We can assist the most difficult USA Connected person with the Asset Protected and Tax Saving structures. This can also be accomplished for individuals of a number of different countries, taking into consideration their nationality and their country of residence. What is more exciting though, is what the structure can do, once the owner is ready to begin investing.
Allow us to introduce the most compelling reason for an offshore investment account – it’s the genesis of Offshore Fund Platforms, Discounted Fund Platforms, Offshore Fund Supermarket and Online Investment Platforms, we call them simply: “Offshore Investment Platforms”.
This best-of-breed Offshore Investment Platform provides portfolio management software designed to give an investor the maximum choice of global financial instruments and the maximum flexibility. It’s easy to set up, has competitive costs and is simple to run. The key to this offshore investment platform is that it allows an individual to invest for many purposes, in one plan, and provides online access to your portfolio with full confidentiality.
We put the 402(b) Regulator Asset Protection Structure, with an Offshore Investment Platform, through a hypothetical stress test, by presenting the concept to a leading U.S. tax attorney, and here’s a sample of what we learned.
Question: Since My LLC in your IRA LLC RAPS structure would be purchasing foreign mutual funds then why would those not be considered a PFIC which has a deemed distribution each year and is taxed annually at 36.9% and requires special IRS reporting?
Answer: Since the U.S. LLC owns 100% of a Foreign Entity-the investment account on the trading platform – the Owner of the U.S. LLC is an IRA, which is exempt from tax, no U.S. Tax is due on the deemed dividend (Internal Revenue Code Section 1248.
With respect to reporting, there is an *FBAR exception for IRA Accounts, however, since the Foreign Entity (Offshore Investment Platform) would be only indirectly owned by the IRA through the LLC we suggest that the client complete the *FBAR even though there is a filing exception for IRA Owners and Beneficiaries.
Note the IRS Form 8938 is only for U.S. Individuals so that would not be applicable.
**The FBAR Foreign Bank Account Report is filed with the Treasury Department (It is not filed with the IRS).
Let us to introduce you to the future of offshore investing on offshore investment platforms.