Offshore Financial Engineering


Providing a Higher Level of IRS Compliant Asset Protection and Tax Planning

 

Our Approach To

Offshore Financial Engineering

 

¨ Take advantage of domestic “Exempt Asset” options.

 

¨ Transfer “Non-Exempt Assets” to domestic

    and/or U. S. compliant international vehicles.

 

¨ International jurisdiction (country) selection.

 

¨ Avoid various state law conflicts and untested domestic planning vehicles.

 

¨ Use IRC Sections 72, 7702 & 817h effectively

    in offshore asset protection and tax planning.

 

¨ Consider offshore captive insurance strategies.

 

 

Representing a consortium of professional organizations dedicated to assisting U.S. taxpayers in the design, implementation and maintenance of U.S. compliant asset protection and tax strategies on both a domestic and  international basis.

International Jurisdiction

Selection Factors

 • Stability of the government.

 • No exchange of confidential information

      through treaties with any other country.

 • No taxes on foreign trusts or corporations.

 • A sound communications infrastructure.

 • Quality international banking.

 • No currency controls.

 • A “common law” heritage.

 • Specific statutes for foreign trusts that:

    • Recognizes and specifically defines foreign trusts.

    • Recognizes that the settler can be a beneficiary

      and can be afforded spendthrift protection.

    • Allows the trust flexibility to relocate to a different

      jurisdiction.

    • Mandates non-recognition of foreign (U.S.)

      judgments.

    • Requires “beyond reasonable doubt standards of

      proof” in establishing fraudulent intent with the

      burden always on the creditor.

    • Requires a posting of bond before litigation can

      commence.

    • Mandates a short statute of limitations period.

Using time-tested Domestic & Offshore

strategies to bring about tax reduction.

— In clear view of the  IRS —

Strict Compliance

with IRS & U.S. Treasury Regulations

The Non-Reporting of

Offshore Financial Accounts

is Criminal Tax Evasion

 

Compliance Issues

 

IRS Notice 2003-34 Revenue Ruling 2003-91 & 92

 

A Sampling of Required IRS Reporting Form: 

3520, 3520A, 1040b, 8832, TDF 90-22.1


Our Financial Life Support SystemsTM

Your client’s financial life support system(TM) makes up their entire financial and economic being.

 

It encompasses the unique attributes of their income and expenses, debt, investment and non-investment assets as well as business entities in conjunction with their specific needs, concerns and objectives.

 

It is complex, interrelated, ever-changing and extremely susceptible to outside forces. Outside forces like legal, financial and economic.

 

In order to achieve long term financial success, your clients need you to help them control, protect, maintain and enhance their financial life support systems(TM) on a constant basis.