Saturday, March 22, 2008

5 trillion held "offshore" in tax havens

5 trillion in assets worldwide is held "offshore" in tax havens the IRS writes on their website: “It is difficult to quantify the amount of assets being held offshore or the rate at which the industry is growing. But it has been estimated that some $5 trillion in assets worldwide is held "offshore" in tax havens. Presumably transfers from the U.S. Represent a large share of this wealth. One authority has estimated the annual revenue loss to the U.S. At a minimum of $70 billion.”

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.


IRS CIRCULAR 230 DISCLOSURE

To the extent this document constitutes tax advice subject to Circular 230this tax advice was not intended or written to be used and it cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer. (The foregoing legend has been affixed pursuant to U.S. Treasury Regulations governing tax practice).

About the Author: The author has been domiciled in a tax haven (Nassau Bahamas) since 1990. He is the author of a 375 page book - Tax Havens of the World (available at Amazon.com/8th edition)and the Tax Haven Reporter (a monthly newsletter published since 1985).

The offshore financial services firm he works for has formed over 1300 Bahamian and Anguilla companies and Anguillian and Bahamian (foreign) trusts since 1990.

Tom is currently an overseas agent for the Anguilla registrar (since 2001) - a UK overseas territory in the eastern Caribbean like the Cayman Islands Bermuda and the B.V.I. The offshore bank we recommend was once called Bank of America Bank and Trust (Anguilla)Ltd.(back in 1984 ) and is a publicly traded bank whose stock is traded on the Eastern Caribbean Stock Exchange. The Government of Anguilla uses this bank for their own registrar services. PriceWaterhouse was the underwriter that brought this bank public back in 2001.

New Providence Estate PlannersLtd.
Overseas Agent - Anguilla Registrar
(Consultants)
54 Sandyport Drive
P.O. Box CB 11552
Nassau Bahamas
Fax/phone: (242) 327-7359
E-mail: taxman@batelnet.bs

Sunday, October 28, 2007

The Yellowfins from HELL!

Hi Lee Palm/Red Rooster crew(San Diego - California).. Keep my rail spot cool for me - won't you?

Fishing Report from Nassau Bahamas (8-10-2000)(Thursday)(Air Temperature 92 degrees. Water temp. – mid 80’s degrees). Clear skies, no wind and burning hot sun. Caught two Yellowfins in the 60-pound range that almost sent me to the hospital.

Caught 2 YFY on Thursday - fishing "solo" aboard my WellCraft Scarab that had just been repowered with two 225 Evinrude fichts (cost was $28,000 including the installation).
Both YFT went about 70#s each (83 pounds of filet). Drift fished with fresh/frozen squid to start. Began fishing at 9:30AM and quit at 2PM.

As I arrived at the US Navy’s AUTEC buoy 10 miles offshore (a practice area for the US Navy’s nuclear subs – which show up on the surface now and then)(the AUTEC buoy is in 6,000 feet of water) Capt. Robbie New (from Trinidad) of the "Little Trick" was just starting to fish.
For the first hour all I managed was a 2 pound jack – that I later used for bait.

Robbie was having no luck either, but we saw several 50# YFTs come high out of the water several times, so that kept us anticipating.

At around 11:00 AM my bow rod with 80 pound test line and 80# green Berkley trilene leader, with a small Mustard circle hook on the end (with a 100# test Sampo swivel in between) went off.

I had just seen a big YFT fly through the area minutes before, and I was thinking I had him or his cousin – for sure. The line screamed out, and the fish ran deep. Everything pointed to a YFT, but after about 10 minutes I saw a 25 pound foot shark on my line, hooked right in the mouth with the circle hook.

Leaving the shark on the line in the rodholder, I sat down for a drink of water – out of a gallon plastic jug in my cooler.

Cut him loose, I thought to myself. But, then I remembered how many YFT’s I’d caught using shark as bait, and went to take another look at him. He was a good 4 feet long. Normally too big to bother with, but the fishing was slow, and I decided to take him.

Even though I knew he would thrash about crazy-like when I gaffed him, I decided to go for it, but I missed my 5-foot long fishbox, and watched him go bonkers on my deck, as I hustled to slide him into the Scarab’s 2-1/2 foot deep fishbox.

By 12 noon I switched from "squid" to the fresh jack for bait on all three of my poles. By now, the shark was dead, so I dragged him to the stern and started to filet him – throwing bits and pieces of shark meat overboard – with plenty of blood being washed overboard with my saltwater thru-hull washdown pump.

I filleted one side of the shark, took the skin and cut it into 5 pieces, and through it over the side. All the time – washing the blood and guts overboard. I cut the shark’s giant liver into small pieces, and watched them float on the surface – as I slowly drifted along towards to AUTEC Buoy.

Within 5 minutes of cutting into this shark, the bow line went off – "screaming". This time I knew it was probably a YFT. The fish had hit the 80# test trilene line on a 5-1/2 foot Palm Beach tuna rod, held in a Perko side mount rodholder.

I immediately scrambled about for my harness and playmate belt. Several times the YFT would stop his run deep, and I’d reel the line in fast to make sure there was no slack in the line, and smiled when I felt his weight again on my pole.

But, it was 95 degrees in the sun, and I was about to expedience something in 8 years of YFT fishing (and over 350 caught and landed), that was going to make this no ordinary day on the water.

After picking up the rod and snapping into the harness, I began the slow process of bringing him to color. I was grateful he had picked the rod with the 80# test line, as the other two reels (Shimano graphite a Penn 30W) had 50# test Trilene (Big Game) line, and fighting a YFT on 50# test line is a completely different ball game.

