Global Capital. Clear Intelligence.
The New Dawn is Government Enforced Disclosure Globally for Money Managers: Monetary disclosure means that multinational employers who used a Trust structure labeled as a Retirement Plan are now recognized by the IRS as non compliant and their U.S. employees are subject to back taxes, late filing fees and tax penalties. Old methods of offshore … Read more
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 … Read more
[typography font=”Cantarell” size=”11″ size_format=”px”]by Simon Black[/typography] July 1, Singapore – Yesterday over coffee, a friend of mine leaked the news that JP Morgan’s private banking division here in Singapore is going to start charging negative interest rates. I almost fell out of my chair. He’s a successful hedge fund manager and one of their best customers. … Read more
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 … Read more
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 … Read more
O.E.C.D. Income Tax Deferred Overseas Retirement Plan. Internationally there are occupational retirement plans. The International Organization of Pension Supervisors (IOPS) covers this whole area, and also if you look at the E.U. Directive itself the whole idea behind these laws and legal concepts is primarily to do with people’s work. It is in regards to … Read more
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. … Read more
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 … Read more