| The 100 year old investment-banking firm
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| | More on the No-tax haven of Anguilla.
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| of Warburg, Dillon Read (on Park Ave.
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| | Click onto the link below for the details
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| N.Y.) (now UBS Warburg) has offices in 39
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| foreign countries - including the
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| Bahamas, the tiny Cayman Islands, Hong
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| | A Tribute in Honor of: Bank Confidential
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| Kong and the Channel Islands. Makes you
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| | Ordinances in the Caribbean
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| wonder why, doesn't it?
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| Non-resident foreign companies, trusts,
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| banks and individuals can trade stocks,
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| bonds, commodity contracts and options
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| 100% free from U.S. capital gains taxes.
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| | The Old Monied Dupont Nemours and
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| | Roosevelt Families Buy a Tax Haven
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| Under the U.S. Tax Code, only when a
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| foreign company, foreign trust or
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| | Want to know why and how the old monied
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| nonresident alien individual takes up
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| | Dupont Nemours and Roosevelt families
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| permanent residence within the United
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| | were able to buy 4,000 acres of
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| States will he be subject to U.S. capital
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| | waterfront property on the island of
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| gains taxes in the same way as domestic
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| | Provindentcials in the tax free, crown
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| taxpayers. For a corporation permanent
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| | colony (or "Overseas Territory") of the
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| residence would be a U.S. office or
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| | Turk and Caicos Islands for 1 cent an
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| warehouse. Capital gains realized by
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| | acre?
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| foreign corporations and other
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| nonresidents "not engaged in a trade or
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| | This 4,000 acre sale (now a marina and
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| business within the United States" are
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| | resort town - with an airport for jumbo
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| exempted from tax under IRC Section 871
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| | jets (the $50,000,000 airport was donated
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| and IRC Section 881 & IRC Section
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| | by the UK government) went down in the
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| 897(c)(3). Moreover, U.S. Treasury
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| | 1970's - not the 1870's!?!?
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| Regulations Section 864-2(C)(1) & (2)
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| provides an exception for what embodies
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| | Source: A Turks & Caicos Government 3
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| being "engaged in a trade or business
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| | full page advertisement in Investor's
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| within the United States". Under U.S.
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| | Daily (1985).
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| regulations, a nonresident's Stock Market
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| transactions carried-out through a U.S.
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| | Was this the most profitable real estate
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| stock broker, independent agent, or an
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| | investment of the 20th century? A quarter
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| employee are not considered to cause the
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| | acre lot in the gated community of
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| nonresident to be "engaging in a trade or
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| | Sandyport here in Nassau, Bahamas sells
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| business within the United States".
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| | for approximately $260,000 today. Half
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| | acre canal lots in Lyford Cay sell for
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| Publicly traded stock market gains (from
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| | about one million dollars.
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| NYSE, NASDAQ or AMEX listed stocks and
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| bonds) accruing to an offshore company
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| | Do the math. On an initial investment of
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| are free of US capital gains taxes by the
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| | just $40, the 4,000 acre property might
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| Internal Revenue Tax Code's statutes, but
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| | be worth almost 4 BILLION dollars today.
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| "US Shareholders" can have a tax
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| liability (indirectly) if the offshore
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| | YOU BE THE JUDGE.... Are the use of the
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| company is a "Controlled Foreign
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| | world's tax havens a blessing or a
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| Corporation (CFC) (i.e., "more than 50%
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| | detriment? Before you answer, see some of
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| of voting and non-voting stock is owned
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| | the IRS's loopholes from our "Tax Code" -
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| by US SHAREHOLDERS). See sections 951
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| | discovered for your viewing below, and
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| thru 958 of the IRC. See especially
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| | buried inside the tax law for the
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| Code-Section 951(b) for the definition of
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| | taxpayers! There's a very important
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| US SHAREHOLDERS.
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| | loophole for the non-resident alien you
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| | should not overlook!
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| American taxpayers that use tax havens
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| are taking more risks (generally) than a
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| | Tom has lived offshore in the Bahamas for
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| foreign non-resident alien (not a US
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| | over 10 years. When I'm not working on my
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| citizen). Whether an American citizen
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| | newsletter, or with a client, I'm out
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| taxpayer will have a tax liability on the
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| | swimming, diving or sport fishing in the
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| offshore company profits depends on a lot
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| | sunny- tax-free Bahamas.
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| of things - including what kind of income
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| is produced by the company (i.e., Subpart
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| | Call me at 242-327-7359 with your
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| F or non-Subpart F) and how many shares
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| | questions. - 9AM to 5PM - New York time
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| in the company you own, and whether the
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| | zone is best.Tom AzzaraNew Providence
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| offshore company is a CFC - as defined in
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| | Estate Planners, Ltd.(Lawyers and
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| the Internal Revenue Code in Sections 957
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| | Consultants)54 Sandyport DriveP.O. Box CB
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| and section 958.
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| | 11552Nassau, BahamasFax/phone: (242)
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| | 327-7359email: taxman@batelnet.
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