top of page
Polar Bear / Napoleon/Penguin Custodians
A Svalbard or St Helena or Fallkands or Akrotiri trust avoids automatic exchange of information
Keep your assets confidential
Row 2
When printing the pdf version of article, ensure you select 'print size to page width', else the image will be too small to read
Articles page D
Articles 27 Dec 2023 - 20 March 2024
Netherlands, Canada and Luxembourg flipped a finger to the OECD on what a Passive NFE for CRS is. Until the OECD stepped on the Dutch's nuts.
If most crypto transactions are off the blockchain, how to track crimes?
Rest assured, as promised in the IGAs, if FATCA's reciprocal reporting is legislated by a Democrat-controlled Congress, it will be simple to bypass.
Can fake and synthetic intangible assets convert a reportable Passive NFE to a non-reportable Active NFE? An easy cheat but IFRS says no!
Meh, David Copperfield made a jet disappear. Watch as a bank account vanishes off the face of the earth for CRS.
Row D 78
Using nominees for CRS planning? Seinfeld called, he wants his 1990s tax plans back.
UK non-domiciled? Move your ass to set up a non-UK trust if you want to avoid IHT. Can also avoid CRS.
Fooled into a PPLI when unaware of alternatives. US Senate Finance Committee finds it a tax shelter and will propose legislature to curb its use.
We try to present in kindergarten language, the death of UK non-domiciled taxation. Attention on inheritance tax within trusts
IRS tackles Malta's International Pension Plan, abused by US persons. What a shocker when lawyers come to the defence of the indefensible.
Row D 77
Row 1
Row 1
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
IRS sinks the brainless captive insurance tax abusive arrangement from Puerto Rico but the carnival barkers continue to hawk this scam.
Carnival barkers selling Citizenship by Investment in 💩hole Caribbean and Pacific islands... time to fess up?
Is the Dutch FGR or the Luxembourg Special Limited Partnership the better fund solution for CRS and CARF? You'll be amazed at the difference.
Reviewing the Consultation of Cayman’s VASP (Virtual Asset Service Provider) Act Amendments February 2024
Crypto, schmipto. Don't be fooled by the difference between a CASP and a VASP
Row D 76
Row 1
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Row 2
Row 2
How the heck can a trust, even a private trust, be a Custodial Institution for CRS?
As sure as god made little apples, FINCen is going to appeal the Northern District of of Alibama's federal district court's judgment against the CTA.
Can you be a CRS Financial Institution (FI) but not a FATCA Foreign Financial Institution (FFI)? Yes, with crypto. More on this fukup explained.
Best CRS/CARF planning structures since sliced bread... and that's no joke.
The fatal flaw in CRS: Managed Investment Entities as reporting FIs merely don't register as a Reporting FI and subsequently "forget" to report.
Row D 75
Row 1
Row 2
Row 1
Row 1
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
CRS-CARF Times Vol 2 of 4 🔹 Regular journal of exploiting CRS and CARF loopholes and weaknesses 🔹 March 2024
Row 5
Row 5
CRS-CARF Times Vol 4 of 4 🔹 Regular journal of exploiting CRS and CARF loopholes and weaknesses 🔹 March 2024
CRS-CARF Times Vol 3 of 4 🔹 Regular journal of exploiting CRS and CARF loopholes and weaknesses 🔹 March 2024
CRS-CARF Times Vol 2 of 4 🔹 Regular journal of exploiting CRS and CARF loopholes and weaknesses 🔹 March 2024
CRS-CARF Times Vol 1 of 4 🔹 Regular journal of exploiting CRS and CARF loopholes and weaknesses 🔹 March 2024
Let's see if one can avoid CARF by using decentralized exchanges and cold wallets.
Row D 75
Row 5
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Great is the OECD, and greatly to be praised. In black, white & purple they confirm an Investment Entity does not report on its Custodial Institution
If a clown opines you start a new NFE company every 2 years because it's a non-reportable Active NFE, complete the act with a cream pie in their face.
You thought Alabama fucked over CTA? Nope, FINCen fooked Alabama.
Major differences between CARF, the EU's DAC8, and CRS. Extraterritorial, retroactive, managed Investment Entities looked through, €0.5m penalties...
CRS Commentary - page 200 par(139) regarding ignoring the Nominee account holder is the best invention since sliced bread.
Row D 74
Why do so many residence-by-investment clowns troll LinkedIn, with BS... "call us today to get a new residence for great tax benefits"
What the hell is a holding Active NFE? It's the biggest loophole since sliced bread.
Can´t believe there are still morons pushing retirement plans as a way to avoid CRS
Which of the 89 non-participating CRS 💩hole countries is safe to bank to avoid the CRS? Hint: Good luck.
Taxman snacking on your lunch? Delay their meal until you retire stinkin' rich to a tax haven.
