Global Capital. Clear Intelligence.
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, … Read more
Transfer your USA IRA to a Registered Foreign Account The purpose is to transfer assets of a USA qualified retirement plan to a non-U.S. investment account, recognized by the IRS and FATCA, without a change to current tax consequence (Ordinary IRA or Roth IRA). This delivers to a U.S. person: Tax-free transfer of his retirement … Read more
Pre-Immigration Statutory Asset Protection for EB-5 Visa This ORSO/IRC 402(b) entity is the only statutory asset protection and tax deferred income solution possible for residents of the People’s Republic of China because it is integrated pension laws that are recognized by the Peoples Republic of China, the Internal Revenue Service, the Department of the Treasury, … Read more
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 … Read more
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 … Read more
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 … Read more
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 … Read more
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 … Read more
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 … Read more