Tag: IRC 402(b)
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Tax Treaty and Overseas Retirement
The purpose of a Tax Treaty is to define which of two countries has the rights of taxation. Upon retirement when there is a Tax Treaty with the USA then it is possible for the 3rd Country national to receive withdrawal from his IRC 401a or IRA without tax or a reduced tax from the…
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402(b) Foreign Financial Account
Governments around the world know more than ever before about the activities of Foreign Financial Account holders that maintain undisclosed accounts and the financial institutions where those accounts are maintained. [box type=”alert” size=”large” style=”rounded” border=”full”]Governments now have unprecedented access and insight into the hidden world relating to the maintenance of offshore accounts.[/box] Much like Foreign…
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Corporatize your Offshore Capital Structure
[box]AML & KYC are the first issues for consideration, when planning an Offshore Capital Structure.[/box] The best course of action to ring-fence liability, is this ORS/402(b) program. FATCA and the Automatic Exchange of Financial Information reporting rules are enforced now. The PRC has the same rules about foreign financial account reporting as does the USA.…
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Offshore Capital Structure White Paper
The Only Type of Foreign Financial Account that U.S. Persons can use for Deferral of Income and Carried Interest on Capital Overseas This deferred income international retirement plan is formally recognized under the Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), Automatic Exchange of Information (AEoI) and specifically mentioned in Double Tax Agreements…
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Charitable Remainder Trust Problems
Charitable Remainder Trust Overview: 1) Trust status cannot extend to beneficiaries and participants The point for all to grasp is that whatever the legal, juridical and tax status of funding structures, that status cannot extend to beneficiaries and participants as individuals. That is why a trust is quite useless to beneficiaries and participants. Besides it…
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IRC 402(b) Global and Mobile International Retirement Plan
IRC 402(b) Global and Mobile International Retirement Plan International enforcement of Tax Compliance by the U.S. Foreign Account Tax Compliance Act (FATCA) took effect on 1 July 2014 and for the OECD it begins in 2017. This reporting of foreign financial accounts dramatically effects the way employers establish, administer and financially report international retirement plans…