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Polar Bear / Napoleon/Penguin Custodians
A Svalbard or St Helena or Fallkands or Akrotiri trust avoids automatic exchange of information
Keep your assets confidential
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Articles page F
Articles 14 May 2024 - 13 July 2024
CRS OECD clown draftsman verify money/cash is not a Financial Asset. They have copy and paste dumbo syndrome without a hint of analytical thought.
Clint's mule wants to know what the hell is a holding Active NFE, the biggest loophole ever. The mule don't like it when you laugh at him.
Do I use my AEoI expertise to assist the set-up of unique structures for your clients? Does a bear sh*t in the woods? Is the pope Catholic?
Chinese can file for Outward Direct Investment (ODI) without authorisation. Can send billions to privacy structures run by wealth managers.
How to strip cash to holding company to become a non-reportable Active NFE.
Row F 108
Appoint Protector with fiduciary powers. Will Protector's excess powers invalidate a trust? No, unless they are a"substituted settlor”.
Singapore the biggest s̶c̶u̶m̶ artists helping Chinese residents evade CRS with Personalized Employment Pass and apartment lease. OECD does fuckall.
How can an investment entity trust legally not report on the settlor? Forget the con of Singapore irrevocable trusts which report zero for settlor.
For CRS, unrelated 3rd parties can be paid the custodial fees. Some jurisdictions require these parties to be connected or related, which is bullshit.
Micro-Captives, Foreign Captive Insurance on IRS 2023 Dirty Dozen List; Particular mention of Puerto Rico as the grifter hub.
Row F 107
Why the US will tell Switzerland to feckoff when they request Beneficial Ownership Information from the Corporate Transparency Act
How I discovered Svalbard is not part of AEOI
OECD greatly to be praised. Black & white confirm Investment Entity does not report on Custodial Institution equity interest. Clowns at SIF disagree
How to manipulate the category of your entity as a Financial Institution so that the bank doesn't report on you for CRS.
What is a SPV Custodian mentioned only once in the OECD CRS FAQ and why no look-through of non-participating Custodial Institutions?
Row F 106
A UK trust may hold hold property, but does this exclusively mean land and buildings or can it include say a methuselah of Dom Pérignon?
If a Democrat Congress ever approved FATCA equivalent reciprocal reporting, it will be worthless due to so many loopholes...
Most secretive trust in the world. No UBO/tax registration/licensed trustee/local agent. No paper/electronic trail. Physically impossible to trace.
My unusual financial industry experience: Pitcairn, Isle of Man cells, China ODI, Bahamas MCAA, German Bundestag, UK SPV Svalbard, etc...
Row F 105
Here's the best structure for crypto to maintain confidentiality...
Been advised your untaxed Investment Entity directed by yourself avoids CRS? Oops, that is b̶u̶l̶l̶c̶r̶a̶p̶ wrong
EU Court ruling on B.O. registers: 18 months on need for harmonised approach is clear. In only 13 countries access is limited.
To the Mauritian insurer providing Zero Cash Value PPLI as a solution to CRS. OECD closed this loophole long ago, you ignorant bozos.
Row F 104
Three countries have no beneficial owner register for trusts/funds/companies. Are they in Pacific/African/Caribbean shitholes? Nope: It's all in Western Europe.
Pasquantino US supreme court case can convict US advisors for wire & mail fraud if they assist foreigners to setup structures to avoid tax back home
If SIF can answer one CRS question, I'll eat my hat live stream. I know the clowns will keep their fat mouth quiet as they are wrong but too proud
Caribbean Citizenship by Investment Schengen visa-free travel in toilet. Meanwhile RbI grifters incessantly warn of fee increase. Malta to follow suit
Balkan Endowment fund is the Serbian version of a foundation. Founder allots assets for benevolent cause or private purpose. Exempt from CRS?
Row F 103
Norway has just made it virtually impossible for any tax planner for CRS / FATCA to set up in Svalbard by halting sale of privately owned land.
Swiss State Secretary International Finance f*ckup on CRS, obliging trusts to look-thru FIs, central banks, regularly traded corps, intnl orgs & govts
Why Switzerland isn't on list of 51 trusted Foreign Requestors to access to the Beneficial Ownership information of the Corporate Transparency Act
Bahamas conmen authorities never changed their spots. Implemented CRS for only half of the OECD's AEoI particpating members...
Why US will tell 150 countries to feck off regarding Foreign Requestor access to CTA BOI. Sureptiously will only provide info to 51 trusted countries.
