Restructuring four S Corps Into QSubs?

I presume you mean "controlled foreign corporation" regulations. Many different countries have their own CFC regulations including Australia, the USA, etc. These laws essentially create a situation where the company needs to abide by the rules of multiple jurisdictions, and not just the one of incorporation. These regulations often stipulate that the "offshore" corporation may be taxed under certain situations (for Americans, an example of this would be Subpart F income) I.e. If an American sets up a company in Great Britain (or China, or Uzbekistan) and owns 100% of the shares, this would be classified by the IRS as a CFC. For Americans CFC regulations come into play when over 50% interest in a foreign corporation is owned by American taxpayers. If, however, you have over 10% interest in a foreign corporation, you should get proper tax advise and file form 5471 - Information Return of U.S. Persons With Respect to Certain Foreign Corporations. Other forms Americans may need to file include TDF 90-22.1 and form 8938. This above answer is a very broad overview, based on my own research and experience owning CFC's, it is not tax advise, and should not be used to avoid taxes.

There is no harm in having several businesses BUT it is wisdom to focus your full energy on the best business out of your lot. Let that focused business give you all the income you need on ongoing basis. Then you need to develop systems so that business doesn't need your full time attention. And then only focus on the next one and so on. Till then just see that other businesses are just maintained.

Hi, I'm not in Oregon so you'll need to speak to a local tax expert to verify the details but here is how it works: When you issue points you're creating a liability. You owe something to someone. It's like a gym which sells a one-year membership, they're only supposed to recognize 1/12 of the sale in the month it was sold. 11/12 of the money actually is a liability called 'deferred revenue.' As each month goes by, they reduce their liability by 1/12 and credit that money to income because now it is 'earned.' In your case you sell points to merchants (who give them to consumers) but most of the money collected is now owed to consumers to redeem their points. This is not income, you're just holding money owed to someone else. A small portion of the money, your gross margin on points sales, would be recognized as revenue and would have to cover your overheads and give you your profit, if any. So your balance sheet will keep growing in cash and an offsetting liability. Your income statement will only recognize the small margin which is your profit from selling the points to the merchants. I hope this helps make it more clear. With this type of business you may wish to investigate whether it makes sense from a liability point of view to hold the funds owed to consumers in a trust account rather than just 'floating' the points. I could see problems arising if you ever dipped into this cash pool to cover your own expenses while trying to argue to tax authorities that you're holding the cash for someone else. If you'd like to learn more about how merchants account for their own proprietary point systems, just book a call with me. I worked in the loyalty field for a few years. Cheers Dave

Yo are talking apples and oranges. Capital gains are related to your basis not the form of payment. If you are a cash basis taxpayer, you pay taxes when you receive cash beyond your basis. We can help you with structure.

I'm assuming you're talking about yourself, working for another company? The first thing to consider is that a "1099" is NOT an employee, rather an "independent contractor". The IRS takes it seriously when a company claims 1099 contractors, when in fact, these contractors are treated as employees (the IRS wants payroll tax and will fine companies that miscategorize). To be a 1099 contractor, rather than an employee (W-2), you must have complete control over your schedule - when you work, how much ect. There are other criteria, but this is the main one - you must clearly not be treated the same as an employee. The other thing to consider is that if you are a 1099 contractor, you are responsible for paying and submitting your own income tax and self employment tax to the state and the IRS. It is more advantageous for a company to pay you as a 1099 contractor as they save paying employer portion of payroll taxes. Also you will not count as an employee for the Affordable Care Act (which impacts companies with over 50 employees). Hope this helps. Kathryn