top of page
Assets confidential . Guaranteed owner cannot be physically traced. Legally not reportable by CRS/FATCA/CARF
A resident of Svalbard, Akrotiri, Falklands, or St Helena as trustee of a UK non-resident trust categorised as a Custodial Institution.
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 E
Articles 27 Mar 2024 - 14 May 2024
Norway has sovereignty over Svalbard & Jan Mayen but not part of EEA, Schengen, CRS, FATCA, CARF, DTAs, AEoI, EoR, OECD MCAA. Strangest place in world
Most secretive trust in the world. No UBO/tax registration/licensed trustee/local agent. No paper/electronic trail. Physically impossible to trace.
The thieving CRS monkeys of Gibratar cannot let go of their pension bananas to unload on ignorants
The digital asset trust. A crypto exchange account or other digital assets held in the name of a trust.
A colossal, enormous CRS loophole that does not work, but used like it's going out of fashion.
Row E 79
How OECD can sink the main CRS loophole. The Professionally Managed Investment Entity (PMIE)...
CARF gonna hit the fan regarding tracking that a Crypto Asset Service Provider is an FI if authority relies on them registering for a IRS GIIN
Exploiting the term 'related' to avoid the CRS
OECD CRS FAQ update February 2019: You're a managing Investment Entity even if you don't get paid fees
Ten years I've said a new NFE company every 2 years as a non-reportable Active NFE is for crooked banks. Unbelievably this shit still goes on...
Row E 78
Can a foundation be a SPV Custodial Institution if most income is from underlying investments? Is this different to a Custodial Institution trust?
An irrevocable trust for a civil-law jurisdiction client is a shaky house of cards built on quicksand. Rather consider revocable Dutch charity
Anyone regurgatating the lunatic ravings of a low-level IRS official US about US implementing OECD's CARF, needs their head read.
Believe it or not, a holding Active NFE is the easiest and dumbest CRS loophole since sliced bread.
What is happening regarding Philippines and Serbia implementing CRS? As usual, the Global Transparency forum making fart noises...
Row E 77
Does the term "Investment Entity" exclude holding companies? Depends if it's FATCA or CRS.
Türkiye substantially completed action plan to be removed from Financial Action Task Force’s grey list. Time to celebrate? Not so fast, chum...
Row E 76
Uninformed reading my structures described that are not reportable for CRS, blurt out 'MDR Hallmark 6, it's reportable', drop the mike and walk...
8 useful revelations regarding CRS Custodial Institutions, I'll bet you never heard about.
Alchemy, how to strip cash to become a non-reportable Active NFE
Shithole, shiny on the outside, rotten to the core inside...
Row E 75
How can synthesized intangible assets hide your offshore stash: Simples, by converting a reportable Passive NFE to a non-reportable Active NFE.
If FATCA's reciprocal reporting is ever legislated by a Democrat Congress, it will be simple to avoid due to loopholes and no anti avoidance clauses.
UK category of trust that's illigitimate elsewhere globally. Provides unheralded confidentiality & sanction busters' dream. AML/KYC be damned...
The last country to not have beneficial owner register or local agent for trusts. Undeveloped Pacific shithole? Caribbean rebel? Nope. It's the UK.
Row E 74
I hear dumb and dumber ideas every day from desperados on ways to avoid CRS. Even banks are offering putrid advice....
Reason for my obsession with Custodial Institution for CRS. Impossible to determine the Controlling Persons... and what about non-participating CIs?
France lost a case where they claimed the beneficiary of a Swiss trust owning a company is a CRS reportable Controlling Person. See UK and BVI views
CARF is a dead horse regarding validation that an Account Holder is a Financial Institution if it relies on the GIIN provided in Due Diligence.
Does the OECD understand how tax evaders exploit the inane CRS exemption of untaxed business and trade entities because they are Active NFEs ??
Row E 73
Quality advice by tax advisors regarding where a BVI Investment Entity is located for CRS
Grifters selling cellular captive insurance from UK territories/ depedencies/Puerto Rico as CRS non-reportable, don't be surprised being stuck up the creek.
Pig, lipstick...If an entity holds a Passive NFE subsidiary and collects the dividends, is it a Custodial Institution, Investment Entity or a Nominee?
A CRS anti-clause that relies on the user to dob himself in is a brainless idea...
Must the UK resident taxpayer report on himself for the UK Mandatory Disclosure Rules? Indeed a Mr Plod move.
Row E 72
UK supra penalties on assets moved to non-specified territories. WTF is a specified territory and why does it exist?
Adoption of Mandatory Disclosure Rules for CRS avoidance arrangements & opaque structures a flop. Useless with key exemptions and no OECD peer review.
IHT: Either Labour is over estimating revenues or headless chicken littles running around warning revenue will collapse. One must be wrong.
55 countries pledged to implement CARF, but 145 countries have kept quiet. CARF is a white elephant project unless it's a minimum standard.
Non-financial asset tokenization brings CRS/CARF automatic exchange of information on these non-reportable asset classes. How to be out of scope?
Row E 71
Proof no better offshore-equivalent trust than the non-UK trust. Using other governing law trusts is likely only for cranks...
Proof that the ostrich strategy doesn't work for CRS.
i) Can a SPV Custodial Institution trust be a settlor? ii) Can a SPV CI be the beneficiary? iii) Can the SPV CI be both the settlor and beneficiary?
