Invest Offshore

Tag: PFIC

  • Charitable Remainder Trust Problems

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    Aaron
    in

    Charitable Remainder Trust Overview: 1) Trust status cannot extend to beneficiaries and participants The point for all to grasp is that whatever the legal, juridical and tax status of funding structures, that status cannot extend to beneficiaries and participants as individuals. That is why a trust is quite useless to beneficiaries and participants. Besides it…

  • How to avoid a scary PFIC Nightmare

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    Aaron
    in

    A mutual fund that is invested in European stocks, but incorporated in the US may be taxed at a long term capital gains rate of 15%, but if the US taxpayer buys an identical fund listed outside the US, they will find their investment may be taxed at up to 50% The first de minimis…

  • Corporate Legal Framework to Invest Overseas

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    Aaron
    in

    Foreign Retirement Plan Corporate Legal Framework This Foreign retirement plan corporate legal framework is the only solution to the IRS rulings in 2014 that demolish U.S. situs deferred compensation structures of working members of limited partnership (LLC/LLP) and the IRS Chief Counsel advises members may be subject to self-employment tax. [box style=”rounded” border=”full”]Under the new…

  • Your IBC problem

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    Aaron
    in

    Your International Business Company (IBC problem) needs immediate attention from a U.S. Tax Attorney or experienced IRS Enrolled Agent. There is NO deferral of income in your current structure. Here is your IBC problem: 1) Your BVI, Seychelles or Anguilla IBC (an IBC from any foreign jurisdiction) is a Passive Foreign Investment Company (PFIC) 100%…

  • Capital Controls Are Here Again

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    Aaron
    in

    I believe the U.S. dollar will lose its role as the world’s premier reserve currency. When that happens, capital controls will have an effect on you. This is why it’s crucial to your financial future to understand what capital controls are, how they are used, and what you can do to protect yourself. Why Governments Impose…

  • Why an IRA Registered Foreign Investment Account Works Wonders

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    Aaron
    in

    Asset Protection Strategy: You centralize your investing in a tax free environment by means of an IRA registered foreign investment account is the important news for you here. Regardless of whether it is for your current holdings only or for your future investments only; if it is emigrating investments out or immigrating investments in, it…

  • Offshore Succession Planning for American’s

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    Aaron
    in

    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…

  • Move your IRA to an Offshore Investment Account

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    Aaron
    in

    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…

  • The legal basis for a 402(b) Overseas Retirement Plan

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    by

    Aaron
    in ,

    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…