Global Capital. Clear Intelligence.
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
Individuals wanting to invest internationally or wishing to have U.S. dollar exposure must take heed of both FATCA and the AIFMD. For example, if a U.S. fund manager is approached by a potential investor from the EU, the question which must be asked is whether or not the fund will be in breach of EU … Read more
Whether you are from China or the USA there are TWO important questions in regards to how one deals with money and offshore investment: on the individual tax compliant level and at the institutional reporting level Whether it is the client himself or the foreign financial institution (FFI) they really have no idea about what … Read more
Our specific pension plan does not require a FATCA GIIN because of its “limited conditional” FATCA status. In fact, for an authorized pension fund to apply for a GIIN would be a criminal violation of the laws on Restricted Information (Secrecy Law) Limited Conditional IRS Form 8957 Foreign Account Tax Compliance Act Registration The correct … Read more
In today’s world of investing and financial markets, HFT, or high-frequency trading, has become one of the most widely discussed buzzwords, due primarily to active debate concerning whether this automated trading system strengthens investors’ positions or destabilizes the marketplace as a whole. On a basic level, high-frequency trading can be defined as a system in … Read more
New study puts a cost on “round-tripping,” a method investors use to avoid the tax collector. by Peter Dizikes | MIT News Office Tax evasion is widely assumed to be an eternal problem for governments — but how widespread is it? For the first time, a new study, co-authored by an MIT professor, has put … Read more
Dublin based Canada Life International Assurance has launched a new estate planning product – the Wealth Preservation Europe Account. The WPEA is based on Canada Life’s award winning Wealth Preservation Account (WPA), which was voted the Best Trust/Estate Planning Product in the International Adviser International Life Awards 2013. The WPEA and WPA both allow individuals … Read more
The 401(k) compared to the 402(b) Foreign Retirement Plan With a 401k your employer will match your contribution to their pension plan up to 15% to a maximum of a set value. If you want your money back you must pay a 10% penalty up to age 59.5 years and declare the entire sum as … Read more