Tag Archives: FATCA

Offshore Succession Planning for American’s

08 Jul
Munich subway station Candidplatz - Offshore Investment

Issue: ”Sovereign Trust – new short form trust structures which present a cost effective succession planning tool with which to hold investments” Faults: Sovereign Trust – succession planning tool U.S. Tax System is Hostile to Offshore Trusts The U.S. tax system is generally hostile to foreign trusts if there is a U.S. taxpayer involved. The […]

Structuring Limited Partner Ownership Offshore

22 Jun
The coat of arms of Brittany, over the gates of the fortified city of Saint-Malo. One can read the latin motto of the country, Potius mori quam foedari (Rather death than stain). - Limited Partnership

This Hedge Fund Limited Partners Ownership is the Only Tax Deferred Income on Gains & Accumulations Entity Not Subject to Self-Employment Tax The effect of all these rulings in 2014 demolished common U.S. situs deferred compensation structures for members of a limited partnership (LLC/LLP) which is the reason that this solution is only found in […]

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, […]