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Assets confidential . Guaranteed owner cannot be physically traced. Legally not reportable by CRS/FATCA/CARF
A resident of Svalbard, Akrotiri, Dhekelia, Ascension, Falklands, or St Helena as trustee of a UK non-resident trust categorised as a Custodial Institution.
Set up in a day.
Articles page C
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Articles 2 Aug 2023 - 27 Dec 2023
Can Chinese residents avoid CARF/CRS by using Taiwan's limited bilateral agreements to exchange info?
Swiss Banking Association commentary on the Crypto-Asset Reporting Framework (CARF) and amendments to the Common Reporting Standard
Can you use CRS non-participating jurisdictions for your confidentiality and data protection? Declare your tax but remain private and data safe.
China’s crypto craving: back-door Binance traders look more important to the exchange’s future in the wake of the US conviction.
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Treasury's FinCEN killed off US banking secrecy in 2024 in four easy steps...
Should US trustees be fobbing off the access granted to foreign requesters of the Corporate Transparency Act's Beneficial Owner Information?
Swiss banks are comatose on the impact of foreigner access to CTA BOI, IRS John Doe Summonses, and Pasquantino which can immediately bring billions.
US banking secrecy over by mid-February 2024. Your tax advisor is too ignorant to realize impact of opening BOI register data to foreign requesters.
The US is screwed as a tax haven to stash your cash, so...
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FINCEN just released a final rule about who can access the new US UBO Registry. Oh sh**, Authorized Recipients: Foreign Requesters.
Why do so many incorrectly believe a corporate director means your entity is a managed Investment Entity? No, no, no. Well rarely yes...
Did the OECD understand how tax evaders exploit the inane CRS exemption of untaxed business and trade entities as Active NFE ??
How to legally cheat to categorize your entity as a Financial Institution so that the bank doesn't report on you.
Lawyers and trustees ignore SPV Custodial Institutions trusts. Are they prematurely concluding clients will not benefit from this rare CRS structure?
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Believe it or not, 2 major European countries that do not register certain trusts. So much for the EU anti-terrorist and money laundering requirements
An irrevocable trust for a civil-law jurisdiction client is a shaky house of cards built on quicksand. Rather consider revocable Dutch charities.
CRS carve-out of a type of managed Investment Entity is a senseless loophole that needs to be shot down.
US and Chile tax agreement in force. Now Chile residents hiding their stash in US banks are in deep doggy doo
Don't be a fool.. Mexicans hiding their undecalred loot in US banks are well and truly screwed.
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This CRS loophole was extremely popular with Mexican tax advisors until it fell apart. But they still use it!
If you believe the US reciprocates info to IGA 1 partners, meet IRS Rev Proc depositary interest paid to individuals resident in a few jurisdictions.
Bugs Bunny opines on a UK lawyer based in Switzerland asserting a UK trust cannot exist if no UK Lexus.
Banks wrongly advise untaxed investment entity companies that there is no CRS reporting if the owner and director are in the same jurisdiction
How do fake and synthesized intangible assets hide your offshore stash: By converting reportable Passive NFE companies to non-reportable Active NFEs
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The epitome example of obtuse
Does the Investment Entity term exclude holding companies? Depends if it's FATCA or CRS.
For CRS, if an entity holds a Passive NFE subsidiary and collects the dividends, is it a Custodial Institution, Investment Entity, or a Nominee?
Five crazy CRS loopholes the OECD should whack on the head
Been advised your untaxed Investment Entity (company) directed by yourself avoids CRS? Oops, that is 𝗯̶𝘂̶𝗹̶𝗹̶𝗰̶𝗿̶𝗮̶𝗽̶ wrong...
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Listing on an exchange is a CRS loophole that the OECD can easily tackle
Singapore and Hong Kong banks likely categorize an operating business as a non-reportable Active NFE even though its cash makes it a Passive NFE
CRS/CARF reportable persons when a trust/foundation is a non-participating Custodial Institution? Errr, nobody.
Ignorants try to circumvent the CRS by claiming Companies Limited by Guarantee have no Controlling Persons or are Active NFE charities.
France tried to smack the Swiss Piñata open. They claimed the beneficiary of a trust holding a company is a CRS reportable Controlling Person.
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The OECD must explain at muppet level language two clauses of the CRS that banks get wrong (nudge nudge wink wink on purpose to avoid CRS)
The mistaken confidence of banks who shifted billions of clients' cash to the USA and continued servicing the portfolio. Ha.
