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Aaron NQDC-vs-402(b) – aka RAPS An alternative to the US Tax Regulations that require NQDC plans (nonqualified deferred compensation plans) to be not formally funded ( The Total Return Swap Hedge requires 25 million annual contributions.) The Alternative to Unfunded, Unhedged, or informally funded NQDC Plans: We have a number of 402(b) Foreign Retirement Plan proposals … Read more
UNITED STATES IRC 402(b) LAW (1986) UNLEASHES TAX OFFSHORE The U.S. Tax system is generally hostile to foreign financial structures if there is a U.S. taxpayer or U.S. beneficiary involved. The hostility is understandable-foreign structures interfere with government ability to impose or collect tax. Avoiding international tax pitfalls can be best achieved, both foreign and … Read more
Legal challenges that US persons have to deal with, living overseas. The following legal challenges are extremely problematic for USA persons: No foreign bank will open an account for a US person or US person beneficiary.(Other than a bank of the overseas employer for their income overseas) No offshore brokerage will open an account for … Read more
Jersey holding companies, trusts and limited partnerships have been used by private individuals, family offices and institutional investors over many years for property investment. Jersey holding companies, trusts and limited partnerships have been used by private individuals, family offices and institutional investors over many years for property investment. The industry and structures involved in this … Read more
What are UCITS Funds? A growing number of investors are including hedge funds and other alternative strategies within their portfolios as a way of providing better portfolio diversification during adverse market conditions, as well as potentially boosting risk-adjusted returns over the long term. However, the recent financial crisis and a number of high profile fraud … Read more
The pace of oil and gas exploration is frightening, and discoveries are weekly, if not daily, with volumes investors would only have dreamt of a decade ago. With each new discovery, it becomes difficult to keep track of the playing field, and even more difficult to rank the potential. There are also a lot of … Read more
There are many benefits and advantages of trading Forex. Here are just a few general reasons why more and more people are choosing this market. No middlemen Spot currency trading eliminates the middlemen and allows you to trade directly with the market responsible for the pricing on a particular currency pair. At FinFX all trading … Read more
In a recent talk, Charmian Gooch of Global Witness stated that a recent study of 200 cases of corruption had shown that “70%… had used anonymous shell companies” and referred, a little disparagingly to “that nebulous phrase ‘weak governance’…”. Unlike a lot of other commentators, however, she also mentioned that they all use the international … Read more
Diego S., a wealthy Latin American media executive, travels frequently on business between his home city in South America and New York City. He usually prefers to take a flight with a Miami stopover rather than one of the two daily NYC bound non-stops. The Miami stop is not about visiting relatives or even shopping, … Read more