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| US Billionaire Rupert Murdoch ‘s News Corp. owns more than 15 subsidiaries in the Cayman Islands? | I can take a taxable U.S. estate tax liability of $200,000,000 to 0 using entirely legal applications! |
| Commentary. Matthew Lynn - columnist for Bloomberg News. The opinions expressed are his own. Well, in truth, it is the big companies we work for, own shares in, and buy goods from. Here are just two examples, plucked at. News Corp., the media company run by Rupert Murdoch, according to its latest annual report, is the owner of companies such as News Cayman Ltd., based in the Cayman Islands, Newscorp Netherlands Antilles, Quazar Investments, based in Mauritius, and the cutely named Shining Profits Ltd., based in the British Virgin Islands. In total, News Corp. owns more than 15 subsidiaries in the Cayman Islands, and more than 40 in the British Virgin Islands. Is it really necessary to have 40 subsidiaries in the Virgin Islands? Surely it's quite hard to find 40 people, never mind 40 businesses you would actually want to own. Barclays in St. Lucia Barclays Plc, one of Europe's biggest banks, operates branches in such places as Belize, the British Virgin Islands, Cayman, the Netherlands Antilles, Puerto Rico, the Turks & Caicos Islands, St. Lucia and St. Vincent, according to its corporate website. Again, what is it doing there? Is the St. Lucia economy so important that Barclays feels unable to ignore it? This is a bank that has not yet troubled itself to establish bases in countries such Poland or Thailand or Chile. But it feels St. Lucia is a good place for a bank. Why? The point is not to single out those companies: they are no different from thousands of their peers. But their behavior poses two questions. If there are tens of thousands of offshore companies, serviced by hundreds of offshore banks, all of which are closed to regulators and the police, does that not create an environment in which it is easy for terrorists to hide and launder their cash? And does it not also create an environment in which it is impossible for investigators to track money down to its source? Among the billions held in offshore accounts, shuttling between the offshore subsidiaries of global companies and global banks, the money trail goes cold very soon. Call me at 242-327-7359 with your questions. - 9AM to 5PM - New York time zone is best. Check out our websites below for more information. Tom Azzara New Providence Estate Planners, Ltd. (Lawyers/Barristers and Consultants) 54 Sandyport Drive P.O. Box CB 11552 Nassau, Bahamas Fax/phone: (242) 327-7359 email: taxman@batelnet.bs websites: http://www.bahamasbahamas.com/ FOR MORE TAX LOOPHOLES FOR AMERICAN AND FOREIGN TAXPAYERS USING TAX HAVENS. CLICK ONTO ONT0 ANY OF THE WEBSITES BELOW Retire offshore and get $74,000 salary exemption from the IRS. http://www.geocities.com/taxhavens123/retirement_havens.html MORE ON THE NO-TAX HAVEN F ANGUILLA - A BRITISH OVERSEAS TERRITORY LIKE THE CAYMAN ISLANDS click onto the link below http://www.geocities.com/taxhavens123/caribbeantaxhavens.html Thousands of Offshore "Banks" trade the NYC Stock Markets tax free - legally! How? click onto the link below for the details http://www.geocities.com/taxhavens123/capitalgains_taxfree.html For my Offshore Request Form click on to..... (or paste in your browser) http://www.bahamasbahamas.com/orderibc.php Professional track record: In the last 11 years, I've incorporated over 1,250 International Business Companies here in Nassau and Anguilla - a United Kingdom “Overseas Territory” like the Cayman Islands and the British Virgin Islands. Beginning in 2,001, we began forming IBCs out of the Crown Overseas Territory and no tax haven of Anguilla - 150 miles east of Puerto Rico. We have a total of over 400 IBC's (in-house) that are mostly Bahamian in origin, and most all are being moved to better jurisdiction - in our opinion. We've formed more than 205 Anguillan IBCs since the beginning of this year (1-3-2001 thru 1-3-2002). It takes less than one day to get the documents and company registered in Anguilla, and on the way back to client the next day. In January, 2001, I became an "Overseas Agent" for the Anguilla Government Registrar of Companies, and as such, have a signed “official” Agreement with them. I also have same agreement with a barrister in Anguilla - also working directly with Anguilla Government. I provide clients with bank contacts and application information for good banks in the following jurisdictions: Isle of Man (a major institution) + Anguilla (2 banks there - one used by the Anguilla government) + Bermuda (one of oldest banking institutions in offshore world) + NEVIS - The Bank of Nevis (a small institution with a $5,000,000 net worth). NOTE: All offshore banks today have tough "due diligence" rules and procedures. More stringent screening of their clients and his activities is now the norm. If you can't tell your bankers what you do and who you are, you can forget about banking offshore. Once bank accounts are opened, your confidentiality is usually protected under the jurisdiction's "statute" - within a Confidentiality “Ordinance” or an "Act" Bank confidentiality seems to play an important role offshore. It remains good in Anguilla, the British Virgin Islands, and in most all of the other tax havens. The IRS and other revenue agents cannot seize, lien on, freeze or investigate offshore bank accounts or the assets of an offshore companies registered in offshore jurisdictions like Anguilla, Bermuda, Caymans, the Bahamas, Panama and the other tax havens. In the eleven years I've lived on this island, I've never seen this happen. One Swiss banker with banks in Cayman and Switzerland told me two summers ago that they always do their companies in a different jurisdiction from where the company does its banking. This is good advice, but illegal activities will not be tolerated by any reputable offshore banks. Amazon.com book reviews for our "Tax Havens of the World" - paste or just click on below.. http://www.amazon.com/exec/obidos/ts/book-reviews/1893522016/qid=916410832/s |