Row D 73
China join the Crypto Asset Reporting Framework, CRS's extension to crypto? As per CRS, likely join a year later, even though they not yet pledged
Dutch FGRs are invariably a minefield of confusion for foreign wealth planners. However, tweaking Dutch FGRs is exceptional for CARF/CRS planning
The weirdest clause in the 400 pages of the CRS screws up the OECD attack on the investment entity loophole. Halleluja.
CRS planning with fiscally transparent entities
Why bank AML/KYC staff reviewing CRS self-certification are such Simians regard the treatment of Nominees
Row D 72
Most secretive structure in world for chattels. No paper or electronic trail. Structure renamed daily. Physically impossible to trace or confiscate.
Wealth-structuring folks ignore Dutch FGRs just because they don't understand them. Pull finger and learn, you lazy gits.
When does a Settlor's excess powers invalidate a trust? Does this limitation of powers apply to Protectors?
OECD´s Crypto Asset Reporting Framework (CARF) is deeply flawed by Professor Noam Noked. Good luck suggesting amendments to loopholes
It´s a mistake to ignore the OECD CRS FAQ in domestic CRS legislation. E.g., which jurisdiction’s rules apply to determine an Entity’s status?
Row D 71
Innovation: An interesting history of two of my wealth planning structures: i) Pitcairn Island, and ii) Isle of Man fiduciary placement cell insurance
If you can answer these three simple questions on CRS/FATCA, then I´ll eat my hat and belt.
How OECD can sink the managed Investment Entity CRS loophole
A subsidiary of a listed CSP ineptly advises their product is legitimately excluded from CRS. If they approach you, be like Gump and Run Forrest Run.
Your PPLI is a tax con, so says US Senate Finance Committee under Senator D-Oregan Rob Wyden. He recommends they...
Row D 70
Can crypto in an exchange be held by a trust
Is cross-breeding unincorporated structures useful for CARF planning? Surprisingly....
Lawyers and trustees ignore SPV Custodial Institutions trusts. Are they prematurely concluding clients will not benefit from this rare CRS structure?
Law firm's incompetent advice that deferred income investments are not CRS reportable. Hope the client was refunded as quickly as they were billed.
Is Montenegro learning to lie and cheat like its big brother Serbia regarding implementing CRS? Anecdotal evidence and logic suggest so
Row D 69
CARF is gonna hit the fan regarding validation that an Account Holder is a Financial Institution if it relies on the GIIN provided in Due Diligence.
More on those fake IDs generated by AI, down to the fluffy carpet backdrop. KYC /AML staff you may now retire gracefully.for CARF planning? Surprisingly....
How OECD can sink the managed Investment Entity CRS loophole
OECD has omitted 79 of the crappiest nations for CRS but tries to guide them. Are you a loon to use structures in these shitholes to avoid AEoI?
Would a reporting Financial Institution understand this obscure clause about nominees? Me thinks not....
Row D 68
The critical difference between a Custodial institution and a nominee/agent/signatory/strawman.
Learn 8 whatchamacallit, thingamagigs, and thingamabobs regarding CRS Custodial Institutions. I´ll bet you never heard about these.
Is the crusader origin of trusts a medieval bullshit story?
What the hell is an SPV Custodian mentioned in the OECD CRS FAQ dated Feb 2019?
Is it simple to exploit Trump's countries for CRS? I don't mean a knuckle-dragging strategy of opening a bank account there.
Row D 67
The CRS loopholes that remain when countries give the finger to the OECD regarding updates to the CRS via the FAQ, Implementation Handbook, and MDR.
FINCen extends the Corporate Transparency Act to residential real estate. Well, that didn't take long. The end of US as a tax haven days are nigh.
Does the UK recognize any trust in the world where the settlor chooses the UK as the governing law? Yep, and without any nexus to the UK.
Which of the 89 non-participating CRS 💩hole countries is safe to bank to avoid the CRS? Hint: Good luck.
A dive into Article 29 of the OECD Multilateral Convention on Mutual Assistance in Tax Matters Amended by the 2010 Protocol.
Row D 66
From yachts to lavish estates, tracking Russian assets seized so far. You can hide a yacht in Turkey, but how to hide a villa in France?
Can a crypto exchange account be held in the name of a trust? How to include crypto in your estate plan.
Employed for AML/KYC? You're the equivalent of an 8-track player or rotary phone. Inside the underground site where Neural Networks provide fake IDs.
FGR, the Star of Dutch Investment Funds
China Never Completely Banned Crypto. Despite government crackdowns and reports crypto is outlawed in China, crypto trade is much alive in China.
Row D 65
China proposes a ban on converting game tokens to Fiat. CARF would report this transaction to China. Yet the dolts have yet to pledge to join CARF.
Is a municipality-issued utility bill sufficient documentary evidence for the CRS residence test? Not so simple.
Which is the only signatory of the 147 parties of OECD Multilateral Convention on Mutual Assistance in Tax Matters to exclude part of its territory?
Is CARF just an extension of CRS? Nope, and the bad news is the main method that avoided CRS is outdated and will be in scope. So are you in the 💩?
