Global Capital. Clear Intelligence.
Donald Trump’s Fiscal Tax Plan will increase the ultimate yield on your corporate projects and investments offshore. Trump’s plan scraps dividend tax and at the same time it scraps the foreign bank interest tax exemption. Which means, for example, bank lending overnight from the Cayman is redundant / irrelevant. ”Tax Havens” such as Cayman, Bermuda, … Read more
Beware of FATCA! It has recently come to our attention that some people have mistakenly been recommended to use an Escrow Account for privacy of overseas financial transactions. Criminal sanctions would apply to any U.S. Person use of an Escrow Account for the purpose of secrecy. Any U.S. Person participation, interest, legal right, beneficial ownership, … Read more
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 … Read more
IRC 402(b) Global and Mobile International Retirement Plan International enforcement of Tax Compliance by the U.S. Foreign Account Tax Compliance Act (FATCA) took effect on 1 July 2014 and for the OECD it begins in 2017. This reporting of foreign financial accounts dramatically effects the way employers establish, administer and financially report international retirement plans … Read more
Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial consequences for the 12 million undocumented immigrants that have not filed tax returns at the federal and state level. It is … Read more
The Only Type of Foreign Financial Account that U.S. Individuals can use for Gains and Accumulations of Capital Offshore. Construct legally a tax compliant IRC 402(b) retirement plan in a way that is optically good for U.S. Persons so they are relaxed, they are U.S. Tax and reporting compliant and the bulk of their contributions … Read more
It all started with 9/11. After the twin towers fell in 2001, the US government sprang into action to wage the global war on terrorism. Within days following the attack, Congress pushed through the USA PATRIOT Act, providing unprecedented authority to the US federal government. The legislation also gave several government agencies sweeping powers over … Read more
Structure Capital Offshore – The Only Tax Rules Compliant and Double Tax Agreements Non-Reporting and Excluded Account The pension regime is very important internationally and one thing the OECD organization has done amazingly well is Double Tax Agreements. They have come out with an amendment to the OECD model double tax agreement that introduces a … Read more
We provide clients with a private label trust platform that is consolidated international occupational retirement law and is government regulated, registered and recognized in over 130 countries. A Fairbrook Alliance Private Label Trust is not a tax haven, insurance product or company, or personal trust; it is a globally-recognized occupational retirement plan providing far greater … Read more