Row F 102
Can HMRC extraterritorial reach if non-resident submits a fraudulent dormant UK LTD company filing? Is it's information request worth toilet paper: Yes
How many countries pledged to join the Crypto Asset Reporting Framework (CARF) as announced by the Global Transparency Forum? Answer: 54 by Dec 2023
Offshore centres introduced con that equity holding company is excluded from Economic Substance. Meanwhile the dumbo OECD is fucking sleeping on this.
European Court of Justice is about to re-confirm the legal privelege of lawyers, who will thus be exempt from AEoI/MDR/AML/KYC reporting obligations.
Monaco & Venezuala added to the 24 FATF 'grey list' shithole countries subject to increased monitoring. Imagine Turkey, Jamaica & UAE white listed.
Row F 101
Swiss sign FATCA IGA-1. Ignorant imbecile tax professionals believe SIF's bullshit on forthcoming US reciprocal reporting. Dumbos deserve harsh rebuke.
Why cross-breed unincorporated structures? Speed, no set-up fee, no annual costs, no b.o. register, no CSP, no notary, no representative agent...
Why typical CRS AML/KYC/Compliance is ignorant regarding nominee/agent/custodian/as the account holder
Global Transparency Forum clowns still counting USA as pledging to support the implementation of Crypto Asset Reporting Framework (CARF)
Row F 100
Will Philippines implement CRS? The OECD's Global Transparency Forum celebrates Asia initiative whilst countries escape...
Where are untaxed NFEs versus Managed Investment Entities located for CRS? It's far from simple...
The best confidential structure for CRS and CARF, without exception. Use nominee/agents instead of Professionally Managed Investment Entities.
Is the Dutch FGR or the Luxembourg SCSp Special Limited Partnership the better solution for CRS/CARF? You'll be amazed at the difference
Dutch FGRs are a minefield of confusion for foreign wealth planners. Tweaking FGRs provides the best structure for CRS and CARF.
Row F 99
Get millions out of China for your wealth management business. If less than $300m, Chinese can merely file for ODI using a privacy structure.
Hiding your money in the USA? IRS issues John Doe summonses to assist foreign governments track your ass. Far better than the meek OECD EOIR.
Chinese residents are now getting tax bills on their offshore profits. How the f*ck did China find the profits not reported by CRS? Easy - EOIR or EOD
The PMIE nil report is CRS's primary weakness. US Senate Finance Committee identifies it as biggests FATCA loophole.
OECD Exchange Information Upon Request: Data by a tax authority to another prohibits fishing expeditions making EoIR as useless as tits on a boar.
Row F 98
Chinese residents with BVI Managed Investment Entitities more often than not, submit a nil report... dumbo move.
48 countries pledged to implement CARF. A month later 6 more countries joined. Since the OECD is quiet on who else is joining, what is the current status?
Vanuatu defends granting citizenshipby investment to convicted businessman amid passport abuse.
What circumstances will Holding Companies and Treasury Centres of financial groups have the status of Financial Institutions under CRS vs FATCA?
How the f*ck can a private trust be a Custodial Institution for CRS? Well, it's because CRS is a fictitious world.
Row F 97
Global Transparency Forum clowns self congratulate their Africa initiative. 84% Exchange on Request done by the 5 African CRS members. What a circus.
Kick the bucket & kiss your crypto away. Mellon bank heir dies with $billions of XRP donated to the ether gods. Rather place in trust with bequest.com
Dummy OECD mistake obliges trusts to look through account holders who are non-reportable eg. FI, central bank, regularly traded corp, intnl org & govt
Malta and EU Commission court fight regarding Citizenship by Investment as result of journalist investigating golden visas. Karma is a bitch.
Real world asset tokenization brings automatic exchange of information to currently non-reportable asset classes. Brilliant, grifter hawkers ignorant.
Row F 96
Con artists hawking offshore captive insurance despite IRS warning they are tax cons due to be eradicated.
Senate Finance Committee will release legislation to clamp down on offshore PPLIs promoted to avoid taxes on the sale of closely held businesses.
OECD morons f#ck up untaxed Active NFE off CRS hook, even if hold stock portfolio. No AEoI for commissions, salary, bonuses, medical, consulting, rent
The best CARF structure in the world, bar none
Can an entity be categorized as two types of Financial Institution for CRS? Why is this critical?
Row F 95
Many query me how an offshore consulting company be a non-reportable Active NFE, even if holds a stock portfolio. Thank the dim f*ckwits at OECD.
Non UK trusts are superior in every aspect than shithole centres grifters hawk, charging an arm & leg ever time they sit on toilet and think of you.
CARF is much more complicated than CRS. Further, it will be difficult to ensnare most Crypro Service Asset Providers as Reporting Institutions...