Only nut jobs pay exorbitant Cayman/BVI offshore structures. pirate fees! Worse, beneficial owner regulations are stricter than the UK.
Which is first, FATCA reciprocal or hell freezing over? What can FIs such as banks, local/foreign wealth managers, US trustees, and brokers do?
50% devaluation today. Argentinians screwed by repatriation offer of no tax or penalty. Lawyers who convinced you to regularize are long gone...
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Do structures exist that are not reportable for FATCA? How difficult to set up? Thankfully, guidance from the US Senate Committee leads you there.
Brazil's hilarious new tax on foreign income relies 100% on AEoI to scare its tax evaders
Will the CRS loopholes apply to the Crypto Asset Reporting Framework? Answer: Does Dolly Parton have large boobs?
OECD CARF team does not know what the OECD CRS team does regarding deemed Passive NFEs
HMRC steps in and helps define that a Trust can be an SPV Custodial institution. Excellent for CARF
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Chinese banned from owning crypto, but tens of millions do. What are they going to do about CARF?
The weird aspect of the CRS for Crypto that makes no sense but happily is the basis of the ideal loophole.
OECD CRS FAQ impact on SPV Custodians. Trust is a Custodial Institution if not an Investment Entity? How are non-participating Custodians treated?
Pros and cons of circumventing CRS automatic exchange of information by hiding your money in the USA
What is the major difference between the Common Reporting Standard (CRS) and the Crypto Asset Reporting Framework (CARF)? Do the same loopholes apply?
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Hiding money in the US. Pasquantino vs. US Govt threat regarding federal wire fraud if evading foreign tax. The Corporate Transparency Act looms.../
Do I use my expertise to set up structures with you?
Mexicans must restructure the entities holding their undeclared botín stashed in the USA, due to the US Corporate Transparency Act
The US Senate finance committee identifies a huge loophole in FATCA, which is also the Common Reporting Standard's largest loophole.
I̶g̶n̶o̶r̶a̶n̶t̶ ̶ ̶W̶i̶d̶e̶-̶e̶y̶e̶d̶ ̶F̶o̶o̶l̶i̶s̶h̶ ̶ Naïve OECD concludes USA meets EU tax transparency criteria on AEoI
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Oil traders and tanker owners use corporate mechanisms to hide ownership - what's strong - what's weak.
Clint says these two CRS cracks will make a fistful of Dollars
The most beautiful brochure you have ever seen. This Variable Annuity is a very good privacy structure.
Sanctions, schmanctions. Easy as pie for Russians to set up a European trust
Chinese can file for Outward Direct Investment (ODI) using a privacy structure to get money out.
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Find a better privacy structure with these 24 features and I'll eat my hat. Furthermore, it costs a handful of dollars per year.
Five Crypto-Asset Reporting Framework l̶o̶o̶p̶h̶o̶l̶e̶s̶ omissions the OECD and EU dropped
Hiding from Automatic Exchange of Information by Placing Your Money in the USA? We interrupt your peaceful sleep
OECD celebrating in their circus tent regarding USA's false pledge to Automatically Exchange of Information on crypto
Two questions for UK trust lawyers on 1) validity of non-UK bare trusts, and 2) Tenancy in Common-held assets with no nexus
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Automatic exchange of information for crypto will be toothless. DAC8 is water off a duck's back.
Don't forget this weekend to thank this tax authority for the greatest privacy structure in the world !!
Can Swiss wealth managers legally manage portfolios of non-sanctioned Russian individuals?
The US tells the world to shove it where the sun don't shine regarding equivalent reciprocal automatic exchange of information
Conflict zones like Northern Cyprus and Kosovo will never join the OECD Global Transparency Forum
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i. What the heck is an SPV Custodian mentioned in the OECD CRS FAQ? ii. Why no look-through of non-participating Custodial Institutions?
A giant, colossal, enormous, gargantuan, humongous Common Reporting Standard loophole that does not work, but used like it's going out of fashion
Can a UK trust hold property such as a methuselah of Dom Pérignon or when does property exclusively mean land & buildings?
Serbia pulls the vuna over the OECD's eyes on AEoI.
Global adoption of Mandatory Disclosure Rules for CRS Avoidance Arrangements & Opaque Offshore Structures going nowhere fast.
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