Offshore Capital Structure White Paper

The Only Type of Foreign Financial Account that U.S. Persons can use for Deferral of Income and Carried Interest on Capital Overseas

This deferred income international retirement plan is formally recognized under the Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), Automatic Exchange of Information (AEoI) and specifically mentioned in Double Tax Agreements (DTA) and Intergovernmental Agreements (IGA); which means it checks all the tax and regulatory compliant boxes in the USA, OECD (including Canada, Mexico, the E.U.) and throughout Asia.

Additional Benefits:

• Deferring income on gains and accumulations reduces the cost of tax
• Deferring income can reduce social service cost of employees by 1/3 to 1/2
• Increase investment yield without an increase in risk
• Exclude investments from worldwide taxable assets
• Convert pre-tax profit into a tax deductible business expense
• A capital deductible and capital raising solution
• Tax free environment overseas
• No exposure to domestic or foreign country tax

We provide a turn-key facility for deferred income credential status globally; while you keep command and control of your own business.

Our Alliance constructs IRC 402(b) compliant deferred income retirement plans in a way that is optically good for U.S. Persons and U.S. Dollar transactions that is registered and recognized in the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) as an excluded from reporting and exempt beneficiary financial account.

This style 402(b) ”Exempt Beneficiary” plan is income deferred on gains and accumulation. It is a foreign government regulated, registered and recognized retirement plan that is also acknowledged in the Foreign Account Tax Compliance Act (FATCA) as an exempt from withholding and an exempt beneficiary account. The member does not file a W-9 because the administrator of the plan files a W-8BEN-E box 29e.

The automatic exchange of financial information is data collection to counter parties for the purpose of worldwide taxation. There are rules on data collection and there are no rules on data management.

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