Global Capital. Clear Intelligence.
The whole thing to do with FATCA is starting to build a tidal wave of interest now that most people understand that 1 July is the drop dead date. [quote style=”boxed”]Would you like to guess as to what is treated as an exempt entity?[/quote] This is explicitly for pension funds as exempt beneficial owners and … Read more
This week it was announced that Hong Kong has agreed to hand over financial details of Americans working in the city, to US tax authorities under Foreign Account Tax Compliance Act, US can ask for data if certain conditions are met. The Financial Services and Treasury Bureau said the tax-information exchange agreement allowed the US … Read more
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 … Read more
There is no reason for your advisor to have ever heard of a regulated asset protection structure (RAPS). US advisors do not study this area of law and consequently do not advise on foreign retirement plan law. However, an IRC 402(b) Foreign Retirement Fund (RAPS) allows your assets to be held tax deferred for which … Read more
UNITED STATES IRC 402(b) LAW (1986) UNLEASHES TAX OFFSHORE The U.S. Tax system is generally hostile to foreign financial structures if there is a U.S. taxpayer or U.S. beneficiary involved. The hostility is understandable-foreign structures interfere with government ability to impose or collect tax. Avoiding international tax pitfalls can be best achieved, both foreign and … Read more
Legal challenges that US persons have to deal with, living overseas. The following legal challenges are extremely problematic for USA persons: No foreign bank will open an account for a US person or US person beneficiary.(Other than a bank of the overseas employer for their income overseas) No offshore brokerage will open an account for … Read more
Diego S., a wealthy Latin American media executive, travels frequently on business between his home city in South America and New York City. He usually prefers to take a flight with a Miami stopover rather than one of the two daily NYC bound non-stops. The Miami stop is not about visiting relatives or even shopping, … Read more
There is no U.S. law that disallows a U.S. person from investing into a Foreign Retirement Fund that has a Government Regulated Fiduciary, is a registered foreign retirement plan and where the jurisdiction accommodates persons that may not live in that jurisdiction. This is at the very core of the Regulator Asset Protection Structure (RAPS). … Read more
US anti-tax evasion legislation known as FATCA – the Foreign Account Tax Compliance Act – has caused upheaval among the American expat community and dual Swiss-US nationals living in Switzerland where it was agreed in February. “People are very angry and upset but some are really scared,” declared Jackie Bugnion, a director and tax specialist … Read more