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 […]
A mutual fund that is invested in European stocks, but incorporated in the US may be taxed at a long term capital gains rate of 15%, but if the US taxpayer buys an identical fund listed outside the US, they will find their investment may be taxed at up to 50% The first de minimis […]
Foreign Retirement Plan Corporate Legal Framework This Foreign retirement plan corporate legal framework is the only solution to the IRS rulings in 2014 that demolish U.S. situs deferred compensation structures of working members of limited partnership (LLC/LLP) and the IRS Chief Counsel advises members may be subject to self-employment tax. This Foreign Financial Account is […]
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% […]
I believe the U.S. dollar will lose its role as the world’s premier reserve currency. When that happens, capital controls will have an effect on you. This is why it’s crucial to your financial future to understand what capital controls are, how they are used, and what you can do to protect yourself. Why Governments Impose […]
Asset Protection Strategy: You centralize your investing in a tax free environment by means of an IRA registered foreign investment account is the important news for you here. Regardless of whether it is for your current holdings only or for your future investments only; if it is emigrating investments out or immigrating investments in, it […]
Issue: ”Sovereign Trust – new short form trust structures which present a cost effective succession planning tool with which to hold investments” Faults: Sovereign Trust – succession planning tool U.S. Tax System is Hostile to Offshore Trusts The U.S. tax system is generally hostile to foreign trusts if there is a U.S. taxpayer involved. The […]
Transfer your USA IRA to a Registered Foreign Account The purpose is to transfer assets of a USA qualified retirement plan to a non-U.S. investment account, recognized by the IRS and FATCA, without a change to current tax consequence (Ordinary IRA or Roth IRA). This delivers to a U.S. person: Tax-free transfer of his retirement […]
A Nonqualified overseas retirement plan has characteristics that are opposite of what we have all been used to. This specific 402(b), the Regulated Asset Protection Structure (RAPS), allows for pre-tax contributions. There are no maximum contribution limits as this is a nonqualified deferred compensation tax law issue. The fact that this is precisely the opposite […]
All foreign investment capital needs to be looked at because of the expanded scope of the U.S. Treasury form FinCEN 114 (FBAR), the Foreign Account Tax Compliance Act (FATCA) and Intergovernmental Agreements (IGA). The rule that changed everything is the Foreign Account Tax Compliance Act (FATCA). Continuously there is the ever present report to the […]
Two days ago the colourful painting of two Tahitian women by Paul Gauguin was sold by a Swiss family foundation to a group of state museums in Qatar for nearly $300 million, a record sum for a single work of art. The price would best the roughly $250 million that Qatar paid three years ago […]
For U.S. persons it is absolutely correct that you should engage in diversification of investments and assets overseas. However, the difficulty with much of the information received from a blog or Google search, no matter how attractive it might seem, is completely out of date. All the points sound great if you say them quickly. […]