Incorrect advice by pricey lawyers regarding where a BVI Investment Entity is located for CRS.
Synthetic intangible assets such as patents convert reportable Passive NFE to non-reportable Active NFE. IFRS disagrees but who cares on their opinion
Row F 94
What is Cash Pooling? Is it related to the i) CRS definition of Active NFEs, or ii) Treasury Centres described as a FFI in the FATCA Treasury.
Authority warnings of CRS reporting audits have lower scare factor than 💩 on a shoe.
If most crypto transactions are off the blockchain, how to track crimes? What's on the blockchain is a small portion, just the tip of the iceberg.
EU's strange version of OECD's Crypto Asset Reporting Framework is DAC8. Hilariously, it contains some lunatic asylum add-ons.
Grifters who failed in London, now trying Dubai hawking UAE trusts and foundations, scraping the barrel for shitty justification...
Row F 93
Huge failure of Economic Substance as the dummy OECD were outplayed by tax havens with their shitty Holding Company con... and everybody plays along.
I'll bet most banks confuse CRS untaxed Non Financial Entities residence with Financial Institutions. Wait till you see the OECD tiebreaker fuckup.
It's negligent to headline footnotes of OECD status of CRS commitments that US has undertaken automatic information exchanges pursuant to FATCA
Global Forum self-congratulates its Africa initiative. Meantime, fuckall pressurise on several major countries to implement CRS. Loophole delux.
CARF will be an embarrasing failure for OECD with so many non-participants. Without the US, no GIIN to track FIs. Too many loopholes to list...
Row F 92
EU hammers another nail into the RbI/CbI grifters' coffins. The second nail in weeks.
Turkish Republic Northern Cyprus (TRNC) provides planning opportunity for non-reporting of Automatic Exchange of Information? Yes, if you like risk.
Trillions escaped CRS to US. Ask any bank how many clients shifted assets to US FIs and US trusts. Lawyers in Mexico will only US banks to hide money.
Most of the world's graffiti on OECD & Global Transparency Forum wall about CARF & MDR initiatives that aren't minimum standards, nor prescriptive.
The unknown CRS/CARF loophole. The nominee/agent owned by a NP Custodial Institution.
Row F 91
CARF looks through any Professionally Managed Investment Entity, even if held by a Custodial Institution. Sorry, but this is impossible.
Robert Brockman avoided FATCA with $2.7b using Professionally Managed Investment Entitities incorporated in Nevis & Bermuda. Can you still copy his strategy?
FATCA & CRS will reclassify Investment Entities as reportable persons, look thru to Controlling Persons. It's in CARF & US Senate Committee confirms.
FATCA IRS presumption rules when clients don't respond to queries on claimed FATCA entity status. Whack them with the 30% penalty and close account.
A lead FATCA & CRS compliance officer of world's largest bank messaged me, indicating that banks may be struggling with recalcitrant Active NFFEs.
Row F 90
Caribbean Citizenship by Investment's key benefit sunk. Flush twice, it's a long way to the sewage line.
Lose paddle by falling for grifters selling you a Caribbean Citizenship by Investment. Subsequently, open am account with a smaller local bank to avoid CRS.
Where is an untaxed NFE entity located for CRS? It's radically different to the residence of an FI. Typical advisor is wrong.
Is a trust a Custodial Institution if it's not an Investment Entity? What is the impact of OECD CRS FAQ Feb 2019 on SPV Custodians?
Be aware of those dishing out dog shit advice that a 25% de minimis shareholding applies before being reported for CRS.
Row F 89
WTF is an SPV Custodian mentioned in the OECD CRS FAQ Feb 2019. Now I publish articles on SPV Depository Institutions...
How many of 54 African nations not CRS participants? OECD Global Transparency Forum peer review or pair them for training with participating members?
How a Custodial Institution can ensure a settlor of any revocable trust is not reportable, better than a Singapore irrevocable trust
The recent OECD CRS FAQ update shows you how to establish your own SPV Depository Institution using a trust.
To the muppets opining Depositary & Custodial Institutions need be subject to financial regulations or supervisory oversight to qualify as a CRS FI
Row F 88
Which OECD AEoI initiative is the bigger failure? MDR is hardly implemented outside the EU and 75% of the world has not pledged to join CARF. Both are not minimum standards.
OECD copied a f*ckup from FATCA then tried to fix it like a caveman, making it worse with thousands entities escaping CRS. Congrats you muppets.
So many educated, albeit ignorant dumbos, on linkedin celebrate the US pledging AEoI for crypto. Muppets think LHS cartoon is true but not the RHS!
