Tag Archives: FATCA

A Foreign Account for Your IRA

25 Mar
SpaceX's Falcon 9 rocket delivered the ABS 3A and EUTELSAT 115 West B satellites to a supersynchronous transfer orbit, launching from Space Launch Complex 40 at Cape Canaveral Air Force Station, Florida on Sunday, March 1, 2015 - IRA

Setting up a foreign account without Unrelated Business Income Tax (UBIT) or distribution tax problem: Self-Directed IRA If you search around on the web, you will find that there are many companies offering Self-Directed IRAs. You will find little actionable information on government regulated, registered and recognized foreign pension funds, investment accounts or brokerage accounts. […]

FATCA Overseas Nightmares

12 Mar
View of the Carina Nebula taken from the Astronomy Observatory of Los Molinos (OALM) (es) located in Montevideo, Uruguay. The picture is based on 9 frames of 2 minutes exposure time each with a Nikon Df and a catadioptric Nikkor 500mm f/8 lense, apart from the dark, bias and flat frames for the post-processing. For the post-processing a dedicated software for this kind of photography (PixInsight) was used that merges the images, analyses the brightness scale, reduces the noise and enables the management of saturation and dynamic range. - FATCA

Lost in Space – The reason so many American Expats will suffer a 100% loss in their overseas Group Pension Scheme is because neither attorneys nor tax consultants are regulated, registered and recognized IRC 402(b) product providers. Therefore, 1) Group Attorneys can draw a legal blueprint of a IRC 402(b) Foreign regulated, FATCA registered and […]

Global Online Commerce and FATCA

05 Mar
Photographs from Maldives - FATCA

The fact is that the U.S. tax code can provide tax deferral on an overseas trading businesses but not on an overseas firms dealing in capital. The Foreign Account Tax Compliance Act (FATCA) does not define the difference between trade and capital. Therefore, the big operations overseas, or the very small ones for that matter, […]

Invest from China into USA with an EB-5 Visa

23 Feb
China exit visa - EB-5 Visa

Pre-Immigration Statutory Asset Protection for EB-5 Visa This ORSO/IRC 402(b) entity is the only statutory asset protection and tax deferred income solution possible for residents of the People’s Republic of China because it is integrated pension laws that are recognized by the Peoples Republic of China, the Internal Revenue Service, the Department of the Treasury, […]

How to Invest Offshore Post FATCA

19 Feb
Contando Dinheiro - Invest Offshore

For years, people have invested offshore to protect their investment. This was money that the government could not tax and could not attach to you. Many considered it the safest way to store your money. Recently, however, things are changing. FATCA, Foreign Account Tax Compliance Act, makes it harder for people to invest in offshore […]

Offshore Investment into the United States

17 Feb
The Naval Temple at The Kymin Monmouth - Offshore Investment

Sophisticated tax structuring is generally involved in the Investment activities of foreign private and sovereign investors in U.S. private equity and real estate investments, that generate effectively connected income to a U.S. trade or business (ECI). The focus of this structuring generally accomplishes several important tax and non-tax objectives. Re-characterization of income otherwise it’s subject […]

The legal basis for a 402(b) Overseas Retirement Plan

16 Feb
USS Roper anchor on display at the Massachusetts Institute of Technology - Overseas Retirement Plan

A Nonqualified overseas retirement plan has characteristics that are opposite of what we have all been used to. This specific 402(b), the Regulated Asset Protection Structure (RAPS), allows for pre-tax contributions. There are no maximum contribution limits as this is a nonqualified deferred compensation tax law issue. The fact that this is precisely the opposite […]

Regulatory driven offshore asset protection

12 Feb
United States Seventh Fleet - offshore asset protection

All foreign investment capital needs to be looked at because of the expanded scope of the U.S. Treasury form FinCEN 114 (FBAR), the Foreign Account Tax Compliance Act (FATCA) and Intergovernmental Agreements (IGA). The rule that changed everything is the Foreign Account Tax Compliance Act (FATCA). Continuously there is the ever present report to the […]

Offshore Companies and FATCA

09 Feb
Sign of the Anchor near to Burwell, Cambridgeshire, Great Britain for offshore companies

Structuring Business Ownership of Offshore Companies with FATCA and GATCA Compliance There is a misunderstanding as to what type of businesses the U.S. provides tax deferral overseas. Is it a trading company or a company dealing in capital overseas? The fact is that the U.S. provides tax deferral on overseas trading businesses but not on […]