Tax Fairness for Americans Abroad Act of 2018! Let's get this passed!

Tax Fairness for Americans Abroad Act of 2018! Let's get this passed!

Tax Fairness for Americans Abroad Act of 2018! Let's get this passed! http://bit.ly/2EGkyuh Contact info for key players: http://bit.ly/2EDTmvh https://youtu.be/_WcK1vZtDh0 IRS Medic

Six Ways to avoid GILTI: How to beat the Global Intangible Low Tax Income

Six Ways to avoid GILTI: How to beat the Global Intangible Low Tax Income

Full article: https://ift.tt/2SSi675 What is GILTI: https://ift.tt/2MaYGHr GILTI help :There are six possible ways I know of to avoid, or perhaps more accurately, mitigate GILTI tax exposure. By this time, you probably know that GILTI stands for Global Intangible Low Tax Income. In previous videos I explained the rough idea of what GILTI is and in the next video of this series I will be discussing how to calculate GILTI liabilities. After calculating GILTI liabilities you may now realize how important this topics is. So be sure to subscribe so you don’t miss out on important topics. So now let’s get to those six ways. First, you can elect to covert GILTI to subpart F income. Now you might be scratching your head on this. If you understand a little about international taxation you know that Subpart F is something to be avoided. However GILTI can be so bad, that it can make Subpart F seem good! The second way is a little bit more opaque. You can increase something call QBAI. QBAI stands for Qualified Business Asset Investments. There are a few ways to do this. For instance one can purchase equipment that has been previously leased. The downside is that just because someone is a shareholder in a Controlled Foreign Corporation it does not mean that they can actually control the corporation enough in order to implement this strategy. Management might not be all that hip to this idea. And second, this is a business decision that could have negative effects to cash flow. You might solve a GILTI problem but you could end up with a business problem. Third, GILTI is NOT calculated on a company basis. It is done on a shareholder basis. And what’s worse is that losses in one CFC may not get full credit against gains of another CFC. The way to make sure you don’t miss out on any of your losses is by combining CFCs. Forth, simply avoid either CFC status or US shareholder status. The problem with this is tax reform expanded the definition of what it means to be have a CFC status. However, by adjusting ownership levels with non-US owners, you may be able to find a great solution that avoids this entire mess. The downside is this is not feasible for many people and second, you need to watch those attribution rules — which also have changed for the worse. When you have related parties, you might be considered to have CFC even though you would otherwise not if the parties were not related. The fifth way, and this is proving to be the winner for many of our clients, is to funnel all shares in foreign corporations into a domestic US holding company. This was an overriding theme of the 2017 Tax Cuts & Jobs Act — bring capital back to the US. The reason it works is that US C corporations are allowed to do something US individuals are not. Take what is known as a Section 250 deduction of 50% of GILTI. The downsides are that this does require extra hurdles of having a US domestic corporation which you must honor the corporate formalities of and an additional tax filing requirement of the domestic corporation. However, if your GILTI liabilities are even as low as say $20,000 or even $10,000, it still could be worth the hassle to create this structure. A sixth way I can think of is this. What about putting shares of a CFC into a Private Placement Life Insurance Policy or PPLI. PPLIs are used by the most sophisticated investors for what I consider to be the ultimate tax structure. Essentially how it works is that your assets go into a life insurance policy and you borrow from the death benefit while you are alive. And because death benefits are tax free, you’ve essential avoided all income taxes — both federal and state. This is an even better move to make if you happen to be in a high tax jurisdiction like California or New York. The downside is that life insurance turns most people off, and these are complicated structures and require a flexibility that so many business owners are unwilling to exercise. Additionally the costs are intense. Typically it only starts making sense when you have about $10 million in assets. We are woking on ways to reduce the cost, I’d love to hear from anyone who was able to implement a PPLI for for someone with less in assets. And also, I have yet to hear of a PPLI that has been implemented strictly with CFC stock. There are diversity requirements of a PPLI’s portfolio that could force you to sell your stock so much so that you could no longer have that CFC or US shareholder status. Also you must be very committed to following the structure. People get into trouble with PPLIs when they don’t take the rules seriously. Are there other ways you can think of to eliminate or mitigate GILTI? I’d love to hear about them. Please leave them in the comments below. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/teP8J5y13SM IRS Medic