Swiss told OECD to get screwed on Mandatory Disclosure Rules as it did not constitute a minimum standard. Yet now want to join the optional crypto AEOI
Swiss State Secretary Interntnl Finance misinterpret CRS, oblige trusts look thru FIs, central banks, regularly traded corporations, intnl organizations & govt entities
Row F 87
The gig is up. Singapore's scam of help Chinese residents evade CRS with work permits and cheap apartment lease is over.
Whether to register non-UK trusts for tax - HMRC; or register with the UK trust B.O. register -TRS. Answer: Generally neither, unique in Europe!
Can one exploit Trump's sh*thole non-participating CRS territories? No, not the knuckle-dragging strategy of opening a bank account there.
Trustees exploit a non-sensical CRS clause to exploit a non-existent loophole for thousands of trusts
If an entity holds a Passive NFE subsidiary and collects the dividends, is it a Custodial Institution, Investment Entity or a Nominee?
Row F 86
Sneaky tax havens weasel out of the spirit of economic substance, neutering it useless with holding companies. Laughing at OECD muppets to allow this.
CRS trustees, something new for you. Utility if a trust's underlying company is categorized as agent/nominee/sub-custodian. What's the difference?
OECD took a dump and now reminds entities they don't need a FATCA GIIN to prove they're a CRS Financial Institution. Good luck tracking whose registered as a FI.
I never heard of virtual IBANs. What are they and why do businesses use them? EBA thinks they can be used for money laundering & terrorist financing.
Warning: Do not step into the "Residence and Citizenship by Investment" sales schpiel of sleazy grifters.
Row F 85
The OECD updated the CRS FAQ, inadvertently introducing the "unregulated SPV Depositary Institution". A slew of CRS/CARF loopholes ensues.
OECD now supports a widely used CRS loophole. Thousands of entities can safely be non-reportable Active NFEs because money is not a Financial Asset.
For CRS and FATCA, if your client insists a foundation is the same as a trust, tell him to think again. Here comes the shockers...
Feck-off, occasionally spelled fek or feic, is a word that has several vernacular variations in Irish English, Scots, and Middle English.
Arguments you can expect with ignorant compliance/kyc/aml plonkers. They think they know CRS like the back of their hand, but they don't.
Row F 84
OECD just f*cked-up CRS categorization of cash, then tries to pretzel out with B.S. about Depositary Institutions. A new slew of loopholes awaits.
1st update OECD CRS FAQ since 2019. Covers crypto FIs, Credit Card Issuers & Trading CFD derivatives. F*cks-up cash categorization big time.
IRS sinks the microcaptive insurance tax abusive arrangements from Puerto Rico. The carnival barkers continue to hawk this scam.
OECD muppets misquote the FATF recommendation gleefully accepts there is no need to identify Controlling Persons of listed entities for CRS
Why the patent is the ideal intellectual property to convert CRS Passive NFEs to non-reportable Active NFEs despite IFRS recommending it written off in the short-term
Row F 83
OECD will pressure all CRS jurisdictions to implement the Crypto Asset Reporting Framework. It's not a minimum BEPS action you muppets.
Contrary to the CRS, Netherlands, Canada and Luxembourg deemed most Investment Entitities as Passive NFEs. OECD said, come here little boy....
Is the Dutch FGR or the Luxembourg SCSp Special Limited Partnership the better fund solution for CRS and CARF? You'll be amazed at the difference.
Why the typical CRS AML/KYC/COMPLIANCE is wrong regarding a nominee/agent/custodian/nominee as the account holder, especially if held by a custodial trust
Row F 82
On live TV in 1983 David Copperfield made the Statue of Liberty disappear. Meh, watch a bank account vanish off the face of the earth in 2024 for CRS
150 countries will always be told by the US to f*ck off regarding FATCA equivalent reciprocal information and foreign requestor access to CTA's BOI
What is the difference between a CASP and a VASP for crypto?
Personal Exchange Traded Funds (ETFs) are promoted by grifters, plonkers and con artists as a CRS avoidance solution.
Swiss wealth manager shifts clients account to US trust
Row F 81
The muppet OECD's CRS follows the FATCA balls-up for the income test of a Custodial Institution.
Why is the FGR- Fonds voor Gemene Rekening - the star of Dutch Investment Funds?
China’s crypto craving: Back-door Binance traders look more important to the exchange's future in the wake of the US conviction.
Who are the reportable persons CRS/CARF/FATCA when a trust is a non-participating Custodial Institution? err, nobody.
Can you use CRS non-participating jurisdictions for your confidentiality and data protection? Declare your tax but remain private with data safety.
Row F 80
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