Tag Archives: FATCA

OFFSHORE PRIVATE EQUITY COMPANIES: How to file new IRS Form 8621 for a Qualified Electing Fund or Passive Foreign Investment Company – It’s mandatory for tax years 2014 and beyond.

Posted on May 15, 2014 by New Providence

http://www.theguardian.com/world/2012/aug/23/gawker-mitt-romney-offshore-accountsThere are approximately 480,000 active offshore companies in the BVI and about 100,000 offshore companies registered in the Cayman Islands. I estimate that over 95% of these offshore companies meet the IRS definition of a Passive Foreign Investment Company (PFIC) … Continue reading →

Posted in bahamas, capital gains taxes, companies, financial, formation, tax, tax avoidance, tax planning | Tagged , , , , , , , , , | 3 Comments

There are over 500,000 active IBCs registered in the British Virgin Island and over 100,000 “exempted” companies in the Caymans. Goldman Sachs (Cayman) Trust, Limited operates as a subsidiary of Goldman Sachs (Cayman) Holding Company. Why?

Posted on March 8, 2014 by New Providence

Need a tax haven? https://www.linkedin.com/pulse/partners-associates-wanted-thomas-azzara?trk=pulse_spock-articles JPMorgan/Chase writes on U.S. Estate taxation:  “Because stock of a foreign corporation (in a no tax haven) is not subject to U.S. estate tax, holding U.S. situs assets through a foreign corporation constitutes a planning … Continue reading →

Posted in capital gains taxes, financial, tax, tax avoidance, tax planning | Tagged , , , , , , , , , , , , , , , , , , | 18 Comments