Try to drop your pre-existing beliefs about the topic for a moment (rich people bad, FedBots evil, etc) and ask why this attempt at persuasion has been brought to your attention.
Who benefits from the agitation that occur in your mind when you read this?
Canticle for Liebowitz. I was at a beach rental on vacation and it was on the shelf. Started about 7 pm and didn’t stop until I was finished, about 4 am.
I was in DC on a boondoggle maybe 15 years ago and had a meeting with an old-time staffer (and lawyer) for the Senate Finance Committee. Attached to the Democrat side of the SFC for what it’s worth.
He had been on the tax policy scene long enough to see the pre-1976 carryover basis days and the post-1976 step-up basis days.
He was adamant that a return to carry-over basis would be a shitshow for IRS administrative purposes and fervently argued for the current step-up at death law.
This is a Chesterton’s Fence situation.
The collective “we” seem to forget that many of these ideas have been tried before. This “soak the rich” idea (look at the CRS report and see the reference to an exemption for the little guy so we can tax the billionaire) is one such idea.
The other idea — floated by our current president — is to crank up the capital gains tax rate. This one has been tried (and reversed) before. It would be instructive to find out what those politicians Back In The Day were thinking when the capital gains tax rate went up and why it went down again.
A little bit of humility and history might save some optional wounds.
If the amounts are small, don’t bother lending to the company. Just make a capital contribution.
Loans must be interest-bearing. This makes your life as an entrepreneur more complex. Your tax return and the corporate tax return will cost more to prepare.
Optimize for simplicity in legal structure, bookkeeping, and tax return preparation.
(1) Why corporation?
(2) Why C corporation?
(3) Unless you’re injecting multiple millions of your own money into your new venture, whatever perceived tax benefit you can imagine will be dwarfed by the overhead and cognitive opportunity cost of getting clever.
(4) If you add investors, the first thing they’ll want to do is clear all the bullshit off your balance sheet. Why add it in the first place?
Just contribute capital, unless you can think of a damn good reason to do otherwise.
It's worth going to https://flyertalk.com and reading the forums. These are the people who play the airline status games.
Status with an airline is useful for (a) free upgrades, (b) lounge access, and (c) better phone service when you need to fix things.
I have Diamond status on Delta. (Top tier before their invite-only tier).
Upgrades. The only value I get out of it is that I can book a generic economy seat and immediately get upgraded to Comfort+ for free. I rarely get upgrades to First Class since Delta sells out the seats to real people for real money. I'm frequently #1 of a bunch of people on the upgrade list for nonexistent First Class seats.
Lounge access. I have the Delta Reserve Amex card that gets me into the lounges anyway.
Phone service. This is really an indictment of the shit service that airlines give. For a while, even with the priority phone service I would be on hold for an hour or so. It's far better now, admittedly.
Delta is making it drastically harder to achieve status in 2024. In all probability I am going to go free agent and fly any airline that gets me where I want to go, when I want to go, at a reasonable price.
The airline miles are useful. I don't think I've paid for a flight for my kids with money once in all the years they've been at university in other states. But that's just a "charge enough money on a credit card" thing. It has nothing to do with status.
Do not do create an U.S. corporation until you have a screaming business reason to do so.
Reason: U.S. tax reporting requirements create high accounting costs.
Your problem is not “controlled foreign corporation” status. That’s only for U.S. persons who are shareholders of non-U.S. corporations.
Your primary tax returns will be Form 1120 (the income tax return for a corporation) and Form 5472 (required when a U.S. corporation has at least one non-U.S. shareholder owning 25%+ of the stock).
Form 5472 is the anti-transfer pricing form used by the U.S. tax system to make sure that taxable income remains in the USA to get taxes. Penalties for screwing this up are steep: $25,000.
This means you will want to hire competent tax professionals. Competent U.S. international tax specialists tend to be rare and expensive.
Your tax reporting will also get more complicated in Germany.
I am a big believer in doing things correctly. Future You will reap the rewards that Today You made possible through hard work and solid foundations. Life is a marathon with no finish line.
That said, there are different gradients of “correct” at each stage of business growth.
I don’t know where you are now. I don’t know your revenue, your business needs, your product, where your customers are, whether you will hold this business forever or are building to be acquired, etc.
I will give you a data point for you to make a management decision, because this is a management decision and not an engineer decision. You are making a decision with significant opportunity cost to it, even if it is the correct decision.
Here you go. Money. Order of magnitude for a tax return for a simple U.S. corporation with ownership as you describe and minimal transactions between you and the corporation and the corporation and the outside world. $10,000. Reason: Form 5472. That’s the peak of the bell curve.
Opportunity cost of time and brain damage. 40 hours of your time per year (or pay someone and buy their time). You could be building a product or creating new customers.
At some point you need the infrastructure. Choosing the right time to buy it? That’s hard and there is no right answer.
Source: am international tax lawyer.
