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Offshore Banking and Asset Protection, Offshore Trading
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Offshore Banking and Asset Protection, Offshore Trading

  #41 (permalink)
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On a similar note (restructure, off-shore, etc), see this thread:

https://futures.io/traders-hideout/34346-checkbook-iras.html

I believe it is a completely separate topic so created a separate thread for it.

Mike

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  #42 (permalink)
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Big Mike View Post
Regardless of why, I told that attorney that I didn't get to where I was today by not pursuing a good value. Sure, I need expert advice, but I also need to pay a fair fee for that advice. And that wasn't $80k. Keep in mind this attorney was going to have me fill out a 50 page questionnaire detailing all assets, then they would just pick a structure they've picked a hundred times before for other clients, and populate some names on a PDF form. Then call me a dozen times for no more than 30 minutes per call. That is not good value in my eyes.

My best guess is a fair cost is more in the neighborhood of $15k. And I am including post-creation support and hand holding in that figure. I'll find out soon if I am right or wrong.

Mike

Yeah, $80k is way out of the ballpark. A 1-2 person internet company with no tangible products looking for an offshore jurisdiction is standard fare for them and shouldn't require specialized CPA advice; the tax attorneys at the firm should be able to handle it.

I'd say that $10k each ($30k total) for an upper tier onshore law firm, CPA firm and offshore law firm (Walkers, Maples, Ogier) would be the maximum I would pay for this. You could probably eliminate the CPA firm as I mentioned, making this $20k max. Your mileage will vary.

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  #43 (permalink)
Market Wizard
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Big Mike View Post
Keep in mind this attorney was going to have me fill out a 50 page questionnaire detailing all assets, then they would just pick a structure they've picked a hundred times before for other clients, and populate some names on a PDF form.

Sounds about the norm for lawyers.

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  #44 (permalink)
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SMCJB View Post
Sounds about the norm for lawyers.

Not really. Our offshore law firm's KYC questionnaire only required 2 pages of standard contact info and addresses; they did require scans of passports and proofs of addresses for the general partners and major unitholders though. Mike is correct that the lawyers have a duty to learn the client's needs from their conversations and not to pass you a 50 page boilerplate questionnaire.

As for picking the structure and populating the names, I've seen 50/50 of reused materials and creative new language, I think the latter becomes more frequent over time. Sometimes having the same language as 100 other clients is a good thing and if you don't want boilerplate treatment, make sure you have only 1 point person and not 9-10 different names on the time sheets for your invoices.


Last edited by artemiso; December 24th, 2014 at 02:52 AM.
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  #45 (permalink)
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Obtain russian citizenship.Here is,our ''IRS'' still sometimes have difficulties to understand what a brokerage is.Additionally,In some cases a small entity here pays only 6% in taxes per year,not sure if a web based bussiness would qualify,but it very much might be.

There`s no privilege whatsoever in offshore banking - you still pay taxes.There are some benefits for the large companies with big staff in terms of the wafge tax reduction,as i recall.


Last edited by Cachevary; December 25th, 2014 at 10:23 PM.
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  #46 (permalink)
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Cachevary View Post
Obtain russian citizenship.Here is,our ''IRS'' still sometimes have difficulties to understand what a brokerage is.Additionally,In some cases a small entity here pays only 6% in taxes per year,not sure if a web based bussiness would qualify,but it very much might be.

There`s no privilege whatsoever in offshore banking - you still pay taxes.There are some benefits for the large companies with big staff in terms of the wafge tax reduction,as i recall.

That's just flat wrong. Why would anyone the America region choose Russia, especially having to pay 6% instead of 0% in a tax haven close to home.

Also wrong about only big businesses benefitting.

And wrong about your offshore tax assumption.

If you read the thread these concepts were already discussed, including profit deferral and 0% taxes offshore. And using the foreign earned income of around 100k you can avoid self employment tax of 15% plus tax free on first 100k earned if your primary residence is outside the US.

Im not an accountant nor attorney and this is not tax advice

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  #47 (permalink)
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Big Mike View Post
That's just flat wrong. Why would anyone the America region choose Russia, especially having to pay 6% instead of 0% in a tax haven close to home.

Also wrong about only big businesses benefitting.

And wrong about your offshore tax assumption.

If you read the thread these concepts were already discussed, including profit deferral and 0% taxes offshore. And using the foreign earned income of around 100k you can avoid self employment tax of 15% plus tax free on first 100k earned if your primary residence is outside the US.

Im not an accountant nor attorney and this is not tax advice

Sent from my phone

I meant you pay 6% as a small venture in Russia being a Russian citizen,I didn't mean Russia as offshore zone.Sure there are zero tax heavens in Caribbean basin,what I meant you still have to pay 100% whatever you tax rate is in US for the income in that offshore.Plus,in some places you might be obliged to hire couple of locals as a so called "technical managers".Maybe in some places you don't have to,but that's what I was told by local attorney when I used to live there.

