Need an Offshore Sales Office in a Tax Free Environment?

The 100 year old investment-banking firm oflink below for the details
Warburg, Dillon Read (on Park Ave. N.Y.) (now UBS
Warburg) has offices in 39 foreign countries -A Tribute in Honor of: Bank Confidential Ordinances in
including the Bahamas, the tiny Cayman Islands, Hongthe Caribbean
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. capitalThe Old Monied Dupont Nemours and Roosevelt
gains taxes.Families Buy a Tax Haven
Under the U.S. Tax Code, only when a foreignWant to know why and how the old monied Dupont
company, foreign trust or nonresident alien individualNemours and Roosevelt families were able to buy
takes up permanent residence within the United4,000 acres of waterfront property on the island of
States will he be subject to U.S. capital gains taxes inProvindentcials in the tax free, crown colony (or
the same way as domestic taxpayers. For a"Overseas Territory") of the Turk and Caicos Islands
corporation permanent residence would be a U.S.for 1 cent an acre?
office or warehouse. Capital gains realized by foreign
corporations and other nonresidents "not engaged inThis 4,000 acre sale (now a marina and resort town -
a trade or business within the United States" arewith an airport for jumbo jets (the $50,000,000
exempted from tax under IRC Section 871 and IRCairport was donated by the UK government) went
Section 881 & IRC Section 897(c)(3). Moreover, U.S.down in the 1970's - not the 1870's!?!?
Treasury Regulations Section 864-2(C)(1) & (2)
provides an exception for what embodies beingSource: A Turks & Caicos Government 3 full page
"engaged in a trade or business within the Unitedadvertisement in Investor's Daily (1985).
States". Under U.S. regulations, a nonresident's Stock
Market transactions carried-out through a U.S. stockWas this the most profitable real estate investment
broker, independent agent, or an employee are notof the 20th century? A quarter acre lot in the gated
considered to cause the nonresident to be "engagingcommunity of Sandyport here in Nassau, Bahamas
in a trade or business within the United States".sells for approximately $260,000 today. Half acre
canal lots in Lyford Cay sell for about one million
Publicly traded stock market gains (from NYSE,dollars.
NASDAQ or AMEX listed stocks and bonds) accruing
to an offshore company are free of US capital gainsDo the math. On an initial investment of just $40, the
taxes by the Internal Revenue Tax Code's statutes,4,000 acre property might be worth almost 4
but "US Shareholders" can have a tax liabilityBILLION dollars today.
(indirectly) if the offshore company is a "Controlled
Foreign Corporation (CFC) (i.e., "more than 50% ofYOU BE THE JUDGE.... Are the use of the world's tax
voting and non-voting stock is owned by UShavens a blessing or a detriment? Before you
SHAREHOLDERS). See sections 951 thru 958 of theanswer, see some of the IRS's loopholes from our
IRC. See especially Code-Section 951(b) for the"Tax Code" - discovered for your viewing below, and
definition of US SHAREHOLDERS.buried inside the tax law for the taxpayers! There's a
very important loophole for the non-resident alien you
American taxpayers that use tax havens are takingshould not overlook!
more risks (generally) than a foreign non-resident alien
(not a US citizen). Whether an American citizenTom has lived offshore in the Bahamas for over 10
taxpayer will have a tax liability on the offshoreyears. When I'm not working on my newsletter, or
company profits depends on a lot of things - includingwith a client, I'm out swimming, diving or sport fishing
what kind of income is produced by the companyin the sunny- tax-free Bahamas.
(i.e., Subpart F or non-Subpart F) and how many
shares in the company you own, and whether theCall me at 242-327-7359 with your questions. - 9AM
offshore company is a CFC - as defined in theto 5PM - New York time zone is best.Tom
Internal Revenue Code in Sections 957 and sectionAzzaraNew Providence Estate Planners, Ltd.(Lawyers
958.and Consultants)54 Sandyport DriveP.O. Box CB
11552Nassau, BahamasFax/phone: (242)
More on the No-tax haven of Anguilla. Click onto the327-7359email: taxman@batelnet.