CARF for simpletons without making the mistakes of simpletons
The EU's version of OECD's Crypto Asset Reporting Framework (CARF) is DAC6. Hilariously, it contains some non compos mentos blooper add-ons.
Row E 70
What penalty if use a structure with no CRS reporting? Nada, nil, zero, zilch, zippo, diddly squat. Not self reporting, then you're in for it.
CARF is much more complicated and guileful than CRS. However, it will be difficult to ensnare most Crypro Service Asset Providers as Reporting FIs
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 Regs?
In what circumstances, IF ANY, will Holding Companies or Treasury Centres of financial groups have the status of Financial Institution under CRS?
UK non-dom IHT trust protection in the crapper. Lawyers instigating panic and grifters promote new residence or PPLI crap. Calm down, easy to plan.
Row E 69
Unbelievably, for CRS the OECD misquotes the FATF recommendation and 'accepts' there is no need to identify Controlling Persons of some entities
CRS and CARF gibber on in French describing how "nue-propriété" and "usufruitiers" are treated. Bet you trustees know little about this...
Why so many jurisdictions' CRS guidelines incorrectly mentor that a corporate director means the entity is a Professionally Managed Investment Entity
CRS excludes equity interest in FIs as a financial account. Unless it's a con. Illogically, anti avoidance omits Investment Entities. WTF?
Row E 68
What's with the insurance industry not comprehending Zero Cash Value policies are not a CRS solution?
The 6 categories of Netherlands foundations seem double Dutch to foreign planners. A Stichting is a tax efficient, respectable, flexible structure.
Singapore's irrevocable trusts help Settlors hide assets by reporting zero. CRS jurisdictions should be furious with Singapore authority's deceit.
Swiss State Secretariate for International Finance misinterprets the Implementation Handbook regarding entity equity interest of trusts...
Row E 67
How OECD and G20 will pressure all CRS participating jurisdictions to implement the Crypto Asset Reporting Rramework (CARF)
Critical indecisive CRS update by OECD on entity settlors and entity beneficiaries of FI trusts that only a handful of countries have implemented
A numpty planning to avoid CARF AEOI reporting
So, you think a foundation is the same as a trust for the Common Reporting Standard? Think again buddy...
How a Custodial Institution can ensure a settlor of any trust is not a reportable person, whilst the beneficiaries will be reportable
Row E 66
Labour's proposed tax on non-dom foreign trust assets relies 100% on AEoI to scare you to cough up the IHT
Hilarious linkedIn post today from Residence by Investment grifters and carnival barkers.
Labour just screwed non-doms. What can you do, besides fleeing to Italy/Greece/UAE for a temporary reprieve? I introduce the polar bear non-UK trust...
Labour say close non-dom loopholes and screw IHT trust protection🤡. What can you do to protect foreign assets? Introducing the polar bear UK trust.
Can an entity be categorized as two types of Financial Institution for CRS? Why this is critical.
Row E 65
Which 149 countries will be told to fuck off regarding foreign requestors access to BOI of CTA
UK non-doms going to piss away 40% of your foreign assets. Relax, no need to panic emigrate to Italy/Greece/UAE to escape the UK inheritance tax
Get rid of your wealth manager for CARF
Pasquantino supreme court case can convict US advisors for wire & mail fraud if they assist foreigners to setup structures to avoid tax back home.
US advisors who help LATAMs set up Canadian Partnerships ... I know you're not listening but make the Limited Partner a Custodial Institution
Row E 64
US advisors think they can't be liable for helping their clients set up structures in the US to avoid tax back home 😅
Obtuse US advisors and ignorant LATAM clients hiding money in US can be convicted for wire/mail fraud. Sceptics study 'Pasquantino Supreme Court'
Exploiting the term 'related' to avoid the CRS. Distant relatives of listed entities are excluded. Dumb move.
Singapore and the USA account for 90% of evading CRS. The difference is that the Singapore government backs the "fake residence" evasion scheme
Unrelated 3rd parties can be paid trustee or custodian fees for CRS. There is no connected/related requirement promulgated by several jurisdictions
Row E 63
OECD FAQ update February 2019 - Yeah, you're a managing Investment Entity even if you don't get paid fees
If an entity holds a Passive NFE subsidiary and collects the dividends, is it a Custodial Institution, Investment Entity or a Nominee?
... and you thought AML/KYC is one task, done once, done together ??
A CRS clause mess-up and subsequently, trustees exploit a loophole for thousands of trusts
You were wrongly advised of a minimum threshold (25%?) for CRS reporting shareholders of companies and partnerships of Investment Entities
Row E 62
For CRS and FATCA, when is a foundation an SPV Custodial Institution? Warning: severe mental gymnastics ahead without answers.
Incorrect advice by lawyers regarding where a BVI Investment Entity is located for CRS
Singapore's irrevocable trusts help Settlors hide undeclared assets by reporting zero. CRS participating jurisdictions should be furious.
Is a trust a custodial Institution if it's not an investment entity? See the impact of OECD CRS FAQ Feb 2019 on SPV Custodians.
Carnival barkers from Barbados peddling sham insurance to avoid CRS, but it doesn't work despite their threats to sue if you disagree.
Row E 61
bottom of page