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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 G
Articles 14 July 2024 - 27 August 2024
For CRS and FATCA when can a foundation be a Custodial Institution. Warning: Severe mental gymnastics here.
CRS ambiguities, eg. Financial Account of FI trust not a PMIE, cash financial asset, nil value for irrevocable trust settlor, etc.
OECD updated the CRS FAQ, inadvertently introducing the "unregulated SPV Depository Institution". A slew of AEoI loopholes ensues.
Citizenship by investment lives up to its stinking name. Cyprus announces it revoked ten more citizenships amid ongoing probe, 60 investors since 2021
Cyprus revokes Russian CbI passports. Thank UK on how Russians can use UK trusts to avoid the impact of sanctions, schmanctions. Impossible to catch.
Row G 135
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
Coming Soon
Want confidentiality on a PPLI until payout? Want ultra protection from debtors? Ensure the policyholder is a SPV Custodial Institution.
Singapore now obliges reporting entire property value for settlors of irrevocable trusts. Recategorize the same trust as a SPV Custodial Institution.
Why China/India/Malayia, etc isn't on list of 51 trusted Requestors to access to Beneficial Ownership information of Corporate Transparency Act.
I challenge you to a basic CRS question. Who is the account holder when a trust is a Custodial Institution? Hint: It's not the equity interest.
PPLI Mauritius insurers advise if policyholder is a BVI company, it avoids CRS. Pure bull manure. Sales staff are both ignorant and thieving liars!
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
Coming Soon
Row G 134
Chickens on their way regarding US bullshit promises of reciprocal FATCA, fake pledge to implement CARF and restricted CTA BOI to foreign requestors.
Will CRS anti-evasion or general anti-avoidance rules catch a non-particpating Custodial Institution owning, say, a Singapore Investment Entity? No!
Singapore deletes nil value report guidance for settlors of irrevocable trusts, refers to Implementation Handbook. So can nil still be reported? No.
US pledge to implement CARF is not worth paper it's written on even if Treasury, IRS issue final regulations requiring broker reporting of sales.
Hong Kong pressed to join CARF according to the Global Transparency Forum on its work to ensure wide implementation.
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
Coming Soon
Row G 133
An irrevocable trust for a civil-law jurisdiction client is a shaky house of cards built on quicksand. Rather consider revocable Dutch charities.
Are the CRS anti-avoidance clauses worth the paper it's written on? Hint: No. Will MDR help? Hint: Again no.
Broad participation retirement plan loophole avoid CRS? WTF. OECD not crushing Gibraltar/Channel Islands masters of this sham but destroyed HK ORSOS.
Switzerland publishes consulting list of 99 countries they will send crypto data. Shocker to see it includes countries not implementing CARF.
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
Row G 132
Thoughts on Singapore's Irrevocable Trusts.
Let's Explore Loopholes in CRS/ AEOI.
Let's Talk About Crypto-Asset Reporting Framework (CARF)
Is Privacy Really Dead?
Row G 131
Let's Talk about the Weaknesses of the Mandatory Disclosure Rules?
Can High Net-Worth Individuals Live Tax-Free.
Loopholes in the Corporate Transparency Act.
Future of Residence / Citizenship by Investment.
Row G 130
Is FATCA effective: Interview with Derren Joseph.
Hilarious, single stock MSFT or NVDA have market caps of $3 trillion each but all crypto $2 trillion. G20 making a mountain out of a crypto molehill
How to convert a reportable Passive NFE into a non-reportable Active NFE by sleight of hand
Grifters never give up on pushing costly offshore jurisdictions in Caribbean or Pacific as the best place to form a company by cherry picking crap.
To the BVI compliance ignorants. Can client have a UK governing law trust without any nexus to the UK.
Row G 129
Singapore government endorses the "sham residence CRS evasion scheme". Compliance-KYC staff are stooges, scared to be fired and ignore the OECD CVI.
To the ignorant CRS compliance officer in BVI querying categorization of SPV Custodial Institution. Unrelated 3rd parties can collect custodial fees.
How to disguise your consulting or commission earning company as a non-reportable Active Non Financial Entity for CRS and FATCA.
CRS question for AML/KYC- where is equity interest of untaxed Investment Entities maintained, determining jurisdiction enforcing AEoI reporting.
Row G 128
How the heck can a private trust be a SPV Custodial Institution for CRS? Never heard of it before...
Big 4 misinterprets a CRS clause and subsequently trustees exploit a non-existent loophole for thousands of trusts.
AEOI on global property ownership is getting serious support from the OECD and G20... It was considered a joke request by India a few months ago.
How to legally cheat to categorize your entity as a Financial Institution so that the bank doesn't report on you.
Global offshore trust firms hiding clients in South Dakota. Could the OECD pierce the veil through the firm's headquarters?
Row G 127
RbI grifters out in full force. UK labour on non-dom foreign trust assets relies 100% on AEoI to scare you to cough up for income taxes and IHT.
Singapore trusts and wealth managers, get billions under management almost instantly by Chinese sending ODI funds to your privacy structures.
