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Confidentiality by design. Outside the scope of CRS and FATCA.
A UK non-resident trust in Svalbard or Falklands, classified as a Custodial Institution. O
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Articles 28 August 2024 - 27 September 2024
Ignorants try to circumvent the CRS by claiming Companies Limited by Guarantee have no Controlling Persons or are Active NFE charities.
The 6 categories of Netherlands foundations seem double Dutch to foreign planners. A Stichting is a tax efficient, respectable, flexible structure.
Hiding money in the US. Pasquantino vs. US Govt threat regarding federal wire fraud if evading foreign tax. The Corporate Transparency Act looms.
Mexicans must restructure the entities holding their undeclared loot in the USA due to the US Corporate Transparency Act.
This CRS loophole was extremely popular with Mexican tax advisors until it fell apart. But they still use it!
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
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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 with CTA BOI
SIF's AIA team on way to work. Why does anyone believe their bullsh*t on forthcoming US reciprocal data after changing FATCA IGA-2 to IGA-1? 🤡
A rip-roaring, lap-slapping retort by compliance officer in Singapore regarding CRS due diligence.
How FATCA is piss-easy to avoid. Forget the illegal moronic shell bank loophole used by Robert Brockman. That was for noobies.
Do EU Directives Administrative Assistance (DACS) extend extraterritorially. Some ignoramuses opine DAC8 does, while DAC6 tries. What a frigging joke.
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
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OECD zaps NL. CA & LU say FO. "It's not nice, you laughin', see, my mule don't like people laughing, gets the crazy idea you're laughin' at him".
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
Can you be a CRS Financial Institution (FI) but not a FATCA Foreign Financial Institution (FFI)? Yes, with crypto. More on this feckup explained.
The 4.2024 OECD CRS-related FAQ update on CFDs describes how to establish your own SPV Depository Institution. Cue a slew of CRS/CARF loopholes.
How the feck can a private trust be a Custodial Institution for CRS? Well, it's because CRS is a fictitious world.
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
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AML/KYC make up ludicrous rules who can discretionary manage assets of an investment entity. Licenced? What percent of assets? What jurisdiction?
Singapore government endorses the "sham residence CRS evasion scheme". Compliance-KYC staff are scared to be fired and ignore the OECD
Only the crazies would pay exorbitant offshore trust fees from BVI/Cayman/UAE/Nevis/Jersey, instead of non-UK trusts.
SIF inexeperienced apprentice misinterprets OECD CRS Implementation Handbook and changes the Swiss CRS guidance. Now CARF whacks him on side of head.
Chinese residents with BVI Managed Investment Entitities more often than not, submit a nil report... dumbo move.
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
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Why do so many incorrectly believe a corporate director (not trustee) means your entity is a managed Investment Entity? No. Well could be...
Why all lawyers, trustees, compliance & funds silent (unaware?) that CARF slaughters the most common structure to hold crypto, the Investment Entity.
CARF gibbers on in French describing how "nue-propriété" and "usufruitiers" are treated. Bet you trustees know little about this...
Our clients no longer need CRS solutions. What's your best confidential structure for crypto? Use a non-FI nominee/agent instead of investment entity.
Nil value report for Settlors of Singapore irrevocable trusts in the poo. Here's a superior new trust replacement. Learn from Elon Musk.
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
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Are you a CRS compliance-officer scumbag, that purposely twists & misinterprets CRS ambiguities to help clients avoid reporting. More than you think.
Is a personal listed ETF a viable CRS avoidance solution or a major misunderstanding by schmucks or ignoramuses?
Listing on a sh*thole little exchange is a CRS loophole that the OECD can easily tackle
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
Exploiting the term 'related' to avoid the CRS. Distant relatives of regularly traded entities are excluded from AEoI reporting. Dumbo OECD.
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
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Unbelievably, the OECD misquoted the FATF recommendation and accepts there is no need to identify Controlling Persons of listed entities.
Six ways that crypto will not be subject to Crypto Asset Reporting Framework (CARF). Some are simple and others sophisticated, but only one is ideal.
WTF! UK trust formed by UK non-dom remains a non-UK trust after April 2025 even if he funds it later. No registration with HMRC or TRS.
UK lawyers are seemingly fearful of Mandatory Disclosure Rules, whilst they are exempt. ECJ confirms their continued exclusion.
Fatal FATCA/CRS flaw: Managed Investment Entities merely report 'nil' or 'no reportable persons'. IRS/OECD can only wring their hands in frustration.
