Tag Archives: IRS

Double Down! – Inter-Generational Split Dollar Throws Sand in the Face of the IRS Again

14 Aug
friends toasting the IRS with champagne flute on beach at sunset

Recently I wrote an article on JD Supra called Split to Be Tied (May 4, 2016) regarding the Tax Court decision in Estate of Morrissette, (Estate of Clara M. Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016)). Once again, the IRS has lost a significant inter-generational split dollar case – Estate of Marion Levine, Deceased v. […]

My “Flippín” House?

23 Jun
House flppers

Tax Strategies to Reduce Taxation and Build Wealth for House Flippers I seem to be perpetually out to lunch. When I step on the scale too, this point is further confirmed. I do not know why I have waited so long to write an article for the benefit of real estate investors who “flip” houses. […]

Malta U.S. Pension Scheme Review

15 Jun
Malta U.S. Pension Scheme

If we wrote a book about the Malta U.S. Pension Scheme it would be about 12 pages even if we covered everything imaginable in great detail…otherwise it would be a couple of paragraphs and not worthy of a white paper because it is NOT an occupational retirement plan it is a life time annuity with […]

Private Label Trust

13 Jun
Private Label Trust

We provide clients with a private label trust platform that is consolidated international occupational retirement law and is government regulated, registered and recognized in over 130 countries. A Fairbrook Alliance Private Label Trust is not a tax haven, insurance product or company, or personal trust; it is a globally-recognized occupational retirement plan providing far greater […]

The Trend in Chinese Offshore Investment

18 Apr
Chinese offshore investment

The trend in Chinese offshore investment in the U.S. has been increasing each year. In 2012 the level of investment was $6.5 billion. Much of this investment is in U.S. real estate where great buying opportunities still exist. The registered foreign retirement plan is an ideal asset protection vehicle for Chinese investors that make investments that […]

IRC 402b Foreign Retirement Plans

11 Apr
402b

There are 4 sections of IRS code that need to be considered in regards to non-qualified deferred compensation plans and a U.S. tax lawyer who is without prior research on IRC 402b foreign retirement plans will bill between $125,000.00 and $200,000.00 prior to doing research on foreign country pension laws. The reason that specialist Tax […]

Personal Pension and Foreign Investment Account

23 Mar
Personal pension from old glory

Trade risk for security offshore – Overseas Personal Pension The simple solution is to centralize your investment into a U.S. IRS fully compliant tax free trading environment. This can be accomplished by using a US – onshore regulated Trustee and using a self Directed Individual Retirement Account (IRA) Foreign Investment Account. You can easily rollover […]

Offshore Investment Truth & Myths

19 Mar
Snapshot on Lake - offshore investment myth buster

Offshore Investment Truth Offshore investments have access to the widest possible variety of investment instruments and may often pursue more aggressive investment strategies than if they were registered in a “traditional” jurisdiction.  (These Funds out-perform U.S. Funds in Asia and South America). It is also quite common for an offshore investment vehicle to outsource some or […]

US Government wants retirement savings in US Bonds

16 Feb
The U.S. government just passed $19 trillion in debt

Why the US Government wants retirement savings in US Bonds According to financial research firm ICI, total retirement assets in the USA now exceed $23 trillion. $7.3 trillion of that is held in Individual Retirement Accounts (IRAs). Unfunded Social Security entitlements the government estimate is another $42 trillion. The US national debt has increased by […]

Your IBC problem

13 Feb
United States of America bald eagle - IBC problem

Your International Business Company (IBC problem) needs immediate attention from a U.S. Tax Attorney or experienced IRS Enrolled Agent. There is NO deferral of income in your current structure. Here is your IBC problem: 1) Your BVI, Seychelles or Anguilla IBC (an IBC from any foreign jurisdiction) is a Passive Foreign Investment Company (PFIC) 100% […]

Renouncing U.S. Citizenship eBook

20 Jan
U.S Citizenship

DETROIT, MI (PRWEB) JANUARY 19, 2016 – Freeman Tax Law, a tax law firm specializing in overseas financial issues and IRS representation, recently published an eBook for people who are interested in renouncing their U.S. citizenship. It includes important information regarding expatriation, including what the obligations are when trying to renounce a U.S. citizenship, the […]