I did a research on offshores some years ago and to me it appeared more like myth.

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  #48 (permalink)
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It is funny to read all this stuff, attorney here.... attorney there.... and nobody talks about CFC RULES.

The only good way to do this is the google, starbucks, shell etc.. way with Ireland and Holland as the main players, you will arrange a tax bracket in Holland that is confidential so you will not trigger the CFC RULES and pay legally less tax.
Another way is to be a citizen in a tax friendly country (not for US).

All the rest is just tax evasion and the structures will trigger the CFC RULES in your home country.

You will find allot of online sellers of offshore structures trying to sell stuff like Panama foundation with a Belize IBC and they tell you that this is the safe way to go offshore but in court they will look at that foundation and just look at the way it is used for and that will trigger the CFC RULES.

Just remember that all this companies and even attorney´s, all that they are after is your money!

Maybe this is a good subject for a webinar Mike?
How to legally going offshore?

All have a good trading year 2015,
JJ

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  #49 (permalink)
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http://www.offshorelawcenter.com/offshore-panama-foundation.html


Quoting 
Uses of Panama Foundations

Panama Private Interest Foundations may be established for the benefit of a person or persons, a family, or a specific social purpose. In general, Panama Private Interest Foundations are used by people who wish to control and maintain ownership of foreign corporations, however, they do not wish to own their corporations themselves directly, due to the Controlled Foreign Corporation (CFC) rules in their home countries. Several highly taxed countries such as the UK, Canada, USA, Australia, New Zealand, France, Italy, Spain, etc. have CFC rules which require that their citizens submit declarations (reports) to the appropriate tax authorities, in which they declare that they are the shareholders of such foreign corporations.

Instead of holding the corporations' shares in their personal name or in bearer form, they establish a Private Interest Foundation in Panama that holds or owns the shares of their foreign corporation(s), thus avoiding the CFC reporting rules. Hence, the advantage of using the Foundation as a shareholder for their corporation is to remove ownership from one's personal name (or through a Bearer Share arrangement), and transfer ownership to the name of a foreign entity which does not have owners, rather has privately appointed beneficiaries, which are anonymous. In this way, there is no question as to who owns the company, since the company's shares are issued to the Foundations' name.*
The Panama Foundation provides additional advantages other than just ownership. For example, the Panama Foundation can be useful in transferring funds offshore or receiving funds from offshore. In some cases, people use Panama Foundations as vehicles for these purposes. Some people donate their funds to their Panama Foundations and later use the Foundation to give educational or special grants to their children, grandchildren, or any one else they choose. The advantage in this case, is to avoid fiscal regulations surrounding donations, where some governments impose "gift taxes" and exhaustive reporting requirements.

In general, Private Interest Foundations may not engage in habitual profit-making commercial activities as a corporation can. Nevertheless, they may carry out commercial activities from time to time, as long as the profits of those activities are used for the objectives of the foundation.

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2) Start a journal and post to it daily with the trades you made to show your strengths and weaknesses.
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  #50 (permalink)
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http://premieroffshore.com/retained-earnings-in-an-offshore-corporation/


Quoting 
Controlled Foreign Corporation (CFC): If a U.S. person holds 10% or more of the stock (or voting control) of an offshore corporation, and U.S. persons hold more than 50% of the shares or control of that company, then U.S. persons can defer tax on active income, but not passive income.

In other words, if American(s) control an international business, then that business may defer U.S. tax on retained earnings in an offshore corporation from active / ordinary activities, not from investments. If less than 50% of the business is owned by U.S. citizen(s), then the CFC rules do not apply. For Deloitte’s worldwide CFC guide,*click here.

The CFC rules also limit deductions and control how retained earnings are taxed upon distribution:

Passive income from interest, dividends, investments, etc. is not active income, thus no U.S. tax deferrals are available. Passive income flows through to the shareholders of a CFC and is taxable on your personal return.When you distribute retained earnings from a CFC, they are taxed at your*marginal rate. Long term capital gains rates (currently 20% for 2013) are not available.Losses in a CFC do not flow through to the shareholders. Losses are not deductible until the company is liquidated.If you die holding shares in a CFC, your U.S. heirs do not get a*stepped up basis. When they sell the shares, they will pay tax on their value when you acquired them, not when they inherited them.

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Due to time constraints, please do not PM me if your question can be resolved or answered on the forum.

Need help?
1) Stop changing things. No new indicators, charts, or methods. Be consistent with what is in front of you first.
2) Start a journal and post to it daily with the trades you made to show your strengths and weaknesses.
3) Set goals for yourself to reach daily. Make them about how you trade, not how much money you make.
4) Accept responsibility for your actions. Stop looking elsewhere to explain away poor performance.
5) Where to start as a trader? Watch this webinar and read this thread for hundreds of questions and answers.
6)
Help using the forum? Watch this video to learn general tips on using the site.

If you want
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