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

MORE HERE: https://ift.tt/2G7uT3T Tax Reform 1.0, aka the Tax Cuts and Jobs Act of 2017 has some very unpleasant surprises for those with income and assets overseas. The good news is there is a stand alone bi-partisan legislation that will be presented for Congress to vote on and for President Trump to sign into law that will allow Americans living overseas to "opt-out" of the US tax code by simply filing a certificate that they are in compliance foe the past three years and now live outside the US. If this is passed into law, the burdens of compliance for the US exapt will be greatly reduced. In this video, Advocate for Americans Overseas, Keith Redmond and Attorney John Richardson of citizenshipsolutions.ca join tax attorney Anthony E. Parent as they discuss the proposed laws, regulations and potential law suit that could greatly help those frustrated by a tax regime that seems rather out of control. In particular the three discuss - An end to Citizenship-Based taxation and replacing it with a true territorial tax system - Potential relief for The Transition Tax (Section 965) and Global Intangible Low Tax Income (GILTI) along with the Foreign Account Tax Compliance Act (FATCA). - The IRS's offshore disclosure program for those with criminal exposure. While the acronym has stayed the same as OVDP, it now stands for Offshore Voluntary Disclosure Practice instead he prior Offshore Voluntary Disclosure Program. The three agree that very few expats should ever be scared into an OVDP and if a disclosure program is needed, a Streamlined Disclosure is far for preferential. Ultimately what is needed right now from everyone concerned is unity. No matter your political affilication, the law needs to be changed. The law fails to raise revenue effectively and it is just morally wrong to tax people who are tax residents of outher countries. It is essential that everyone contact Congress and makes their voices be heard: Territorial Tax for Individuals must pass! Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/qa5jeq3hM1s IRS Medic

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

Tax Reform 1.0, aka the Tax Cuts and Jobs Act of 2017 has some very unpleasant surprises for those with income and assets overseas. The good news is there is a stand alone bi-partisan legislation that will be presented for Congress to vote on and for President Trump to sign into law that will allow Americans living overseas to "opt-out" of the US tax code by simply filing a certificate that they are in compliance foe the past three years and now live outside the US. If this is passed into law, the burdens of compliance for the US exapt will be greatly reduced. In this video, Advocate for Americans Overseas, Keith Redmond and Attorney John Richardson of citizenshipsolutions.ca join tax attorney Anthony E. Parent as they discuss the proposed laws, regulations and potential law suit that could greatly help those frustrated by a tax regime that seems rather out of control. In particular the three discuss - An end to Citizenship-Based taxation and replacing it with a true territorial tax system - Potential relief for The Transition Tax (Section 965) and Global Intangible Low Tax Income (GILTI) along with the Foreign Account Tax Compliance Act (FATCA). - The IRS's offshore disclosure program for those with criminal exposure. While the acronym has stayed the same as OVDP, it now stands for Offshore Voluntary Disclosure Practice instead he prior Offshore Voluntary Disclosure Program. The three agree that very few expats should ever be scared into an OVDP and if a disclosure program is needed, a Streamlined Disclosure is far for preferential. Ultimately what is needed right now from everyone concerned is unity. No matter your political affilication, the law needs to be changed. The law fails to raise revenue effectively and it is just morally wrong to tax people who are tax residents of outher countries. It is essential that everyone contact Congress and makes their voices be heard: Territorial Tax for Individuals must pass! Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/y9J_stB9OWE IRS Medic

IRS announces new 2018 OVDP procedures - BIG UPDATE

IRS announces new 2018 OVDP procedures - BIG UPDATE

Contact: info@irsmedic.com Links: Article w/ text version of memorandum - https://ift.tt/2AzqxMS Upcoming CLE with Strafford - https://ift.tt/2TYEpZT On November 20, 2018, the IRS announced new Offshore Voluntary Disclosure procedures, ending months of speculation on what would happen without an official OVDP in place. Thanks to Jack Townsend for posting this notice on his Federal Tax Crime blog. https://youtu.be/HK5FscoYtao IRS Medic

Why are accounting and financial analysis so confusing?

Why are accounting and financial analysis so confusing?

Financial Statement Analysis and Accountancy 101: In this video we explain why you might not be such a dummy about understanding the basics and the more complicated items . Are you frustrated by accounting and financial statements? If you are given a balance sheet, do you just want to run and hide? Are you intimidated by P&Ls, accruals, amortization, double-entry bookkeeping? Good news. I'm not going to get too deep into any of that. But rather, I want to share with you my own frustrations with accounting and financial statements so that you can completely dispel the notion that understanding accounting and conducting your own financial analysis is somehow above your abilities. 1. There are no black and white answers. Accounting is supposed to reflect reality. Yet reality is an awfully complicated sort of thing, isn’t it? And also, sometimes people want to show you a particular kind of story. For instance, can you ethically manipulate your books to show a high value so that you can obtain optimum financing? The answer is yes. It’s done all the time. And conversely, could you show lower profits, hence a lower value, to reduce your taxes? Yes, and this too, is done all the time. In fact, both things are done so routinely, no one even mentions it. Yet there exists this idea that “numbers are the numbers” and “numbers don’t lie.” What complete nonsense. Numbers can be the most effective lies! The dirty secret about accounting is that everything is cooked. But as long as you understand the underlying assumptions and the purpose of the books, and how they were “cooked” the books can still be both honest and helpful. 2. If you are more confused after speaking with either your attorney or accountant or CFO something is wrong. If you are able to start or run your own company, a good attorney, accountant, or CFO should be able to explain any concept to you in simple language. 3. Trust your gut. No one should ever be more interested in your business than you. You probably know the right answer, you are just unable to express it in accounting terms. But just because you can’t express it, doesn’t mean that you’re not right. 4. If you can measure something you can improve it. This is a critical function of accounting. This is why it is so important to understand the underlying assumptions that are “cooked” into the books — then you can make meaningful comparisons to see how you are improving and what still needs improving. Bottom line: Your books should work for you, not the other way around. But sometimes a business owner needs help getting their books to work for them. For us, we’ve seen very little difference between a great accountant and a great lawyer and a great CFO. As a tax and business attorney, I actually speak the same language as our accountants and ou clients' CFOs. All of us work in concert to characterize and qualify things in order to better represent a narrative that suits our clients needs the best. So what do you find confusing about accounting? We’d love to see if there is actually a question we can’t answer in 100 words or less. So please, if you have a question, leave them in the comments below. We love a challenge. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/IGm9GoFEEhk IRS Medic

