Tag Archives: IRS

Recognized Private and Secret Legal Framework

30 Jun
US Capitol dome Jan 2006 - privacy

Cross-Border ”rolls” for Qualified Plans with Legal Framework The purpose is to transfer assets of a USA qualified retirement plan to a non-US foreign investment account, recognized by the IRS, without a current tax consequence. IRS recognized Tax deferred gains and accumulations from outside the USA Asset Protection by Government and by Governance Exempt from […]

The Only Asset Protection that Governments Trust

27 Jun
Lindau Hafen Sonnenuntergang, Germany - Asset Protection

Asset Protection that Governments Trust The 401(k) problem is a U.S. Qualified Plan Trustee, upon his demand, would not transfer his money outside of the USA.because: The IRS has made a ruling in regards to Investing/sending money out of the country from qualified retirement plans. They have ruled against all such foreign transactions. We learned […]

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 […]

The Panamanian Second Passport Program

28 May
Panama city at night.

Panama has become a popular destination for many Americans and Canadians for retirement purposes. As the Switzerland of Latin American, it is also a popular destination for many South Americans particularly Venezuelans and Colombians. Historically, Panama has been and remains politically and economically stable. The currency is tied to the U.S. dollar. For purposes of […]

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 […]