The Federal Estate Tax vrs. “The deviser” The Federal estate tax is the last tax you have to deal with and ponder over while you are alive. I have yet to see the IRS drag a corpse into tax court to settle an estate or income tax claim. Just don’t bury yourself like King Tut did, and they’ll probably leave you alone forever. “They”, meaning everyone – not just the IRS. Engineering for your life's end: Foreign trust corpus (for US taxpayers) approaching 1/2 trillion or more – IRS report indicates? The following statement was gleaned from the IRS's online website in December 2002. It was buried in a 14-page article.....(Publication 1136) (Rev. 11-2001) Bulletin Fall, 2001. "For 1998, some $1,300 million were reported as gifts or bequests from nonresident alien individuals or foreign estates, while $19 million were reported as gifts from foreign corporations or foreign partnerships." - IRS/Treasury Department (Foreign Trusts - by Daniel S. Holik). Take note: US beneficiaries of the above Foreign Trusts investigated by IRS agent/writer Daniel S. Holik are required to report trust income distributions on Form 3520A - but only on trust distributions of over $100,000. Take note#2: Since only $100,000 distributions were reported to the IRS, the REAL amount of trust distributions to US taxpayers is certainly 5 to 10 times greater than the $1.3 billion reported (as much as $50 billion or more is my estimate). Take note#3: The corpus held in these foreign trusts is more than likely 100 times (in size) the annual distribution numbers - or perhaps as much as 5 Trillion dollars. (Our speculation - even the IRS does not know). What is a pound of information worth? After 12 years of practice, I stumbled onto a "formula" of sorts. Hey, listen. They didn’t know everything about DNA 20 years ago either. I can take a taxable U.S. estate tax liability of $200,000,000 to 0 using entirely legal applications, and knowledge from studies in international tax transactions and tax havens (aka - Professor Marshall J. Langer (summa cum laude)- and other book/writers found in all US law libraries). In addition to the 100% marital deduction, the IRS Federal Estate tax law allows for a deductible devise. No domestic tax planning competes or comes close to this type of tax planning. This formula (devise) can be integrated with domestic planning - including gifts to US foundations, philanthropy, etc. De vis er (n) somebody who conceives of something and figures out how it will work. De vise (vt) 1. to conceive of the idea for something and figure out how it will work. 2. to pass on property through a will. Definitions from Microsoft Word dictionary Editor’s note: The "formula" (devise) prescribed for the American taxpayer would likely work for a British member of the House of Lords or the Duke of Marlboro - just as well as it would work for Michel S. Dell (Dell Computer - net worth $30 billion ). UK and US tax law run hand and hand in certain areas. Call me at 242-327-7359 with your questions. - 9AM to 5PM - New York time zone is best. Thomas Azzara New Providence Estate Planners, Ltd. (Lawyers/Barristers and Consultants) 54 Sandyport Drive P.O. Box CB 11552 Nassau, Bahamas Fax/phone: (242) 327-7359 Are the kings of American industry avoiding the Federal Estate Tax? You can bet some of them are. Want to know why and how the old monied Dupont Nemours and Roosevelt families were able to buy 4,000 acres of waterfront property on the island of Provindentcials in the tax free, crown colony (or "Overseas Territory") of the Turk and Caicos Islands for 1 cent an acre? This 4,000 acre sale (now a marina and resort town - with an airport for jumbo jets (the $50,000,000 airport was donated by the UK government) went down in the 1970's - not the 1870's!?!? Source: A Turks & Caicos Government 3 full-page advertisement in Investor's Daily (1985). In 1970 the IRS issued the following ruling to study... Editor’s note: This ruling is just one of the “puzzle pieces”. This ruling does not eliminate the Federal Estate Tax – but tells you that trust distributions from a Foreign Grantor Trust can be received by a US beneficiary TAX FREE. Revenue Ruling 69-70 states: "An individual beneficiary who is resident of the United States is not taxable on a distribution from a foreign trust considered to be owned by a nonresident alien grantor under subpart E of subchapter J of the Code" - these are the exact words of the Internal Revenue Service tax writers - i.e., tax lawyers working for the Treasury department writing your tax law. They are people from Harvard, Stanford, and other big name institutions. FULL IRS TEXT of RULING FOLLOWS: Rev-Rul 69-70: "Advice has been requested whether the income of a foreign trust, under the circumstances described below, is taxable to the beneficiary, an individual who is resident of the United States. X, a