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March 19, 2019 - Phil Hodgen

Minimultinationals Chapter 02: It’s All Taxable to You

Introduction

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.1

Recap

What’s a minimultinational?

Let’s recap. A minimultinational is a small business that:

  • Has U.S. owners; and
  • Generates its profits outside the United States.

“Small” is relative. A minimultinational might have sales in the hundreds of millions or the hundreds of thousands.2

Who this is for?

This series is for owners of minimultinationals.... continue reading

Friday Edition Minimultinationals
March 18, 2018 - Phil Hodgen

Upcoming Section 965 Workshop and a Collection of Links

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!

Rufus Rhoades will give a one-hour free workshop on March 23, 2018 at 9:00 am Pacific Time. Register here; it’s free.

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

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