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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 B
Articles 12 Apr 2019 - 31 Jul 2023
Whether to register a UK non-resident trust with HMRC...
Norway has no tax agreements with any country in the world, nor does it exchange financial account information... well partly true
Landmine for managed Russian-resident portfolios in Swiss banks
Untaxed Financial Institution vs. untaxed Passive NFE. The jurisdictions for CRS are completely different.
If Democrat Congress approved FATCA equivalent reciprocal reporting, it will be worthless due to 12 loopholes
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An irrevocable trust for a civil-law jurisdiction client is a shaky house of cards built on quicksand. Rather consider revocable Dutch charities.
Fake retirement funds... OECD is so naive regarding the easiest CRS loophole.
The 6 categories of Netherlands foundations seem double Dutch to foreign planners. A Stichting is a tax efficient, respectable, flexible structure.
Global Transparency Forum is crazy to rate US largely compliant on automatic exchange information. OECD ignorant on useless FATCA IGA exchange.
CRS should never have allowed a trust to qualify as a holding Active NFE as it provides a commonly used loophole.
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Naive EU Council concludes USA meets EU tax transparency criteria on Automatic Exchange of Information and Exchange on Request.
EU Officials Press Treasury Over FATCA Reciprocity Efforts
Clowns at the OECD must fix the broken CRS allowing loopholes.
For CRS and FATCA, when is a foundation an SPV Custodial Institution? Warning: severe mental gymnastics ahead without answers.
Does the OECD understand how tax evaders exploit the inane CRS exemption of untaxed business and trade entities as Active NFE ??
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Reporting Financial Institutions tell the OECD where to stick their CRS anti-avoidance residence-by-investment recommendations.
CRS question for lawyers - Where is equity interest of untaxed Investment Entities maintained? Determines jurisdiction enforcing AEoI reporting.
Law firms warp semantics to continue the hoax CRS loophole regarding zero cash value insurance policies
Twit promoting circumvention of CRS based on false premise that Hungarian foundations do not have settlors or beneficiaries.
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The top 6 CRS loopholes the OECD should whack on the head
The OECD must explain in kindergarten language two clauses of the CRS that banks invariably get wrong
CRS carve-out of managed Investment Entities is a senseless loophole that needs to be shot down.
If assets aren't professionally managed, a foundation with a corporate director is Passive NFE. A trust with corporate trustee is an Investment Entity
If your CRS legal opinion concludes the reportable surrender value of a zero cash value policy is nil, get those legal fees back pronto...
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So, you think a foundation is the same as a trust for the Common Reporting Standard? Think again buddy...
Oops, don't drop a CRS clause that makes all the difference whether to report or not.
Insurers use batcrap crazy logic to justify reporting a nil value for irrevocable insurance for Common Reporting Standard
Canadian international insurers laughing their heads office at the inane exemption from automatic exchange of information
Why do so many incorrectly believe a corporate director means your entity is a managed Investment Entity? No, no, no. Well rarely yes...
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Taiwan can't get away from CRS
Fat bastard global services providers help their clients lie to avoid BVI Economic Substance laws
Swiss bank relationship managers, desperate to stop clients fleeing to US banks, tell clients how to avoid CRS with incorrect information.
Argentinian current events may support the argument against the automatic exchange of information
Which jurisdictions can be used to avoid the Common Reporting Standard without being beaten up?
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Avoided Common Reporting Standard by wiring money to the USA? You violated the US federal wire fraud statute with criminal incarceration penalties.
Will America go from hunter to hunted in cross-border tax evasion? Finland targets taxpayers with hidden American accounts, what could become a trend.
How offshore jurisdictions have fooled the EU's Economic Substance requirements on holding businesses
How OECD can crush CRS jurisdiction wealth managers looking after assets placed with US Custodial Institutions, such as Pershing LLC or US Trusts
Banks make up ludicrous rules who can discretionarily manage assets of an investment entity. Licenced? What percent of assets? What jurisdiction?
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Prepare to be smacked open like a piñata if hiding your money in the USA. John Doe summonses assisting foreign governments to be used frequently.
Untaxed investment entities, other than trusts, are the single most misunderstood section of the Common Reporting Standard.
Mandatory Disclosure Rules for CRS useful as a chocolate teapot. It's not a minimum standard has major exemptions and legally can't be retroactive
There are two strategies to hide clients from CRS: Use a fake weakness or exploit a real loophole
OECD crowing about the success of automatic exchange causing a 25% fall in offshore deposits. It mostly fled to the USA, you muppets!
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Using loopholes in FATCA legislation for CRS clients? Then you are unaware the OECD has closed these loopholes.
For CRS, who is the account holder when a trust is a Custodial Institution? Can lack of definition be exploited to hide reporting of the settlor?
Banks are ignorant when proposing a prevalent so-called CRS loophole
Many banks conjure up a non-existent CRS rule that to qualify as an investment entity, the assets must be managed by a "licensed" wealth manager
Banks wrongly advise untaxed investment entity companies that there is no CRS reporting if the owner and director are in the same jurisdiction
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The single most misunderstood issue of CRS / FATCA. The asset test of a trading Active NFE.
Quick Common Reporting Standard quiz. If you ace it, I'll eat my hat.
Singapore and Hong Kong banks categorise your business as a non-reportable Active NFE even though it is highly likely a Passive NFE
CRS reportable value of a Zero Cash Value policy for the policyholder is not null. It is the full cash value.
OECD, for monkey's sake, fix up the 20 CRS deficiencies, ambiguities and inconsistencies. Also, ways to go after accounts shifted to the USA.
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