Tag Archives: saving taxes

Tax Planning with GOP Tax Law with Tax Talk on Blog Tax Radio

Tax Planning with the OP Tax Bill uses sophiscated tax laws.  The days of simple tax strategies are gone with the new GOP tax laws.   The GOP Tax Law is written for Big  Business.  If you want to save taxes, you will need to think and act like Big Business.

Learn these sophiscated tax laws with my radio show, Tax Talk. We support a subscription-free internet content supported by advertising.  

Each episode as a 60-second commercial by the company hosting our radio show.

The first episode is the new IRS designer trust… designed by the IRS to avoid  state out of state income taxes. 

Tax Planning with the GOP Tax Bill requires you stop paying state income taxes. 

The trust is the new “Nevada self-directed trust”  You can keep control and avoid state income taxes.  

Tax Planning with the GOP Tax Bill requires you to protect yourself from the IRS’s Big Brother Supercomputer exposes the IRS “financial DNA” of each of us stored in its new Big Data computer.

Tax Planning with the GOP Tax Bill with more Podcasts

Find additiona sophiscated tax planning Podcasts on this link for  Provocative Tax Planning on BlogTalkRadio.  For small business international tax planning with the GOP tax bill, please see this link.

If you need help with tax planning with the GOP Tax Bill, then contact me, Brian Dooley, CPA, MBT, at [email protected]

Court Explains Offshore Company International Tax Plan

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Tax Court explains great tax planning in this case.

This blog is about “Offshore Company International Tax Plan” approved by the the U.S. Tax Court.   The court’s  blueprint on offshore tax planning with a tax haven corporation will cut your tax burden in half.  

 In this Tax Court case, a private annuity was used to fund the foreign corporation.   The   corporation invested in publically traded stocks. 

A private annuity with a foreign corporation is a popular tax plan for the very rich.

What I like about the case, is that the IRS is the victor.  This means the IRS is not likely to disagree with its court victory

Offshore Company International Tax Plan with a Private Annuity

It works like this.  I form a BVI company with $10,000 as capital.    Then I fund my BVI corporation with an additional $90,000.  However, this time my corporation signs an agreement promising me an annual payment of $8,000 a year for the rest of my life or until I dissolve my corporation.    This arrangement is called a “private annuity.”

My BVI company earns $8,000 a year on its $100,000 (the $10,000 for the capital and the $90,000 for the private annuity).  It also deducts the $8,000 it pays me on the annuity,  leaving the corporation with no taxable income.   However, the annuity income tax rules, section 72, allocates $4,000 a year to my cost.  Of the $8,000 I received on the annuity, only $4,000 is taxable ($8,000 minus my allocated cost of $4,000).

I cast my tax planning is stone by filing IRS Form 5471.  Of course, I reference the IRS Tax Court case victory on the Form 5471. It is in this form that I report the activity of my offshore tax haven corporation.  As you may know, Congress enacted new laws to improve offshore corporations.  Here is a link with the basic.

Listen to our internet radio show, Tax Talk,  below (the show is about 15 minutes) to learn how to save taxes on your investment income with your controlled foreign corporation funded by your private annuity.  The term “private annuity”  means that no insurance company is involved.  Only you and your corporation are involved.  

Too busy to listen now? Ok.. then download the episode from our free Itunes page on this link.


Seemingly innocent but deadly to the IRS, private annuities have saved taxes since the beginning of the 1900’s.   But, now they are better.  The U.S. Tax Court agreed that private annuities paid by a tax haven corporation avoid all of nasty the anti-tax haven laws.

It gets better.  The IRS private  annuity interest rates are at an all-time low (about two percent).  This allows for income shifting to your offshore company.

Something as simple as your controlled foreign corporation funded with your money provides tax savings and asset protection beyond your wildest dreams (tax dreams that is).

The trick?   The trick, as you will learn on our internet radio show, Tax Talk (below), is the IRS’s information return, regulations and a recent Tax Court victory in  Dante and Sandi Perano, Petitioners vs. Commissioner of Internal Revenue.

Need Help with your Offshore Company International Tax Plan

If you need advice for your office company international tax plan, then contact me, Brian Dooley, CPA, MBT, at [email protected]

Avoiding Taxes Requires Watching the Politics of a Nation with a Huge National Debt

Successful tax planning looks for trends.  Tax planners look down the road and around the bends.  They structure now for tomorrow.   They don’t rely on year-end tax planning.

