Tag: overseas retirement plan
-
Malta U.S. Pension Scheme Review
If we wrote a book about the Malta U.S. Pension Scheme it would be about 12 pages even if we covered everything imaginable in great detail…otherwise it would be a couple of paragraphs and not worthy of a white paper because it is NOT an occupational retirement plan it is a life time annuity with…
-
American’s Living Abroad and FATCA
An American’s Living Abroad, or an Expat as they’re commonly known, now faces radical changes in how they file annual income tax reports because of the new FATCA (foreign account tax compliance) regulations. Amongst the more common questions and concerns relates to owning offshore mutual funds (held but not sold). This brings us to the…
-
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…
-
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…
-
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…