Tag: 402(b)

  • Structuring Limited Partner Ownership Offshore

    This Hedge Fund Limited Partners Ownership is the Only Tax Deferred Income on Gains & Accumulations Entity Not Subject to Self-Employment Tax The effect of all these rulings in 2014 demolished common U.S. situs deferred compensation structures for members of a limited partnership (LLC/LLP) which is the reason that this solution is only found in…

  • Tax Deferred Foreign Financial Account

    In any payroll these days for U.S. people or not there is some form of tax equalization built into it. You find tax equalization is quite common. Basically your payroll is assumed to be tax equalized one way or the other and that is an expensive way to deal with this problem. Instead you can…

  • Export a UK Pension

    HMRC cannot restrict transfer of UK pension funds HMRC rules specifically states that you do not need to leave the U.K. to transfer your pension funds. Which means the HMRC cannot restrict transfer of pension funds. A transfer payment may be made either to the scheme administrator including persons responsible for administration of the QROPS,…

  • Winning the Money Game

    The Prevailing Principle to Win the Money Game The Power of Compounding Pre-Tax Contributions and Accumulations: For example, a 10% return over 30 years will produce 4 times the accumulation of a 5% return. With marginal income tax rates approaching or exceeding 50 percent, interest in tax deferral has spiked. Many are familiar with the…

  • Global Online Commerce and FATCA

    The fact is that the U.S. tax code can provide tax deferral on an overseas trading businesses but not on an overseas firms dealing in capital. The Foreign Account Tax Compliance Act (FATCA) does not define the difference between trade and capital. Therefore, the big operations overseas, or the very small ones for that matter,…

  • 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…

  • Offshore Companies and FATCA

    Structuring Business Ownership of Offshore Companies with FATCA and GATCA Compliance There is a misunderstanding as to what type of businesses the U.S. provides tax deferral overseas. Is it a trading company or a company dealing in capital overseas? The fact is that the U.S. provides tax deferral on overseas trading businesses but not on…