Tag Archives: offshore tax planning

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.    

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

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

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 used 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.

Trusts 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 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.
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.

By Far, the Best International Tax Planning Book on the Planet

Here are the first few chapter of my easy to read book International Tax Planning in America for the Entrepreneur.   The book is a quick two-hour read. 

The book explains the unique tax savings for the web base business, tax planning for importers and exporters and the best tax structure for the foreign investor coming to the U.S. 

You can get the book on Amazon on this link.  The Kindle is only $9.50.  The book is also available in paper and audiobook. 

International Taxation in America for the Entrepreneur is the fastest tax answering publication in America. Both the  Kindle and PDF edition have our exclusive quick search function. Just type your topic and find the answer to any international tax planning question.  The audiobook is perfect for those on the road and traveling. 

No other foreign tax book is updated via the internet. You can be assured that you have the best foreign tax planning book on the market.

Cross Border families have special needs because America’s laws differ from every other country. The multi-national family risks paying taxes in more than one country.  

 A cross-border business has a similar problem.  Multi-national businesses often experience double taxation on one item.  American tax laws are different from the rest of the World.    

Using  “plain English” my book provides solutions to issues regarding cross border taxation.  For those looking for advance tax planning, the hundreds of footnotes and hyperlinks to court cases and tax planning articles are just a mouse click away.

Please take a five minute test drive of the audiobook, below. 

Saving Taxes with a Late-Filed Form 5471 (Controlled Foreign Corporation)

Big Data, Big Brother, IRS, roboaudit,

IRS Private Letter Rulings provide you certainty in your foreign tax planning. .

Offshore tax planning involves filing Form 5471 by any U.S. person owning shares of a foreign corporation. If the Form is not filed, audit time period of  your individual and domestic corporation return never ends.  

For example, in 2016 you own a foreign corporation.  You did not know that Form 5471 must be filed.  Ten years later, the IRS audits your 2026 return and discover you owned a shares of a foreign corporation in 2016.  The IRS can audit your 2016 return in 2026. 

We found an internal IRS letter stating that the IRS that once your file the Form,  the IRS is limited in its ability to assess taxes.  Lesson: It is better to be late than to never show up (or in this case file the tax form).  

The IRS issued this letter as  IRS Letter Ruling 201432020 which is below in blue print.

If you need help with your international tax concerns, then please email me, Brian Dooley, CPA, MBT at [email protected] 

The IRS internal letter is below is blue. 

Number: 201432020  Release Date: 8/8/2014 

From:  IRS International Tax
Sent: Tuesday, July 22, 2014 3:17:00 PM

Subject: Section 6501(c)(8) 

I understand you have a question about 6501(c)(8) as it relates to one of your cases. I  hope this clarifies things for you.    

In your case, section 6501(a)’s period of limitations would have expired in prior to the effective date of the HIRE Act.  Section 6501(c)(8), however, prior to the HIRE Act would have kept the statute open as to the entire return due to the taxpayer’s failure to file the Form 5471.   

When the HIRE Act came in 2010, amending slightly section  6501(c)(8), the effective date provision of the Act provides that the HIRE Act (2010) version of 6501(c)(8) applies to returns filed after the effective date (not our case) AND, returns filed before the effective date (our case) if the section 6501 statute of limitations was still open as of the date of the enactment of HIRE Act.

 Given that the period of limitations was open on the whole return under the pre -HIRE version of the 6501(c)(8) at the time of the enactment of HIRE Act, it remains open under HIRE act as to the whole return.   

If the taxpayer files the missing 5471, however, and establishes that it had reasonable cause for the late filing of the form, then the statute of limitations under section  6501(C)(8) would be open for a period of three years from the date of the filing of the form, but the assessment period would only be open as to the items related to the late-filed information return pursuant to 6501(c)(8)(B).   (Author note:  This is great news.  Most attorneys and CPAs believe that your entire return was open to assessment; not merely the items of taxable income on the Form 5471)

If any other provision of section 6501 keeps the assessment period open for a longer period of time (such as 6501(e) or (c)(3)) then we would rely on the longest assessment period possible. 

