Tag Archives: IRS

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 […]

Hong Kong TIEA is Good for U.S. Expats

27 Mar
Hong Kong signs TIEA with USA helps American Expats

This week it was announced that Hong Kong has agreed to hand over financial details of Americans working in the city, to US tax authorities under Foreign Account Tax Compliance Act, US can ask for data if certain conditions are met. The Financial Services and Treasury Bureau said the tax-information exchange agreement allowed the US […]

Regulated, Registered, Recognized Foreign Retirement Plan

21 Aug
Internal Revenue and Commerce Building, Washington DC - 402(b) Foreign Retirement Plan

NQDC-vs-402(b) – aka RAPS An alternative to the US Tax Regulations that require NQDC plans (nonqualified deferred compensation plans) to be not formally funded ( The Total Return Swap Hedge requires 25 million annual contributions.) The Alternative to Unfunded, Unhedged, or informally funded NQDC Plans: We have a number of 402(b) Foreign Retirement Plan proposals […]

Top 5 Reasons for you to consider the Regulator Asset Protection Structure

02 Mar

1. We suspect that a typical US provider would be proposing a life or annuity structure product and those are regulated individually by each state in the United States, have no Federal registration and are not always recognized by any foreign government. A typical U.K. provider would propose a UK life policy savings plan, but […]