Fifteen minutes into the struggle, my thumb (on the reel) got an awful cramp, and actually stuck to my palm. I couldn’t understand why this was happening, but kept going – attempting to shake off the cramp.

A few minutes later the cramps spread to my forearm – then up to my biceps. I’m 220 pounds, a former HS All American swimmer, and 4 time NY State gold medallist, so I’d been through tough workouts, but this was something I never dealt with.

Even my legs were cramping up. There was no wind, no cover from my bimini top, and it was 95 degrees in the shade. It all added up to one thing - "Heat Exhaustion".
To cool off I tried stepped into a 5-gallon bucket of saltwater, but this didn’t help one iota. My feet were also too big for the bucket.

In addition, I was getting unusually tired – FAST. HEAT EXHAUSTION had set in, and was challenging me like "The old man and the sea".

It took me 55 minutes to land this 70-pound YFT, but I finally got him in the boat. Boy, was I relieved.

Usually I wash all the blood off my boat immediately upon landing a fish, but this time I went to the stern, turned on the saltwater pump, sat on my cooler, and just let that saltwater run over my head for 5 minutes. I finished off about 3/4 of that gallon jug of water too.
As I slowly headed back in the direction of Capt. Robbie’s "Little Trick", the cool air hitting my Toronto Raptor NBA Jersey (#14 worn by Vince Carter) made me feel much better, but I still wasn’t 100%.

By the way, you might want to purchase one of these NBA "Jersey’s sometime. You’ll know why the NBA uses them. They are 1000 times cooler than anything cotton or other material. I have a Laker’s #34 too. My favorite.

I waved at Capt. Robbie, as I passed slowly off his stern, and he shouted – "I thought you were fighting 2 YFT, you were gone so long."

Anyway, I set up again to try for another (YFT).

Now I’m using white shark chunks on all my hooks, and chunking with the fresh shark – as the lines are let out.

About 45 minutes later, the stern line goes off – screaming. This is my Penn 30 International with no leader and 50# Trilene line – no swivel. Christ, I said to myself, why did this fish do this to me?

The hook on this line was only a #4 Mustard live bait hook - that you can buy 50 to a package for under $10 at Wal-Mart or K-Mart.

This was going to be a whole new "ballgame". I’m going to have to be "gentle" on the drag – or he’ll bite through the trilene, or pull the hook.

As it turned out, I eventually got this YFT to color after over one hour. I experienced the same cramps as before, and at one point – on this fish – I thought about "giving up".

It wasn’t the fact that I get $6 a pound for the fillet (from my restaurant friends) that kept me at the rail, but the thought of cutting a YFT off was out of the question.

After gaffing this 70# YFT and pulling him over the gunwale, I trolled by Robbie (who stayed until 7PM and caught not a one) and waved – saying I’m going home.
True Story.

THE END
Capt. Solo – aka Tom AzzaraBoat – "the Taxman"Nassau, BahamasBritish Commonwealth territory(not part of the "East Coast")

Tom's Fishing Gallery.
http://endtaxes.com/images/gallery.html
Take a break, and check out these pictures from the 6th annual Billabong's fishing tournament held in Nassau, in the sunny, tax free Bahamas.
click onto (or browser it) below....
http://endtaxes.com/images/gallery2.html

From: Lee Palm Long Range Sportfishers (more fishing adventures/west coast).
TRIP #14; August 6th to August 11th 5-Day Trip:
The second of the three back-to-back 5-dayers in the Red Rooster III's summer schedule once again provided outstanding fishing for her passengers. Chuck Melber of Agoura CA led the way with a 84.1 lb. bluefin tuna to take the jackpot, followed by a 79.8 lb. bigeye for Justin Christensen of Newbury Park CA and a 73 lb. bluefin for JoeStickles of Orange CA. "It was good consistent action throughout the trip" noted captain Andy Cates. "Some days seemed wilder than others ofcourse, but looking back on the trip I'd say that there was good consistent fishing the whole way through."

The trip fished as far down as Guadalupe Island for some excellent grade yellowfin, but the albacore grounds closer to home yeilded limits of the longfins and a good take on the bigger bluefin as well. "We had some really exceptional moments," noted co-captain Jeff DeBuys, "but nonequite as surprising as the second-place jackpot bigeye landed by Justin . When we got that puppy to color we knew we had foundsome quality fishing for our guys. It was definitely a notable fish, and in the end it added nicely to our trophy bluefin count." This,combined with the quality-sized albacore had by all, gave the Rooster yet another in her long string of exceptional long range adventures.

FISH COUNT: LIMITS OF ALBACORE, 52 BLUEFIN TUNA, 49 YELLOWFIN TUNA, 45YELLOWTAIL AND 1 BIGEYE.

Need an Offshore Sales Office in a Tax Free Environment?

$5 trillion in assets worldwide is held "offshore" in tax havens the IRS writes on their website: “It is difficult to quantify the amount of assets being held offshore or the rate at which the industry is growing. But it has been estimated that some $5 trillion in assets worldwide is held "offshore" in tax havens. Presumably transfers from the U.S. Represent a large share of this wealth. One authority has estimated the annual revenue loss to the U.S. At a minimum of $70 billion.”

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 detailshttp://www.geocities.com/taxhavens123/caribbeantaxhavens.html
A Tribute in Honor of: Bank Confidential Ordinances in the Caribbean
http://www.geocities.com/taxhavens123/bank_confidentiality.html

IRS CIRCULAR 230 DISCLOSURE

To the extent this document constitutes tax advice subject to Circular 230this tax advice was not intended or written to be used and it cannot be used by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer. (The foregoing legend has been affixed pursuant to U.S. Treasury Regulations governing tax practice).

Dupont Nemours and Roosevelt families build 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 aliens trading in the US stock markets you should not overlook!