Useless/ignorant KYC-AML let 1'000's of Chinese be Singapore residents, avoiding CRS while living in China. Heard of Center of Vital interest muppets?
Why settlor re-settle (UK) or decant (US) an irrevocable trust? Acceptable to courts? Settlor be a NP Custodial Institution & why non-reportable?
Serbia pulls the wool over the OECD's eyes on CRS and AEoI.
Row G 126
Something seriously wrong with State Secretariate of Interntional Finance in understanding aspects of AEoI
North Korea signs Svalbard Treaty
Dumb and dumber ideas from desperados on ways to avoid CRS. Even banks are providing putrid plans like Active NFEs....
Singapore, u-turns against settlors after years of enticing with a nil value CRS report. Now they're screwed as trust can't be revoked. Or can it?
Can equity interest of an FI trust be non-participating Custodial Institution, eg. settlor or beneficiary. Can debt interest be a CI?
Row G 125
Swiss State Secretary International Finance misinterpret CRS, obliging trusts to look thru FIs, central bank, international org & govt entity.
Barbados incompetent Financial Service Commission allows peddling of surety bonds and long-term care policies to avoid CRS. Pity it's an outright sham
Awaiting Singapore's justification to ignore the CRS regarding settlors of irrevocable trusts and wrongly interprets their own rule to aid tax evaders
A deep legal dive into a legitimate non-reportable structure for Crypto users held by CASPs, VASPs, CESPs, CASSprs, Digital asset exchanges and CTPs.
A deep legal dive into legitimate non-reportable structures for UK non-doms. Can be used for many other purposes.
Row G 124
Which English Dutch Latina American countries are CRS non-particpating?
Which countries of Africa are CRS non-participants?
Which Asian and Pacific Countries are CRS non-participants
Which Latin American Countries are CRS non-participants?
Which European Countries are CRS non-participants? Which have no IGA with the US?
Row G 123
A deep legal dive into a legitimate non-reportable structure for crypto users held by CASPs, VASPs, CESPs, CASSprs, Digital asset exchanges and CTPs.
FATCA data transfers to the US are incompatible with the EU General Data Protection Regulation. What can you do besides squealing like a stuck pig?
Some jurisdictions misunderstand CRS that trusts look-thru equity interest entities viz FIs, central bank, traded corp, intnl org & govt entity.
UK branch of Swiss bank CRS/FATCA incompetence is beyond belief
Singapore trustees & lawyers irrevocable trusts to hide settlor value. Rather, OECD confirms trusts do not report Custodial Institution settlors
Row G 122
Can synthesized intangible assets hide offshore stash? Convert reportable Passive NFE companies to non-reportable NFE with fake IP viz. patent pending
Here are 8 critical privacy and confidential CRS features regarding Custodial Institutions, you've never contemplated...
Chinese can file for Outward Direct Investment (ODI) using a privacy structures to get money out.
We told them more than a decade ago that we'd reciprocate the exchange of info for FATCA. Now the morons believe we'll exchange crypto account data.
Could an amendment to CRS or CARF look-through a non-participating Custodial Institution and identify reportable controlling persons: Hint: Nope.
Row G 120
CARF gonna hit the fan regarding validation that an Account Holder is a Financial Institution if it relies on the GIIN provided in Due Diligence
The illogical and hilarious custody-related fee to qualify as a CRS Custodial Institution
Is a Dutch foundation supervisory board better than a trust protector or reserved powers of a settlor?
Fishing expeditions vs necessary. Global Forum treats EOIR as important as AEOI. Tunisia - GF peer review Exchange of Information upon Request.
Clowns at the OECD should fix the CRS weaknesses allowing loopholes.
Row G 121
Can China residents avoid CRS by using Taiwan's limited bilateral agreements to exchange info. What about Vietnam?
The difference between CRS and FATCA on managed Investment Entities owned by non-participating Custodial Institutions.
Listing teeny private companies on a small exchange is a CRS loophole that the OECD can easily tackle
Fake retirement funds. OECD is so naive regarding the easiest CRS loophole.
OECD says identify Passive NFE Controlling Persons regardless of parent FI status in the legal chain of ownership. See the feckup on parent FI trust
Row G 119
Nov 2023, 47 countries pledged implement Crypto Asset Reporting Framework. July 2024 the list is 58. Who joined after Nov? Why the US pledge is fake.
I laughed my ass off when India proposed to G20 the exchange of information on property. Be very afraid as G20 officially asks OECD to explore.
If your CRS legal opinion concludes the reportable surrender value of a zero cash value policy is nil, get those legal fees back pronto...
How to bypass US Senate Finance Committee proposed counter measures to biggest FATCA loophole, used by R. Brockman to evade $2.7b.
I get paid commissions, offshore salary, or foreign property rental income. How can I avoid CRS and CARF?
Row G 118
Hong Kong/ Singapore pressed to join CARF according to the Global Transparency Forum on its work to ensure wide implementation. What about China?