Standard legal waiver/disclaimer/pre-emptive strike/warning shot applies: I’m an idiot and I am not your lawyer, so this is not legal advice and if you think it is, you are an idiot.
1. How do I know you are who you say you are? (You don't identify yourself).
2. How do I know that you will do what you say you will do? (The website says says nothing).
3. How do I know that all spammers, worldwide, will do what you tell them to do and delete my email address from their databases permanently and forever? (Are you God?)
I'm sorry, but color me skeptical. Here's what I would want to see before accepting your offer:
A. Tell me who you are.
B. Tell me why I should trust you.
C. Tell me what you will do for me.
D. Tell me why you will succeed while Google, Barracuda, and countless other juggernauts have failed to keep spam out of my inbox.
"They sell you the benefits and give you the harms for free."
Your HN post sells me the benefits (no spam). That means you're giving me the harm for free. I don't know what harm is bundled with your benefits, so I will pass on buying the benefits.
Thank you for the link to the YouTube video. There are some thought-provoking (and behavior-changing) ideas in those 9 minutes.
My interpretation is that “strategy” as he defines it is an exercise in human whimsy. “I choose to play in this playing field.” “My theory for why I can achieve the objective — which is inherently outside my control — is xyz.” In other words, strategy is first a moment of creation. Ex nihilo.
After selecting a strategy the AI berserkers* take over and relentlessly and pitilessly drive you forward to Total World Domination.
So I guess what I’m saying is: I don’t understand how AI participates in that “In the beginning . . . “ creation of a strategy. Unless, of course, AI is God.
What am I not seeing?
* when I read all of the breathless doomer “AI is going to eat babies” articles online I am reminded of Fred Saberhagen’s Berserker series.
Imagine telling a business owner that there is no such thing as gross revenue. The price you charge your customers doesn’t matter, because what matters is net profit.
This is an effort at political persuasion, just as the concept of “tax gap” is a deliberately manufactured effort of political persuasion by the government. It’s a great phrase to focus your attention on something, isn’t it? Ask yourself what you’re focusing on, and whose interests are served by directing your focus.
In a sense, this article is correct. The only thing that matters is whether I have a dollar in my pocket to spend on anything I want.
From a different perspective, I am converting an irreplaceable hour of my brief existence into money so I can eat and sleep in a warm, dry place. This author is telling me to ignore the gauntlet of pickpockets (government included) that make my quest harder.
Hell, no. I will keep my eyes wide open. Just as I, as a business owner, keep my eyes wide open on my financial statements, from gross revenue and pricing to net after-tax profit.
Yes, after-tax profit is the only thing I can use to go buy a hamburger. But I don’t ignore everything else upstream from that.
The Ghost of Bernays is hard at work with this article.
"Admits interfering with U.S. elections." That's one way to look at it. "Claims to have interfered with U.S. elections" is another.
I'm not saying whether interference occurred or not and I don't know whether CBC knows the answer, either. I'm just seeing CBC's opportunity for manipulating public opinion.
I looked at recall-app.com and decided not to invest time exploring it further. The reason I passed is the same reason I moved from Roam to Obsidian and will stay with Obsidian:
* Data in some mysterious location "in the browser" with a promise of future export capability which will be delivered at the worst possible time of a product's life-cycle: when the company is dying.
* Data in plain text on my computer right now and always.
No aspersions cast on either company's people, intentions, goodwill, or the products' (Roam and Recall) quality and value. It's just that "I own my own life" is an organizing principle that I violate at my peril. My life is more important to me than your app.
As for the comment "ideas are cheap and execution is everything," I'm not sure how to connect that question to the success/failure of recall-app.com. The IF/THEN does not compute in my brain.
And yeah, the [[keyword]] thing is something I'd like to replicate in my knowledge base. It would make life easier for the users, and thereby increase the likelihood that they'll, y'know, actually use the knowledge base.
You should be proud of your accomplishment. Even I, an international tax lawyer with negligible programming exposure (i.e., decades ago), was able to successfully get Docusauras installed and operational on my MacBook. :-)
I am attempting something similar, and at the moment the tool I am using is https://docusaurus.io/ with the same set of problems to overcome. (Especially the photos problem).
I have considered using Obsidian Publish. My objective is to build an internal knowledge base: SOPs for a business. It won't be publicly visible. Obsidian Publish would require me to password protect the site, and that's an unacceptable addition of friction to day-to-day use.
Collaborative editing is the other problem to solve. In my world, "here's the repo on Github" draws blank stares. I have to use Google Docs or endless iterations of Word files.
Nobody will actually use an SOP in a Google Doc online, of course, and the trove of Word files on our server collects dust.
That's why a website (built using Docusaurus or similar) appears to be the best way to reduce friction and inertia. The path of least resistance should be the website full of SOPs, not "I remember how this works" or "I'll just re-invent the wheel."
I sympathize with your plight and I'm busily trudging along a parallel path.