Tag: UBIT

  • Charitable Remainder Trust Problems

    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…

  • Your IBC problem

    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%…

  • Buy an Exemption from Foreign Financial Institution Regulatory Reporting

    January 1st, 2016, recognized foreign retirement plans will be bracketed with US retirement plans for the purpose of investments; which means our recommended Hong Kong ORS402(b) is for anyone, including US people to invest in US Real Estate completely free of tax, as an Exemption from Foreign Financial Institution Regulatory Reporting (FIRPA). [box type=”tick” style=”rounded”…

  • Why an IRA Registered Foreign Investment Account Works Wonders

    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…

  • 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.…

  • Move your IRA to an Offshore Investment Account

    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…

  • Offshore Self Directed IRA

    Set-up a Foreign Account for Your U.S. IRA without Unrelated Business Income Tax (UBIT) or (UBTI) distribution tax problems 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…

  • Offshore Investing with an IRA

    The most common question asked about an overseas retirement account and an IRA. Can I Invest in a Business with my IRA? Surprisingly, yes you can invest in an active business with your retirement account. There are a many caveats and limitations, but you can usually lend money to a business, purchase shares in a…