Category: Stocks and Bonds
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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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Foreign Account Tax Compliance Act Registration
Our specific pension plan does not require a FATCA GIIN because of its “limited conditional” FATCA status. In fact, for an authorized pension fund to apply for a GIIN would be a criminal violation of the laws on Restricted Information (Secrecy Law) Limited Conditional IRS Form 8957 Foreign Account Tax Compliance Act Registration The correct…
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How widespread is tax evasion?
New study puts a cost on “round-tripping,” a method investors use to avoid the tax collector. by Peter Dizikes | MIT News Office Tax evasion is widely assumed to be an eternal problem for governments — but how widespread is it? For the first time, a new study, co-authored by an MIT professor, has put…