All of the profits generated by a minimultinational enterprise will be exposed in real time to the U.S. tax system. Chapter 2 explains why.
We will talk about how the U.S. taxes those profits in future installments of this book. Different business structures have different tax results.1Recap
Let’s recap. A minimultinational is a small business that:
“Small” is relative. A minimultinational might have sales in the hundreds of millions or the hundreds of thousands.2
This series is for owners of minimultinationals.... continue reading
The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces income recognition in the 2017 tax year, so there is not a lot of time to figure this one out!
I call this a workshop because the intention is for Rufus to talk a bit about the new law, then we will open it up for questions and input. Some of you out there are smart about Section 965, so please share with us.... continue reading