Need an Offshore Sales Office in a Tax Free Environment?


The 100 year old investment-banking firm of Warburg, Dillon Read (on Park Ave. N.Y.) (now UBS Warburg) has offices in 39 foreign countries - including the Bahamas, the tiny Cayman Islands, Hong Kong and the Channel Islands. Makes you wonder why, doesn't it?


Non-resident foreign companies, trusts, banks and individuals can trade stocks, bonds, commodity contracts and options 100% free from U.S. capital gains taxes.

Under the U.S. Tax Code, only when a foreign company, foreign trust or nonresident alien individual takes up permanent residence within the United States will he be subject to U.S. capital gains taxes in the same way as domestic taxpayers. For a corporation permanent residence would be a U.S. office or warehouse. Capital gains realized by foreign corporations and other nonresidents "not engaged in a trade or business within the United States" are exempted from tax under IRC Section 871 and IRC Section 881 & IRC Section 897(c)(3). Moreover, U.S. Treasury Regulations Section 864-2(C)(1) & (2) provides an exception for what embodies being "engaged in a trade or business within the United States". Under U.S. regulations, a nonresident's Stock Market transactions carried-out through a U.S. stock broker, independent agent, or an employee are not considered to cause the nonresident to be "engaging in a trade or business within the United States".


Publicly traded stock market gains (from NYSE, NASDAQ or AMEX listed stocks and bonds) accruing to an offshore company are free of US capital gains taxes by the Internal Revenue Tax Code's statutes, but "US Shareholders" can have a tax liability (indirectly) if the offshore company is a "Controlled Foreign Corporation (CFC) (i.e., "more than 50% of voting and non-voting stock is owned by US SHAREHOLDERS). See sections 951 thru 958 of the IRC. See especially Code-Section 951(b) for the definition of US SHAREHOLDERS.

American taxpayers that use tax havens are taking more risks (generally) than a foreign non-resident alien (not a US citizen). Whether an American citizen taxpayer will have a tax liability on the offshore company profits depends on a lot of things - including what kind of income is produced by the company (i.e., Subpart F or non-Subpart F) and how many shares in the company you own, and whether the offshore company is a CFC - as defined in the Internal Revenue Code in Sections 957 and section 958.


More on the No-tax haven of Anguilla. Click onto the link below for the details
http://www.geocities.com/taxhav ens123/caribbeantaxhavens.html


A Tribute in Honor of: Bank Confidential Ordinances in the Caribbean

http://www.geocities.com/taxh avens123/bank_confidentiality.html

The Old Monied Dupont Nemours and Roosevelt Families Buy a Tax Haven

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).

Was this the most profitable real estate investment of the 20th century? A quarter acre lot in the gated community of Sandyport here in Nassau, Bahamas sells for approximately $260,000 today. Half acre canal lots in Lyford Cay sell for about one million dollars.

Do the math. On an initial investment of just $40, the 4,000 acre property might be worth almost 4 BILLION dollars today.


YOU BE THE JUDGE.... Are the use of the world's tax havens a blessing or a detriment? Before you answer, see some of the IRS's loopholes from our "Tax Code" - discovered for your viewing below, and buried inside the tax law for the taxpayers! There's a very important loophole for the non-resident alien you should not overlook!

Tom has lived offshore in the Bahamas for over 10 years. When I'm not working on my newsletter, or with a client, I'm out swimming, diving or sport fishing in the sunny- tax-free Bahamas.

Call me at 242-327-7359 with your questions. - 9AM to 5PM - New York time zone is best.

Tom Azzara
New Providence Estate Planners, Ltd.
(Lawyers and Consultants)
54 Sandyport Drive
P.O. Box CB 11552
Nassau, Bahamas
Fax/phone: (242) 327-7359
email: [email protected]

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22 States Considered Eliminating the ‘Tampon Tax’ This Year. Here’s What Happened.  The New York TimesMenstrual products are subject to sales taxes in 35 states, and lawmakers' efforts to exempt them have foundered. Now supporters of 'menstrual equity' are ...
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Things You Should Know Before Filing Your Income Tax Returns (ITR)  NDTV NewsITR filing: Non-filing of return of income may result in penalty and prosecution, according to the Income Tax department.
Budget 2019: Sitharaman urged to bring cigarette taxation to pre-GST level  Business StandardThe Federation of All India Farmer Associations (FAIFA) has urged Finance Minister Nirmala Sitharaman to correct an error in cigarette taxation under the new ...
Sensex plunges further as super-rich tax on foreign trusts stays  LivemintIndian markets on Monday fell another 1% after to hit a *fresh* two-month low as investors were disappointed after the government refused any respite to foreign ...
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No Input Tax Credit for GST paid on expenses incurred on promotional schemes, rules AAR  BusinessLineInput Tax Credit (ITC) will not be available on the Goods and Services Tax (GST) paid on expenses incurred towards promotional schemes, an order by the ...
Wealthy New Yorkers are ditching city's high taxes for Miami  New York Post Affluent New Yorkers, distressed by recent changes to the nation's tax laws, are bucking the New York's high costs and heading to Florida's Miami-Dade County ...
Budget 2019: Income tax collection target too steep, say experts  Business StandardThe income tax collection target was still far from realistic despite the number being revised downwards in the full Budget from the interim Budget projection, ...
Tax department tightens the noose on offenders  LivemintCBDT's stiffer tax provision will ensure serious offenders can't escape prosecution.The guidelines restrict the number of times a person can file a compounding ...
How a Tax Loophole Is Helping Silicon Valley Workers Save Millions  The New York TimesA little-known tax break allows some start-up employees who own company stock to avoid paying taxes on up to $10 million when they sell their shares.
Budget unlikely to up Rs 2.5 lakh income tax exemption limit  India TodayThe current basic income tax exemption limit of Rs 2.5 lakh is unlikely to be raised in the forthcoming full Budget 2019-20, according to informed sources, as the ...
What is the last date to file income tax return? - It's not same for all  Economic TimesThe last date to file income tax return (ITR) varies for different categories of taxpayers. For individuals, Hindu Undivided Families (HUF) and those taxpayers ...
Facebook answers how Libra taxes & anti-fraud will work  TechCrunchFacebook provided TechCrunch with new information on how its cryptocurrency will stay legal amidst allegations from President Trump that Libra could facilitate ...
Tax on buybacks levels playing field for companies, investors  Economic TimesMumbai: The central government has proposed to introduce 20 per cent tax on buybacks by listed companies. Until now, such provisions were applicable only to ...
Opinion | Mitigating tax evasion under GST  LivemintThe present government was instrumental in ushering in two major reforms in India, viz, demonetisation and the Goods and Services Tax (GST). The stated ...
BJP accuses HD Kumaraswamy of wasting tax payers' money  Economic TimesThe BJP on Tuesday accused Karnataka Chief Minister H D Kumaraswamy, battling a major political crisis threatening his government, of "wasting" the tax ...

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