Category: Stocks and Bonds
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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…
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Wealth Preservation Europe Account
Dublin based Canada Life International Assurance has launched a new estate planning product – the Wealth Preservation Europe Account. The WPEA is based on Canada Life’s award winning Wealth Preservation Account (WPA), which was voted the Best Trust/Estate Planning Product in the International Adviser International Life Awards 2013. The WPEA and WPA both allow individuals…
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USA pension plan 401k vs. 402b
The 401(k) compared to the 402(b) Foreign Retirement Plan With a 401k your employer will match your contribution to their pension plan up to 15% to a maximum of a set value. If you want your money back you must pay a 10% penalty up to age 59.5 years and declare the entire sum as…