Tag Archives: IRS

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. […]

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, […]

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 […]

Brought to you by FATCA

02 Feb
Thyssen-Krupp-Quartier-Essen-FATCA

Recapturing Pre-Tax Contributions and Tax Deferred Accumulations in a 402(b) Regulated Asset Protection Structure Contributions to this Internal Revenue Service (IRS) acknowledged and FATCA registered foreign company retirement plan are for persons working inside or outside the USA. Assets held within this specific IRC 402(b) are recognized globally as not included in worldwide taxable assets […]

Held Captive! The Closely Held Insurance Company

11 Jul
Sessions House, Hamilton Bermuda

Captive Insurance – An Integrated Tax and Risk Management Solution Captive or closely held insurance companies have been around a long time, at least fifty or more years. For most of their existence, captive insurance companies lived in relative anonymity and were mostly in the domain of public companies. Businesses or industries with significant warranty […]