Why does the IRS audit taxpayers? This insider information that might really help you

Why does the IRS audit taxpayers? This insider information that might really help you

Does this seem like a silly question? Well it's not. Because slowly but surely, the IRS audit process has changed over the last 10 years and it is critical you understand why, if you or your business is the one who is the subject of an IRS examination. In this video, tax attorney Anthony Parent speaks about both the public statements the IRS has made, along with his law firm's clinical experience helping thousands of taxpayers deal with an overbearing IRS. While so many articles are written by tax lawyers, accountants, CPAs and other tax professionals about the IRS Audit Red Flags, Attorney Parent explains the reasons why these articles are obsolete. Believe it or not, the IRS used to audit, or in IRS-speak “examine,” every single taxpayer. The reason is that when the income tax was first enacted in 1913, it only applied to those who were truly wealthy. No income tax was due until your income exceeded an inflation adjusted $500,000. And the top tax rate of 6% did not come into play until your income was at the equivalent of $12 million. Because the income tax affected so few people, the IRS had the resources to audit every single return. This changed of course. When Congress blatantly and openly broke the central promise of income tax by applying the tax to nearly everyone — not just the truly wealthy as promised. This drastic change created a flood of new taxpayers that the IRS audit team could not keep up with. So the IRS began to audit only a portion of taxpayers year after year. The purpose of these audits was to primarily ensure compliance. Believe it or not, assessing additional revenue was not the main goal of the examination division. Again, it was compliance compliance compliance. So anyone could be subject to an audit. The IRS really wanted to spread the misery around, and it did. Along with multibillion dollar corporations the IRS would also routinely audit the plumber down the street. But things changed politically. The IRS is one of the least-liked organizations in the world. And many politicians don’t want to be seen as supporting the IRS. Yet, they don’t want that revenue the income tax brings in to dry up. So what’s the play for someone who needs to look like they are on the taxpayers side, but are still completely in love with that revenue the IRS brings in? Well it’s simple. Cut the IRS’s budget. In fact, the IRS’s budget has been cut so much, in the last ten years, the IRS lost its most experienced agents and officers. Yet they haven’t been replaced. Yet, Congress insists the IRS do more with less. And because ensuring compliance isn’t really a goal that has a data points that one can rest their conclusions upon, the new focus for the IRS examination divisions has become something that is more measurable — that is, increased assessments. So this is the sea change. The IRS is no longer interested in compliance for compliance sake, but rather wants examinations where there will be a good chance of assessing additional taxes and for them, massive penalties. So what types of cases involve the prospect of huge additional assessments? The focused targets we see are: Domestic cases where the IRS suspects something egregious; Cases involving foreign income and assets. The IRS wants domestic audits where they suspect a slam dunk that could trigger massive civil fraud penalties along with a huge tax assessment. And also, the IRS also wants more international audits. The reason? Cases involving international income and assets are a huge penalty wonderland for the IRS. There exists a litany of penalties that can trip up any decent, honest, intelligent person. Penalties of over $10,000 for not reporting the existence of a foreign bank account on what is known as an FBAR form, and penalties of $10,000 for not reporting the ownership of a foreign bank account on a slightly different form, a Form 8938 Along with: A $10,000 for not reporting interest in a foreign business on Form 5471 A $10,000 for not reporting a Foreign pension on Form 3520-A A $10,000 penalty for not reporting distributions from a foreign pension on a Form 3520. A $10,000 penalty for not reporting a transfer to a foreign business on Form 926. Multiple penalties for multiple years can really add up into the hundreds of thousands of dollars. Oh and by the way, this list is far from exhaustive. And willful FBAR penalties can even be higher How to win your audit? It is critical you get the highest level of legal representation possible if you are worried that a revenue-hungry examiner is looking at you as a mere target to aggregate into a press release. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https;//www.irsmedic.com https://youtu.be/FxVRnJnegMQ IRS Medic