nonresident alien individual, created a foreign trust for the benefit of a resident of the United States. Under the terms of the instrument, X reserves the absolute power to dispose of the beneficial enjoyment of both the income and the corpus of the trust. The trustees are nonresident aliens, and all the trust property had a situs outside the United States. When income-producing property is placed in trust, the Federal income tax liability generally shifts from the grantor to the trust and beneficiaries in accordance with subparts A through D of part I, subchapter J, Chapter 1, subtitle A of the Internal Revenue Code of 1954 (sections 641 through 669). However, where the grantor retains dominion and control over the income and corpus of the trust, subpart E of subchapter J (sections 671 through 678) rather than subparts A through D of subchapter J, is applicable. Since X, a nonresident alien grantor retained the absolute power to dispose of the beneficial enjoyment of both the income and corpus of the trust, he is treated as the owner of the trust under IRC §674(a) of the Code. Accordingly, an individual beneficiary who is a resident of the U.S. is not taxable on that portion of the income distributed to him from the foreign trust which is considered to be owned by the nonresident alien grantor under subpart E of subchapter J of the Code. It should be noted that United States source income of a foreign trust considered to be controlled by a nonresident alien grantor is taxed to the grantor. If the grantor is a resident of a non-treaty country, the provisions of section 871 of the Code apply concerning the tax. However, if the grantor is a resident of a treaty country, the provisions of the treaty may determine the tax." [Author of this ruling is our own IRS]. Applying Rev-Rul 69-70 to an example is one practical way to show off its significance. EXAMPLE: Number 1 son Y of successful Bahamas businessman X marries American debutante Z in June of 1999. Both Y and Z plan to live in the United States permanently. Instead of giving them a lump sum of money as part of their wedding gift, Mr. X (a nonresident alien for purposes of U.S. tax law) asks his Bahamas lawyer to place $1,000,000 in trust for Z and Y. The Bahamian trust is revocable by the non-resident alien grantor X. meaning he can call back the assets any time. The trust designates Y and Z (both residents of the United States) as the sole beneficiaries, and stipulates that Y and Z have the power to add new names to the list of beneficiaries, should there be any little Zs or Ys in the future. The corpus of the trust consists of Dutch Antilles issued Eurodollar bonds of Exxon Corporation paying 10% interest pa. Income of the trust is to be distributed to the beneficiaries, as it accrues. Under the U.S. grantor trust rules neither Y nor Z is viewed as the owner of the trust corpus ($1,000,000), because neither has the power to vest the trust assets in favor of his or herself. Having the power to name "new" income beneficiaries is not a grantor trust power under U.S. tax law, and will not shift the incidence of taxation away from the grantor to the U.S. beneficiaries. In addition, it is clear that income distributions paid by the foreign trust to Y and Z can be received free of all Federal Income taxes via Rev-Rul. 69-70, so long as there is a non-resident grantor for the trust (i.e., as long as Mr. X lives). If the foreign trustee takes care not to purchase investments that incur a U.S. tax liability (such as dividends from U.S. stocks which incur a 30% withholding tax), the trust will have no tax liability to discuss with the IRS. As for the U.S. beneficiaries, they should answer item 11(a) (YES) and item 12 (NO) on Schedule B, Part III which appears on the back of every U.S. taxpayer's IRS Form 1040. But this disclosure is frivolous. DO YOU KNOW WHAT A REVENUE RULING IS? A Revenue Ruling is not a law passed by Congress; it is a proclamation by the Internal Revenue Service explaining the facts as they relate to a particular set of laws. Revenue Rulings are the published conclusions of the IRS concerning the application of tax law to an entire set of facts. Revenue procedures are official statements of procedures that either affect the rights or duties of taxpayers or other members of the public, or should be a matter of public knowledge. The purpose of these rulings is to promote a uniform application of the tax laws, and therefore IRS employees must follow the rulings. While taxpayers can rely on the rulings, they can also appeal adverse return examination decisions based on the rulings to the Tax court or other Federal courts. The statement above was written by the IRS. It was taken (word for word) from one of their own publications. • One of the most effective applications of offshore trusts is in an ownership combination with a limited company. • Richard Graham-Taylor, partner Ernst & Young, Grand Cayman (January 1990) |
| Billionaire Michael S. Dell (Dell computers) is building a mansion on this island paradise - we were told by two islanders of substance. Click on website below..http://www.geocities.com/taxhavens123/caribbeantaxhavens.html | |
| READ ALL ABOUT IT.. MONTSERRAT'S CONFIDENTIALITY ORDINANCE FOR PRIVACY IN YOUR FINANCIAL AFFAIRS. CLICK ONTO http://www.geocities.com/taxhavens123/bank_confidentiality.html |
Call me at 242-327-7359 with your questions. - 9AM to 5PM - New York time zone is best. |
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