Internal Revenue Service
Office of Chief Counsel
1111 Constitution Ave., NW Washington, DC 20224

Trump “I Fight Very Hard to Pay as Little Tax as Possible” & Shouldn’t You?

Mr. Trump is not the first President that promote legal tax avoidance.  We know that Big Business and the Wealthy pay less in taxes.   If you own a business or real estate, my  the question is “Why don’t you?”

tax planning, avoid taxes, small tax business,

President John Kennedy (Democrat) is the most respected president of last century. The President and Supreme Court Justice Hand agreed that patriotism does not mean paying more than your legal share.
Supreme Court Justice Holmes said tax planning means you get as close to that legal line as possible

As JFK stated, the less you pay in taxes, the more money you have to create new jobs as you expand your business.

While President Kennedy as a Democrat, he and his family were very wealthy.  He and his family knew that it takes money to make money.

Senator Bernie Sanders paid tax at 13% and reported that tax planning corporations are taxed at an average of 14% (more on this link).

Yet, most small business owners believe tax planning means talking to their CPA at year end.

This is not tax planning.  Tax planning is closely looking at each function of your business. Then you optimize that function’s structure to avoid taxes.

Presidential Candidate Mitt Romney provides such example.  He has offshore businesses.  To bypass all the complex controlled foreign corporations tax laws,  he used a self-directed retirement plan,  You can learn how to use a Romney type self-directed retirement plan on this link.

mitt Romney IRA,

Big tax savings require a long term tax strategy. As long as you keep thinking “year end” tax planning, you will always pay more than your fair share of taxes.

This is why he is a billionaire.   He spends money to save money.  While most small business owners spend more on car maintenance than tax planning.

Since his plan, a new plan allows has been enacted for small business.  It is called the “Solo 401K” plan and your can learn how to use it on this link.

The Trump $billion legitimate tax loss is not from “year end” tax planning.  It is planned years in advance.  Mr. Trump had to avoid the following laws that prevent such a loss:
1.  “At Risk” limitation,
2.  “Passive loss” limitation and
3.  “Forgiveness of Debt” income.

Often I wonder if one of the reasons a small business becomes a big business is their passion for legal avoid taxes.  When LifeCycle started in a garage in Irvine (my home town), we had many breakfast meetings talking about taxes.   Year-end tax planning was never a topic. LifeCycle is now a “Big Business” with  40 years of success.

What you can do to have more money by paying less taxes.
1.  Be the leader of your tax team (usually a CPA and attorney).
2.  Be willing to work hard to avoid taxes
3.  Focus on the reward of having more cash to pay your bills and expand your business
4.  Be willing to spend $1 (on professional fees) to save $5 in taxes.
5.  Dissect your business and examine the tax laws for each activity.

If you want to save taxes like a billionaire, then create and work with your tax team. Meet no less than once every three months.  

Meanwhile, please enjoy our radio tax show on Blog Talk, entitled Presidential Loopholes.

tax planning, avoid taxes, small tax business,

Great Tax Savings using the New IRS Regulations on Debt versus Equity

tax planning, avoid taxes, small tax business,

President John Kennedy (Democrat) is the most respected president of last century. The President and Supreme Court Justice Hand agreed that patriotism does not mean paying more than your legal share.
Supreme Court Justice Holmes said tax planning means you get as close to that legal line as possible.

If you were a tax nerd, like me, you would have read many many articles on the new IRS section 385 regulations (debt versus equity transactions).  Nobody like change and that applies to most tax planners.   But for every action, there is an equal reaction.

While corporate tax planning will be more complex with these regulations, small business tax planning is improved.

 This blog looks at shifting income and wealth by valuing a promissory note.  For estate tax planning, you want the note to have a low value.

For small business income tax planning, you want the note to have a high value or a low value. In the example below,  the note had a low value.  
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