Category: ETF, Hedge & Mutual Funds
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Top Offshore Mutual Funds
Offshore mutual funds is a term which generally refers to a collective investment scheme domiciled in an offshore jurisdiction. The reference to offshore, in the classic case, usually means a traditional offshore jurisdiction such as the Cayman Islands, Jersey or the British Virgin Islands. However, the term is also frequently used to include other corporate…
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Offshore Investment into the United States
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…
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The legal basis for a 402(b) Overseas Retirement Plan
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…
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Regulatory driven offshore asset protection
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…
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Offshore Self Directed IRA
Set-up a Foreign Account for Your U.S. IRA without Unrelated Business Income Tax (UBIT) or (UBTI) distribution tax problems If you search around on the web, you will find that there are many companies offering Self-Directed IRAs. You will find little actionable information on government regulated, registered and recognized foreign pension funds, investment accounts or…
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Hong Kong Fund Management Growth Sets Record
The annual Hong Kong Fund Management Activities Survey (FMAS) released today by the Securities and Futures Commission (SFC) shows that the combined fund management business in Hong Kong hit another record high of $16,007 billion as of the end of 2013, representing year-on-year growth of 27.2%. The latest survey indicates that Hong Kong continued to be a…
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Cayman Funds and the Seven Deadly Myths of FATCA
It is quite a human trait to live in a state of suspended disbelief – when the news is just too bad to absorb, or when the consequences of an action are too much to contemplate. Response to the Foreign Account Tax Compliance Act (FATCA), it seems, is one of suspended disbelief by some in…