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Articles page A

Articles 9 Feb 2019 -  16 Apr 2019

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Lawyers and trustees ignore SPV Custodial Institutions trusts. Are they prematurely concluding clients will not benefit from this rare CRS structure?

 

Part 2 - Incorrect advice regarding Balkan Endowment funds exempt from Common Reporting Standard
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Part 3 - Useless legal opinion on the zero surrender value of irrevocable insurance policies
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Part 4 - Incorrect big four advice on not being an Investment Entity
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Part 5 - Idiotic advice given by a bank to avoid the Common Reporting Standard
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Row A 32

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Pink Sugar
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CRS can oblige wealth managers or its parent to report on accounts in the USA by piercing the corporate veil

 

Where is an untaxed entity located for CRS? It's far from simple.
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Ignorants try circumvent the CRS by using Companies Limited by Guarantee as having no controlling persons or are Active NFE charities.

 

CRS: What amount should be reported for a policyholder of a Zero Cash Value Insurance Policy? Hint: not zero.
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Global offshore trust firms hiding clients in South Dakota. Could the OECD pierce the veil through the firm's headquarters?

Row A 31

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Been advised your untaxed Investment Entity managed by yourself avoids CRS? Oops, that is wrong...
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Zero tax jurisdictions dislike economic substance? No problem, they've surreptitiously escaped its main impact.
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If an entity holds a Passive NFE subsidiary and collects the dividends, is it a Custodial Institution, Investment Entity or a Nominee?
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The misplaced self-confidence of banks to move clients'​ assets to USA and continue servicing the portfolio

 

Singapore's irrevocable trusts help Settlors hide undeclared assets by reporting zero. CRS participating jurisdictions should be furious.
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Row A 30

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Barbados: Peddling surety bonds or Long term care policies to avoid CRS. It isn't out of scope despite providers assuring such

 

What's with Gibraltar trustees mistakenly advising that some retirement funds avoid the CRS?
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Exploiting the term 'related'​ to avoid the CRS
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Big 4 misinterprets a CRS clause and subsequently trustees exploit a non-existent loophole for thousands of trusts
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OECD misquotes the FATF recommendation and subsequently "accepts"​ there is no need to identify Controlling Persons of certain entities

Row A 29

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What's with the insurance industry not comprehending Zero Cash Value policies are not a CRS solution?

 

FIs are not listening to the OECD initiative to tackle abuse of residence by investment
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OECD FAQ update February 2019 - Yeah, you're a managing Investment Entity even if you don't get paid fees
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Financial alchemy - Passive NFE becomes Active NFE / Investment Entity
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Don't confuse the EU Commission's failed blacklist vs. EU Code of Conduct Group's blacklist of USA

Row A 28

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Fleeing BVI / Cayman due to Economic Substance legislation
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Automatic exchange of information's gap regarding non-participating Institutions
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EU Code of Conduct Group closes the Investment Entity CRS loophole - perhaps

 

Common Reporting Standard becoming different standards
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EU Code of Conduct Group strategy coalesces against USA as an uncooperative tax haven

Row A 27

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