Tag: FATCA
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How to Invest Offshore Post FATCA
For years, people have invested offshore to protect their investment. This was money that the government could not tax and could not attach to you. Many considered it the safest way to store your money. Recently, however, things are changing. FATCA, Foreign Account Tax Compliance Act, makes it harder for people to invest in offshore…
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Offshore Investment into the United States
Sophisticated tax structuring is generally involved in the Investment activities of foreign private and sovereign investors in U.S. private equity and real estate investments, that generate effectively connected income to a U.S. trade or business (ECI). The focus of this structuring generally accomplishes several important tax and non-tax objectives. Re-characterization of income otherwise it’s subject…
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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…
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Regulatory driven offshore asset protection
All foreign investment capital needs to be looked at because of the expanded scope of the U.S. Treasury form FinCEN 114 (FBAR), the Foreign Account Tax Compliance Act (FATCA) and Intergovernmental Agreements (IGA). The rule that changed everything is the Foreign Account Tax Compliance Act (FATCA). Continuously there is the ever present report to the…
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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…
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Invest Offshore in Collectibles and avoid FATCA
Two days ago the colourful painting of two Tahitian women by Paul Gauguin was sold by a Swiss family foundation to a group of state museums in Qatar for nearly $300 million, a record sum for a single work of art. The price would best the roughly $250 million that Qatar paid three years ago…
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Brought to you by FATCA
Recapturing Pre-Tax Contributions and Tax Deferred Accumulations in a 402(b) Regulated Asset Protection Structure Contributions to this Internal Revenue Service (IRS) acknowledged and FATCA registered foreign company retirement plan are for persons working inside or outside the USA. Assets held within this specific IRC 402(b) are recognized globally as not included in worldwide taxable assets…