Tag: FATCA

  • Offshore Succession Planning for American’s

    Issue: ”Sovereign Trust – new short form trust structures which present a cost effective succession planning tool with which to hold investments” Faults: Sovereign Trust – succession planning tool U.S. Tax System is Hostile to Offshore Trusts The U.S. tax system is generally hostile to foreign trusts if there is a U.S. taxpayer involved. The…

  • 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…

  • Offshore Investment Strategy of the Rich and Famous

    The offshore investment strategy used by the rich and famous (until recently), featured tax avoidance tactics based on trust law. Let’s take a closer look and analyse how these foreign trust examples take advantage of OSP. In this example, Hughes, Katz and the Durands form their trusts in order to safeguard income and property from…

  • A Foreign Account for Your IRA

    Setting up a foreign account without Unrelated Business Income Tax (UBIT) or distribution tax problem: Self-Directed IRA If you search around on the web, you will find that there are many companies offering Self-Directed IRAs. You will find little actionable information on government regulated, registered and recognized foreign pension funds, investment accounts or brokerage accounts.…

  • It’s True: Most Wealthy People Know How to Hide Money

    It is often said that most wealthy people know how to hide money, but the reality is it is impossible to hide money since the Foreign Account Tax Compliance Act (FATCA). Nowadays, the rich do not hide their assets. In the past they used special attorney driven instruments such as a funded and managed family…

  • FATCA Overseas Nightmares

    Lost in Space – The reason so many American Expats will suffer a 100% loss in their overseas Group Pension Scheme is because neither attorneys nor tax consultants are regulated, registered and recognized IRC 402(b) product providers. Therefore, 1) Group Attorneys can draw a legal blueprint of a IRC 402(b) Foreign regulated, FATCA registered and…

  • 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,…