| The 100 year old investment-banking firm of | | | | link 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, Hong | | | | the 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. capital | | | | The Old Monied Dupont Nemours and Roosevelt |
| gains taxes. | | | | Families Buy a Tax Haven |
| | | | |
| Under the U.S. Tax Code, only when a foreign | | | | Want to know why and how the old monied Dupont |
| company, foreign trust or nonresident alien individual | | | | Nemours and Roosevelt families were able to buy |
| takes up permanent residence within the United | | | | 4,000 acres of waterfront property on the island of |
| States will he be subject to U.S. capital gains taxes in | | | | Provindentcials 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 in | | | | This 4,000 acre sale (now a marina and resort town - |
| a trade or business within the United States" are | | | | with an airport for jumbo jets (the $50,000,000 |
| exempted from tax under IRC Section 871 and IRC | | | | airport 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 being | | | | Source: A Turks & Caicos Government 3 full page |
| "engaged in a trade or business within the United | | | | advertisement in Investor's Daily (1985). |
| States". Under U.S. regulations, a nonresident's Stock | | | | |
| Market transactions carried-out through a U.S. stock | | | | Was this the most profitable real estate investment |
| broker, independent agent, or an employee are not | | | | of the 20th century? A quarter acre lot in the gated |
| considered to cause the nonresident to be "engaging | | | | community 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 gains | | | | Do 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 liability | | | | BILLION dollars today. |
| (indirectly) if the offshore company is a "Controlled | | | | |
| Foreign Corporation (CFC) (i.e., "more than 50% of | | | | YOU BE THE JUDGE.... Are the use of the world's tax |
| voting and non-voting stock is owned by US | | | | havens a blessing or a detriment? Before you |
| SHAREHOLDERS). See sections 951 thru 958 of the | | | | answer, 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 taking | | | | should not overlook! |
| more risks (generally) than a foreign non-resident alien | | | | |
| (not a US citizen). Whether an American citizen | | | | Tom has lived offshore in the Bahamas for over 10 |
| taxpayer will have a tax liability on the offshore | | | | years. When I'm not working on my newsletter, or |
| company profits depends on a lot of things - including | | | | with a client, I'm out swimming, diving or sport fishing |
| what kind of income is produced by the company | | | | in the sunny- tax-free Bahamas. |
| (i.e., Subpart F or non-Subpart F) and how many | | | | |
| shares in the company you own, and whether the | | | | Call me at 242-327-7359 with your questions. - 9AM |
| offshore company is a CFC - as defined in the | | | | to 5PM - New York time zone is best.Tom |
| Internal Revenue Code in Sections 957 and section | | | | AzzaraNew 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 the | | | | 327-7359email: taxman@batelnet. |