Quote:
Originally Posted by Greedy,Greedy,Greedy
162(m) relates to business deduction of salary. Just make it something other than salary, whether dividends or equity comp what have you. Lawyers who take partnership draws aren't subject to 162(m); it is a corporate provision.
So you're saying that if I keep my cash abroad it's not taxed here. WAHOOO! Not a problem. Retiring to the little Attican villa owned by an offshore trust sounds cool. In the meantime, Canada is close and very, very nice.
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As for Section 162(m), I would repeal everything but Section 162(m)(1), redefine it to apply to all business entities not disregarded for FIT, and make the only limitation on it an allowance for any compensation to the extent it is exempt from employee income and deductible to the employer under IRC 401. Also, dividends, equity, options, etc. are all taxable compensation except to the extent excluded under the Code. My first step would be to remove all exclusions except for income treated as income of the sole owner of a disregarded entity or income subject to IRC 401.
If it's earned in the US, it's taxed in the US. I was talking about removing the ability to offshore earnings or inbound earnings through loans or other constructive transactions.