Author: Aaron
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Seraph Summit to Present the Panama Papers Antidote
IRS Compliant “On the Grid” Offshore Asset Protection Structures Presented at the Seraph Summit The massive leak of documents from a secretive Panamanian law firm… it’s the world’s fourth biggest offshore law firm, Mossack Fonseca, contain details of various world leaders’ offshore companies – over 70 current and former world leaders in fact! This includes…
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Planning on Hiding Behind Banking Secrecy?
Things have changed that make citizens of the People’s Republic of China (PRC), and all “high net worth individuals” (HNWI) a target now. Hiding assets PRC style (off the grid) and pretending someone else called ”Aunty”, a business, trust or nominee account owns them puts you at criminal risk needlessly. ORSO402(b) legal non-disclosure programming has…
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Canada Pension Plan to Invest Offshore
Canada Pension Plan Investment Board Invests EUR480 Million in the Mandatory Exchangeable Facility of LeasePlan TORONTO, ONTARIO–(Marketwired – March 30, 2016) – Canada Pension Plan Investment Board (CPPIB) announced today that its wholly owned subsidiary, CPPIB Credit Investments Inc., has completed the funding of EUR480 million in the Mandatory Exchangeable Facility of LeasePlan. This investment…
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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…
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The $2 Billion Market For Passports
As migration and inequality continue to get significant attention from US presidential candidates, it is worth noting a rising phenomenon at the intersection of these two topics: economic citizenship. A growing number of countries offer individuals passports in return for investment, and the wealthy have been taking advantage in increasing numbers. In 2014, the global rich spent…
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Invest Offshore in Brazil
I’m often asked about the process of opening a business or buying property in Brazil, after-all I’ve been living here a dozen years. I think the banking systems work well and for the most part it’s simple. My best advice for anyone planning on doing business here in Brazil, is to have a good attorney…
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The Defense of Canadian Sovereignty
Canadian Sovereignty at risk, particularly for those considered to be American persons for taxation purposes An organization called the Alliance for The Defense of Canadian Sovereignty is challenging a Canadian law that implements FATCA. The organization claims that the Canadian law violates the Canadian Charter of Rights & Freedoms, particularly the provisions related to discrimination on…