disregarded or is taxed as a partnership (if it has more than one member).  The domestic LLC can elect to be  taxed as a domestic corporation.

The tax classification of the foreign LLC is the opposite from the domestic LLC.

foreign LLC is usually  taxed as a corporation and is not a disregarded entity.   A foreign LLC is a disregarded entity if, under the laws of the country, a owner are liable for the LLC’s debts.  Each nation’s laws are different.  

To obtain certainty with the IRS, you must file form 8832.  Use IRS form 8832 (below) to elect disregarded or partnership status or corporate status.  You want certainty in your tax planning. 

The IRS  update is below.   If you need to up the quality of your tax planning, then contact me, Brian Dooley, CPA, MBT, [email protected]

For IRS International Audit Guide on foreign entity classification, please see this link.

Learn international tax planning with my easy to read book at Amazon (in audio, Kindle and paper) on this link.

The IRS Special rules for Limited Liability Company (LLC)  (Including a Nevis LLC, a Belize LLC and a Cayman LLC). is below

A Limited Liability Company (LLC) is a business structure allowed by state statute. LLCs are popular because, similar to a corporation, owners have limited personal liability for the debts and actions of the LLC. Other features of LLCs are more like a partnership, providing management flexibility and the benefit of pass-through taxation.Owners of an LLC are called members.

Since most states do not restrict ownership, members may include individuals, corporations, other LLCs and foreign entities. There is no maximum number of members. Most states also permit “single member” LLCs, those having only one owner.A few types of businesses generally cannot be LLCs, such as banks and insurance companies. Check your state’s requirements and the federal tax regulations for further information.

There are special rules for foreign LLCs Classifications.  The federal government does not recognize an LLC as a classification for federal tax purposes.  This means that the LLC is classified as something else. 

An LLC is classified as  an corporation, partnership or sole proprietorship tax return. An LLC that is not automatically classified as a corporation can file Form 8832 to elect their business entity classification. A business with at least 2 members can choose to be classified as an association taxable as a corporation or a partnership, and a business entity with a single member can choose to be classified as either an association taxable as a corporation or disregarded as an entity separate from its owner, a “disregarded entity.” Form 8832 is also filed to change the LLC’s classification.

Effective Date of Election. The  election to be taxed as the new entity will be in effect on the date the LLC enters on line 8 of Form 8832.  However, if the LLC does not enter a date, the election will be in effect as of the form’s filing date.  The election cannot take place more than 75 days prior to the date that the LLC files Form 8832 and the LLC cannot make the election effective for a date that is more than 12 months after it files Form 8832.

If the election is the “initial classification election,” and not a request to change the entity classification, there is relief available for a late election (more than 75 days before the filing of the Form 8832).

Author note: International tax planning with a foreign limited liability company and most foreign corporations start with Form 8832.   This is important.  Without filing this form and election to be treated as a pass through entity, your foreign LLC is taxed as a foreign corporation.  This will cause the controlled foreign corporation rules to apply.