A recent article (in France) jumped out at me as I read about the American Republican Parties pretending to “reform” taxes.   France government subsidies and immigration are worst than the U.S. (thankfully).  However as the U.S. National debt combine with many states and cities facing insolvency, the battle between the have nots and the have is  looming.   New York has proposed a new tax that applies only to the haves.

Keep in mind, as you read this article, former President Obama, at an Orange County rally, told the audience those with household incomes exceeding $250,000 were the “rich”.   The $250,000 threshold continues to be the red line in the United States.   

You think it can not happen in America?  Since Democrat  Jerry Brown became governor, income taxes have increased by 30%.  The U.S, has had a tax rate up to 94%.  Add to that your state income taxes, I hope you can see that you must plan now for the future. 

Keep this in mind as you read this article.  

For your small business tax planning, you should watch the trends… which is higher taxes unless you are active in tax planning.   Great tax planning is not year end tax planning.  It is long term with a separate plan for each part of your business. 

I had the article translated  and it is below . 

Economic inadequacy or social justice? For thirty-six years, “the tax on the rich” made controversy. Emmanuel Macron wants to reform it, distinguishing between real estate and financial investments.

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Internet Tax Planning – Saving Taxes with the Cloud

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Saving taxes with the cloud-based business requires innovative tax planning,

Internet tax planning provides fantastic tax savings. 

The Internet-based business decides which country or state has the best tax advantage.  Saving taxes is easier than ever.  You will learn how to save taxes on this blog.

International e-commerce tax planning starts with placing your computer server in a low tax or no tax jurisdiction.  Web-based business tax planning provides big state and federal tax savings. 

To learn how big international companies are using the internet to legitimately avoid taxes, please view the California Society of CPAs 40 minutes seminar on this link or listen below on my blog Tax Talk radio show.  You can also download the show as a podcast from iTunes.    

Don’t miss out on our new e-commerce tax planning book.  Learn more on this link.
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Avoiding the Form 1120F- Foreign Corporation Branch Profits Tax Trap

Preparing the Branch Profits Tax section of the IRS form 1120F  has trapped many foreign investors in U.S. real estate and with US business operations.

 In addition to paying income tax on your profit, the foreign corporation pays tax again on the change in the value of its U.S. business. 

The branch profits tax is based upon a law from the 1950’s. The section 531, tax on accumulated earnings, was deadly to a small business.  However, now most small businesses operate in S-corporations or limited liability company. Since entities of this type are pass through, avoid section 531 does not apply.   Because of this many tax professionals are unaware of this law.

The branch profits tax is just as deadly to the foreign business.  This tax applies if the foreign corporation has income effectively connected with a U.S. business. The applies if the corporation has either a permanent establishment of a fixed place of business.

 If you want help preparing your Form 1120F, then call me Brian Dooley, CPA, MBT at 949-939-3414.

Some CPA’s are advising their clients that keeping assets on the American branch office balance sheet avoids the branch profits tax.    Just holding assets on the books,  does prevent the branch profits tax.  The assets must be continued to be used in an active corporate business.

Section 531 (a tax on accumulated distribution) is the concept used when the branch profit tax was enacted.  Under this section, the corporation must prove the business reason for keeping liquid assets.   The point of section 531 is to cause the second tax.  This is a tax on a dividend that the corporation has refused to distribute.

Likewise, the IRS can impose the branch profits tax when a foreign corporation with a US branch merely retains liquid assets just to avoid the tax.   

Upon a distribution of property to the shareholder of a foreign corporation, the 30 percent branch profits tax apply.  Similar to section 531, corporation needs to maintain ongoing director minutes, shareholder minutes and business plans explaining why assets are not distributed to the shareholder or the home office.

Learn about winning the IRS audit of the branch profits tax on this link.   On this link, find out more innovative methods to eliminate both the branch profits tax and foreign corporation income tax on this link.   If you need help with an international tax audit, then contact me at [email protected]

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Learn how to save taxes with “International Taxation in America for the Entrepreneur” using tried and true methods.

If you would like to us to prepare your Form 1120F,  then please call me, Brian Dooley CPA, at 949-939-3414.  

Learn move about international tax planning with my easy to read book, International Taxation in America for the Entrepreneur available at Amazon on this link.  The book takes about two hours to read.