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
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Update on those AI fake IDs, down to the fluffy carpet or stained blanket backdrop. Keanu Reeves says KYC /AML staff may now retire gracefully.
The 2 weirdest UK trusts: i). Co-ownership express trusts. ii). Non-UK trusts which likely do not register with HMRC or TRS unless....
UK non-doms sitting on their behinds, will soon have their financial asset information traversing the world. Confidentiality, a Tim Burton movie!
Swiss SIF CRS expert noobie embarrasingly shows the world he misinterprets CRS clause worse than anyone.
Swiss bank helped Robert Brockman evade $2.7b income using Shell Bank Loophole id by US Senate Committee. FINMA now freezes new accounts due to M-L.
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
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Why I'm fine & dandy describing structures that are legally not subject to AEoI. If you want to submit fraud due diligence then you deserve the crap.
UK lawyers and RbI grifters are so quiet on a likely 45% exit-tax on UK non-doms? US expatriation tax whacks those in the ass on their way out.
Napoleon became fluent in English exiled in St. Helena, wrote it's an ideal place to establish a Custodial Institution to avoid CRS. Kidding, but true
Argentinians repeatedly screwed by fake repatriation offers of low tax. Lawyers convinced you to regularize are long gone. US shit. So what to do now?
Dutch FGRs (Fund for Joint Account) do not register in the trust Beneficial Owner Register if non-EEA fund manager and foreign particpants.
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
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Unbelievably, PPLI grifters return to push Zero/Frozen Cash Value PPLI as a solution. OECD closed loophole long ago & US Senate attacks it.
Can HMRC extraterritorially reach a non-resident submiting a fraudulent dormant UK company filing? The compulsory info request worth toilet paper?
A fascinating YouTube video on a visit to Svalbard. One of best tour videos on the Norwegian archipelago I have seen.
I posted a physical letter to the Swiss State Secretariat for International Finance proving how they misinterpreted CRS on reporting trusts.
Can't be blamed if you're confused about financial penalties if using structures not subject to CRS. Don't confuse with the toothless MDR
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
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Canadian international insurers laughing their fecking heads off at the inane exemption from automatic exchange of information...
What the hell is a holding Active NFE? It's the biggest loophole since sliced bread.
CARF is much more complicated and guileful than CRS. Moreover, it will be difficult to ensnare most Crypro Service Asset Providers as Reporting FIs.
When will 'Exchange of Information Upon Request/Demand' as guided by the OECD Global Forum on Transparency and Exchange of Information fail?
Why non-UK trusts can never oblige beneficial owner registration (TRS) if no nexus with UK. Neither do these non-UK trusts register with HMRC for tax
Equity and Debt Interest refers to Investment Entities. However, a CRS obscure clause extends this to all FIs, that no-one has written about.
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CARF is easy to avoid. However, when cashing out, one needs to combine with CRS avoidance, and that ain't so simple, but quick to establish.
I feel empathy with new CARF reporting Financial Institutions. It's much more difficult, tricky, unclear and onerous than CRS /FATCA reporting FIs.
The only way to legally avoid FATCA, with ideal features. Forget FATCA's dumb shell bank and other loopholes.
Three countries that have no beneficial owner register for trusts/funds. A Pacific/African/Caribbean shithole? Nope: They're all in Western Europe.
RbI grifters pushing Switzerland for UK non-doms to escape 40% UK IHT. Switzerland to hold referendum to increase IHT/Gift to 50% over CHF50m.
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
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Shameful CRS compliance staff earning 7-figure salary are ignorant as a blind dormouse on dual tax residences, else they're stooges for their FIs.
What is income test of a Custodial Institution that has nothing to do with assets held for someone else. Can these fees be paid to unrelated parties?
UK non-doms, rather than listening to RbI grifters panicking you to flee to Italy/Greece for a 10-yr reprieve, consider a polar bear UK trust.
Oh well, Viet Nam joins the OECD Multilateral Convention to tackle tax evasion and avoidance
Seemingly unaware how toothless MDR is, advisors prepare to warn UK non-doms of Mandatory Disclosure Rules penalties if they try avoid CRS...
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
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What penalty if use a structure with no CRS reporting? Nada, nil, zero, zilch, zippo. Hower, if no self-reporting, then trouble. UK lawyer retorts BS.
