Tag: IRS
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Held Captive! The Closely Held Insurance Company
Captive Insurance – An Integrated Tax and Risk Management Solution [typography font=”Open Sans” size=”11″ size_format=”px”]by Gerald Nowotny[/typography] Captive or closely held insurance companies have been around a long time, at least fifty or more years. For most of their existence, captive insurance companies lived in relative anonymity and were mostly in the domain of public…
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Asset protection and tax deferred solutions (offshore) for U.S. Persons
Many US citizens know that it is extremely difficult to hold assets outside of the US solely for asset protection and tax deferral. Some perceived to be authorities say you can invest ” anywhere you want” but that’s just not true. The fact is that there is tax deferred solution that when used the Internal…
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Hong Kong TIEA is Good for U.S. Expats
This week it was announced that Hong Kong has agreed to hand over financial details of Americans working in the city, to US tax authorities under Foreign Account Tax Compliance Act, US can ask for data if certain conditions are met. The Financial Services and Treasury Bureau said the tax-information exchange agreement allowed the US…
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Regulated, Registered, Recognized Foreign Retirement Plan
NQDC-vs-402(b) – aka RAPS An alternative to the US Tax Regulations that require NQDC plans (nonqualified deferred compensation plans) to be not formally funded ( The Total Return Swap Hedge requires 25 million annual contributions.) The Alternative to Unfunded, Unhedged, or informally funded NQDC Plans: We have a number of 402(b) Foreign Retirement Plan proposals…
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The FATCA Dirty Dozen
Legal challenges that US persons have to deal with, living overseas. The following legal challenges are extremely problematic for USA persons: No foreign bank will open an account for a US person or US person beneficiary.(Other than a bank of the overseas employer for their income overseas) No offshore brokerage will open an account for…
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Offshore Investing Strategy for Americans
There is no U.S. law that disallows a U.S. person from investing into a Foreign Retirement Fund that has a Government Regulated Fiduciary, is a registered foreign retirement plan and where the jurisdiction accommodates persons that may not live in that jurisdiction. This is at the very core of the Regulator Asset Protection Structure (RAPS).…
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Top 5 Reasons for you to consider the Regulator Asset Protection Structure
1. We suspect that a typical US provider would be proposing a life or annuity structure product and those are regulated individually by each state in the United States, have no Federal registration and are not always recognized by any foreign government. A typical U.K. provider would propose a UK life policy savings plan, but…
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What is FATCA?
FATCA, or the Foreign Account Tax Compliance Act was passed as part of the HIRE act of 2010. Designed to take United States tax compliance beyond the borders of the United States and into foreign territories to prevent the loss of potential billions of dollars in tax revenue, FATCA tightens compliancy standards and increases transparency…