Global Capital. Clear Intelligence.
Aaron Sophisticated tax structuring is generally involved in the Investment activities of foreign private and sovereign investors in U.S. private equity and real estate investments, that generate effectively connected income to a U.S. trade or business (ECI). The focus of this structuring generally accomplishes several important tax and non-tax objectives. Re-characterization of income otherwise it’s subject … Read more
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 … Read more
Many of the world’s most secretive tax havens, ranging from Anguilla to Uruguay, are set to open their books to foreign tax by 2017. A year later, dozens more, including Belize, Hong Kong and Singapore, are set to follow suit. Among them is Switzerland, abandoning a tradition of secrecy that dates back at least as … Read more
Most foreign pension plans are likely characterized as trusts for U.S. tax purposes. Neither the statute nor the regulations define the term “employees’ trust.” However, if a foreign pension (i.e., the trust): (i) was created by a foreign employer, (ii) is administered by the foreign employer, and (iii) is more than half funded by the … Read more
The master developer of Escudo de Veraguas (to be referred to as “the project”) will be by HES International, S.A., IPPCorporation and the Ngobe (Ngabe)-Bugle´Indian Tribe. Escudo de Veraguas is an island off the east coast of Panama in Bocas del Toro Province. HES International owns 100% of the land and holds the master concession … Read more
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 … Read more
LONDON, England — A Labour government would push for UK overseas territories to be put on an international blacklist if they refuse to co-operate with a drive against tax avoidance, Labour Party leader Ed Miliband has told them ahead of general elections in Britain in May. In a letter to the leaders of British Overseas … Read more
In response to the single most common question we’re asked at Invest Offshore: I would like to take funds out of the country, going through the regular channels and obtaining tax clearance, to invest with an offshore bank or banks via platforms for investing in overseas markets. What options do I have as an investor … Read more
Structuring Business Ownership of Offshore Companies with FATCA and GATCA Compliance There is a misunderstanding as to what type of businesses the U.S. provides tax deferral overseas. Is it a trading company or a company dealing in capital overseas? The fact is that the U.S. provides tax deferral on overseas trading businesses but not on … Read more