Tag: tax deferred

  • Pooled Income Funds for the Repatriation of Offshore Carried Interest

    Looking Over the Edge of the Cliff – The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest Overview The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge…

  • Offshore Investment Truth & Myths

    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). [box type=”tick” size=”large” style=”rounded” border=”full”]A series of offshore investment funds, designed under the same…

  • The Solo and Global Tax Deferred 401(k) Retirement Plan

    For U.S. persons ONLY these two types of Foreign Financial Accounts provide Tax Effected Yield on Income and Accumulations which are formally recognized by FATCA and by IRS tax code to purchase investments globally from a tax free environment exempt from Foreign Financial Institution reporting and exempt from passive foreign income reporting. If you are…

  • Tax Deferred Foreign Financial Account

    In any payroll these days for U.S. people or not there is some form of tax equalization built into it. You find tax equalization is quite common. Basically your payroll is assumed to be tax equalized one way or the other and that is an expensive way to deal with this problem. Instead you can…