Best confidential structures for CARF. Eg., nominee instead of investment entity. Plus 12 other ways to avoid CARF entirely. Long read, but worth it.
Global Transparency Forum just published will peer review jurisdictions not implementing AEoI on crypto. Exploiting the term 'related' to avoid CARF.
Ignorants try to circumvent the CRS by claiming Companies Limited by Guarantee have no Controlling Persons or are Active NFE charities.
OECD Global Transparency publishes its work to ensure widespread implementation of the Crypto Asset Reporting Framework. 58 have so far acquiesced.
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Row G 117
OECD says identify Passive NFE Controlling Persons regardless of parent FI status in the legal chain of ownership. See the feckup on parent FI trust
Norway has no tax agreement with any country in the world, nor does it exchange financial account information, neither on demand. Well partly true...
Update on the 2 West European countries that don't register some trusts, effectively telling the EU anti-terrorist & money laundering to get fecked...
OECD should never have allowed a trust to qualify as a holding Active NFE as it provides a commonly used loophole.
The asset test of a trading Active NFE is the most misunderstood issue of CRS, especially involving accumulated cash.
Row G 116
Can China residents avoid AEoI by using Taiwan's limited bilateral agreements to exchange CRS information?
Is it simple to exploit sh*tholes for CRS? I don't mean the knuckle-dragging strategy of opening a bank account there.
The critical difference between a Custodial institution and a nominee/agent/signatory/strawman.
Corporate service providers help their clients lie to avoid Economic Substance. Chickens will eventually come home to roost.
Trying to exploit loopholes in FATCA legislation for CRS clients? Then you are unaware the OECD has likely closed these loopholes.
Row G 115
If an entity owns a Passive NFE and collects the dividends, is it a Custodial Institution, Investment Entity or a Nominee?
Discover 8 whatchamacallit things regarding CRS Custodial Institutions. I´ll eat my hat if you heard about any of these.
Forget your dinosaur structures. CARF looks through managed investment entities. Use a non-FI corporate nominee held by a SPV Custodian.
Why do so many incorrectly believe a corporate director means your entity is a managed Investment Entity? No, no, no. Well rarely yes...
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.
Row G 114
What are trustees exposure to risk of liability for investment losses? Singapore court of Appeal on the Ivanishvili case tries to answer it.... tries
Oops, don't drop a CRS clause about determining FI status of in non-participating jurisdiction that makes all the difference whether to report or not.
The CRS definition of managing an Investment Entity went off the rails... yet no one says anything?
Labour's tax on non-dom foreign trust assets relies 100% on AEoI to scare you to cough up the IHT. RbI grifters out in full force.
Experienced but obstinant, ignorant trustees grate me. Yes, settlors, trustees and beneficiaries can be the same persons for UK co-ownership trusts.
Row G 113
WTF surprises of the Crypto Assets Reporting Framework. This is worth reading...
There are two strategies to hide clients from CRS: i) Use a fake weakness, or ii) Exploit a real loophole.
OECD CRS-related FAQ. Yeah, you're a managing Investment Entity even if you don't get paid fees...
CRS: A deep dive into Article 29 of the OECD Multilateral Convention on Mutual Assistance in Tax Matters Amended by the 2010 Protocol.
AML/KYC make up ludicrous rules who can discretionary manage assets of an investment entity. Licenced? What percent of assets? What jurisdiction?
Row G 112
Didn't know Equity & Debt Interest as financial accounts relates only to Investment Entities. Thought also applies to custodial institution trusts.
The weirdest clause in the 400+ pages of the CRS screws up the OECD attack on the investment entity loophole.
Reporting Financial Institutions tell the OECD where to stick their CRS anti-avoidance residence-Citizenship-by-investment warnings.
Ignorants try to circumvent the CRS by claiming Companies Limited by Guarantee have no Controlling Persons or are Active NFE charities.
CRS evaders thank OECD morons for Broad Participation Retirement Funds as non-reporting Financial Institutions. Gibraltar trustees love this loophole.
Row G 111
Is a personal listed ETF a valid CRS avoidance solution or a major misunderstanding by schmucks and ignorant tools?
If assets aren't professionally managed, a foundation with a corporate director is Passive NFE. A trust with corporate trustee is an Investment Entity
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? Yes.
Does the Turkish Republic of Northern Cyprus provide opportunity for non-reporting of automatic exchange of Information. Hint: Yes.
So, you think a foundation is the same as a trust for the Common Reporting Standard? Think again pal...
Row G 110
OECD crows about the success of automatic exchange causing a 30% fall in offshore deposits. No, it mostly fled to the USA you schmucks!
Singapore and Hong Kong banks categorise your business as a non-reportable Active NFE even though it is highly likely a Passive NFE
When to register a UK non-resident trust with HMRC and its Trust Registration Service...
Unbelievably, the OECD clowns misquote the FATF recommendation and accepts there is no need to identify Controlling Persons of listed entities
Ya read my non-participating SPV Custodial Institution without b.o. registery, holding a PMIE/FGR/Partnership. You wanna clone it without my help...
Row G 109
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