Row D 64
Why China and Hong Kong will join the OECD Crypto Asset Reporting Framework
China Strengthens AML Laws - Cryptocurrency transactions in focus. So when will they implement CARF?
Can Controlled Foreign Corporation rules be a toothless cartoon?
Stashing undeclared loot in the US? "You're screwed". You're a 🍩 if your advisor/relationship manager is clueless about what's happening.
How Russians can use trusts to avoid the impact of sanctions, schmanctions.
Row D 63
Row 1
Row 1
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Row 2
Row 2
Row 2
Remember the 1990s acronym FILTH, Failed In London, Try Hong Kong. Well, seems there is FILTZ. A Zurich lawyer's outdated thoughts on UK trusts.
To the scumbag insurer in Mauritius. Your shit CRS advice to your prospects is pathetically wrong.
Praised be HMRC. For they are good. Confirming trusts can be Custodial Institutions.
Several Commonwealth countries are in direct conflict with the OECD CRS guidance.
What is an SPV Custodial Institution for CRS? Is it possible to determine the Controlling Persons?
Row D 62
Hong Kong to join the 54 countries pledging to implement CARF? They already gave the finger to Mandatory Disclosure Rules, a non-minimum BEPS action.
Bruised by the stock market, the Chinese rush into banned Bitcoin. Is there a drastic need for a privacy solution for CARF?
Scottish Limited Partnership with Dutch Foundation as GP as a Custodial Institution. The client is the Supervisory board of the GP
To schmucks opining FIs such as Custodial Institutions, need to be supervised by a country's domestic financial regulations to qualify as a FI for CRS
3rd parties can collect trustee or custodian fees for CRS. There is no attribution/connected test of income promulgated by several CRS jurisdictions.
Row D 61
Experienced but obstinant, ignorant trustees grate me. Yes, settlors, trustees and beneficiaries can be the same persons for UK co-ownership trusts.
Svalbard under Norway's sovereignty but not part of EEA, Schengen, Nato, visas, CRS, CARF, FATCA, DTAs, AEoI, EoR, OECD MCAA. Independent in 31 areas
End of US bank secrecy. You've got to know when to hold 'em, know when to fold 'em.
Laundromats and VPNs: How China’s Crypto Traders Are Evading the Rules. What are they going to do when CARF dobs them in?
To the Mauritian insurer providing Zero Cash Value PPLI today as a solution to CRS. OECD closed this loophole long ago, you ignorant bozos
Row D 60
Untaxed Financial Institution vs. Untaxed Passive NFE. The jurisdictions for CRS are completely different.
Forget your dinosaur structures. CARF looks through managed investment entities.
Can your Uncle Billy Bob be a trustee of an SPV Custodial Institution to hold your managed Investment Entity? If so, what are the advantages?
A non-resident Scottish Limited Partnership as a Custodial Institution
How would CARF/CRS look through a Custodial Institution holding an Investment Entity? Hint: It cannot.
Row D 59
Trump's nemeses live up to their ill-reputed reputation by reneging on Common Reporting Standard
We told them more than a decade ago that we'd reciprocate the exchange of info for FATCA. Now they think we will exchange data on crypto accounts.
Can US Persons maintain their privacy by avoiding FATCA, but declare FBAR/8938? Is this legal or is it a don't drop the soap action?
WTF surprises of the crypto assets reporting framework (CARF)... this is worth reading.
If Crypto CRS (CARF) is not a minimum standard, how will the OECD's Global Transparency Forum compel its 170 members to implement it?
Row D 58
When is an e-money Institution subject to CARF? It's not simple... and CARF is not a minimum standard, so will it be a f**kup like MDR?
Oh, oh... CARF and Custodial Institutions are mortal frenemies and may never work together
You must be a crazed loon to fall for the exorbitant offshore trust fees instead of UK trusts
Residence and Citizenship by Investment schemes are invariably a tax con. Apply the OECD's Centre of Vital Interest and prove me wrong.
OECD CRS FAQ update - Yeah, you're a professional managing an Investment Entity even if you don't get paid fees
Row D 57
Row 1
Row 1
Using nominees for CRS planning? Seinfeld called, he wants his 1990´s tax plans back.
Row 2
Row 2
The Binance Crackdown Will Be an Unprecedented Bonanza for Crypto Surveillance
China cracking down and showing teeth with its crypto ban. Time to analyze the Crypto Asset Reporting Framework in detail.
Could any amendment to CRS look through a non-participating Custodial Institution?
The CRS definition of managing an Investment Entity went off the rails... yet no one says anything?
The shocking, illogical, and hilarious custody-related fee to qualify as a CRS Custodial Institution
Row D 56
Row 2
Lawyers and trustees ignore SPV Custodial Institutions trusts. Are they prematurely concluding clients will not benefit from this rare CRS structure?
The CRS Custodial Institution balls up
The difference between CRS and FATCA on managed Investment Entities owned by non-participating Custodial Institutions
Trying to educate investment entities that they must report on themselves for CRS. It's a waste of time as no one wants to listen
Row D 55
bottom of page