Tag: IRS

  • 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…

  • Recognized Private and Secret Legal Framework

    Cross-Border ”rolls” for Qualified Plans with Legal Framework The purpose is to transfer assets of a USA qualified retirement plan to a non-US foreign investment account, recognized by the IRS, without a current tax consequence. IRS recognized Tax deferred gains and accumulations from outside the USA Asset Protection by Government and by Governance Exempt from…

  • The Only Asset Protection that Governments Trust

    Asset Protection that Governments Trust The 401(k) problem is a U.S. Qualified Plan Trustee, upon his demand, would not transfer his money outside of the USA.because: The IRS has made a ruling in regards to Investing/sending money out of the country from qualified retirement plans. They have ruled against all such foreign transactions. We learned…

  • 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…

  • Tax Deferred Foreign Financial Account

    In any payroll these days for U.S. people or not there is some form of tax equalization built into it. You find tax equalization is quite common. Basically your payroll is assumed to be tax equalized one way or the other and that is an expensive way to deal with this problem. Instead you can…

  • The Panamanian Second Passport Program

    Panama has become a popular destination for many Americans and Canadians for retirement purposes. As the Switzerland of Latin American, it is also a popular destination for many South Americans particularly Venezuelans and Colombians. Historically, Panama has been and remains politically and economically stable. The currency is tied to the U.S. dollar. For purposes of…

  • 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…