If the US tax treaty can't distinguish between Svalbard and Spitsbergen, then it's an ideal location for FATCA planning.
FATCA falls down completely when dealing with Custodial Institutions in non-particpating IGA countries.
The confidence of ignorant banks to move clients' assets to USA, yet continue servicing the client...
If a Democrat Congress ever approved FATCA equivalent reciprocal reporting, it will be worthless due to so many loopholes...
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
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Been advised your untaxed Investment Entity directed by yourself avoids CRS? Oops, that is b̶u̶l̶l̶ c̶r̶a̶p̶ wrong.
I use my AEoI expertise to consult / assist formation of unique structures? Does a bear poop in the woods? I work almost exclusively via brokers...
If SIF can answer one CRS question, I'll eat my hat live. But I know they'll will keep their pie-hole closed as they are wrong but too proud.
State Secretary International Finance misinterpret CRS, obliges truststo look-through FIs, central banks, regularly traded corporations, international organizations & government entities.
Who am I to scold FIs & authorities where they're wrong? Pitcairn, Isle of Man cells, China ODI, Bahamas MCAA, German Bundestag, UK-Svalbard trusts...
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
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Here is feedback from Singapore's Compliance-KYC officers on ignoring dual residencies of their foreign HNWI work-permit clients.
Only one way to avoid CARF, which starts in 16 months. However getting compliance to understand it, then I take my hat off...
Compliance ignores OECD CRS update that client may not show documentary evidence of all tax residences. Use Model Convention to reveal all residences.
Is it possible Singapore's compliance industry ignores OECD addendum warning of schemes where not all tax residences are declared. Work permit sham?
Part II of II : Difference how CRS treats a Custodial Institution vs. Nominee/agent/signatory that is not an FI.
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
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Part I of II: What is a Custodial Institution vs. a Nominee for CRS?
None so blind as compliance will not see. The sham Singapore work permit, TIN and leased apartment is likely dual a resident HNWI client. Use OECD MC.
Chinese can file for Outward Direct Investment (ODI) without authorisation. Can instantaneously send to privacy structures run by wealth managers.
How many days to be resident with Singapore's sham work permit? Singapore compliance & KYC don't determine dual residence because their jobs at risk
Why table 7 in the OECD CRS Implementation Handbook is wrong when an FI trust in not an Investment Entity.
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
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Can US Persons maintain their privacy by avoiding FATCA, but self declare FBAR-8938? Is this legal or is it a don't drop the soap action?
Major differences between CARF, the EU's DAC8, and CRS. Extraterritorial, retroactive to 2016, Investment Entities looked through, €0.5m penalties
Trustee admin or custodial fees can be paid to unrelated 3rd parties, despite erroneous nexus requirements by some countries' CRS/FATCA legislation.
What does OECD and US say about agreements with Svalbard. Why no FATCA, CRS, CARF or EOIR. Why not a single DTA. Why excluded from MCAA. Is it blacklisted
These are the top two dozen CRS ambiguities out of the 100 I identified. Will review all in my October Zoom seminar in Singapore.
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
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Co-ownership trusts where trustees & beneficiaries are same persons. Do trustees own assets in joint tenancy or tenancy in common?
For CRS, why do so many believe a corporate director means your company, foundation, partnership is a managed Investment Entity. No, well rarely yes.
Cambodia, Fiji, Palau, Philippines, Uzbekistan, Vietnam, N. Korea, ROC, Bangladesh, E. Timor, Kiribati, Kyrgyzstan, Solomon Is, Tajikistan, Turkmenistan
UK eye watering additional penalties on assets moved to offshore "non-specified" territories. WTF is a "specified" territory and why does it exist?
Majority kids don't recognize 1990s floppy disks, overhead projector, cassette tapes, CD player, pagers, fax or VHS. Do you know 10 CRS ambiguities?
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 H 137
IRAD revokes nil reporting for settlors of Singapore irrevocable trusts, must report total property. Decant (resettle) trust a solution?
Crypto grifters and G20 making a mountain out of a molehill. Hilarious, stocks MSFT or NVDA market cap of $3 trillion but all crypto $2 trillion.
Proof, no better offshore-equivalent trust than the non-UK trust. Using other governing law trusts is likely only for cranks...
So, you think a foundation is the same as a trust for the Common Reporting Standard? Think again pal...
A legitimate UK category of trust that's illigitimate elsewhere globally. Provides unheralded confidentiality dream. AML/KYC... what's that?
Row H 136
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