Hi ,

Russian officials recently announced plans to create Moscow into an International Financial Centre (IFC), with the City of London as a strategic partner to achieve this objective. Despite all the squabbling between New York and London for bragging rights, neither is actually home to the largest number of billionaires, that honor belongs to Moscow. The Russian capital is home to 74 billionaires, with an average net worth of $5.9 billion. Meanwhile, Russian billionaires, and mere megamillionaires, are dropping tens of millions of dollars for the most opulent houses in London. Jewelry stores and outrageously expensive boutiques hire Russian-speaking staff, and purveyors of everything from Bentleys to Beluga caviar are happily riding this wave of Russian affluence in a city some are starting to call "Moscow on the Thames".

Please keep the comments and questions coming.

Aaron A Day
Editor

International Retirement Plan, 402(b) is the recommended strategy for a couple from USA who've been living in South America. His wife's dormant 401k (meaning no longer making current contributions) and this USA person (husband) who worked a number of years in Peru where his company provided him with a local Peru pension which works like a 401k (as contributions) were all pre-tax and now after seven years in Peru the Peru government will allow him to take out this money without a tax consequence in Peru HOWEVER, please read on:

"The purpose of this information is to save you and your wife taxes by transferring out both her dormant 401k plan and also your Peru Pension Plan".

• a) She "Rolls" the 401k into a Self-Directed IRA.
• b) Her Self-Directed IRA owns a Limited Liability Company.
• c) LLC sponsors International Retirement Plan, 402(b).

• Real Estate both Domestic and Foreign
• Real Estate State Investment Trusts (REITS)
• Limited Partnerships Public or Private)
• Ginnie Mae Mortgage Pools
• Cash-Money Market Funds
• Domestic and Foreign Stocks, Bonds and Mutual Funds
• Foreign Currencies
• Bankable Precious Metals
• Domestic and Foreign Hedge Funds
• Improved Real Estate
• Previously Invested Hard Assets*
• Managed Futures
• or, any other IRS approved asset

Second Issue is your Pension money in Peru?:
B. You mentioned that you could move out your Peru Pension without a Peru Tax Charge. If that is true than the IRS will require you to add that withdrawal sum to your current years income because of Internal Revenue Code 72(w):
a) IRC section 72(w), provides that if the person did not pay tax on a pension arrangement or its earnings while a nonresident alien, they will have to pay tax on the pension distributions when they receive a distribution after moving to the US.
The treaties generally would not get at this as they provide for taxation in the country of residence at the time of the distribution (and that is only for corresponding plans as defined for each country, not all pension funds. Peru and the USA do not have Tax Treaty "corresponding plans").
b) Therefore, you need to transfer your Peru pension directly into an International Retirement Plan, 402(b).
c) The 402(b) allows payout under Tax Treaty rather than under IRS rules. (Payout is tax advantaged).
Therefore, it is recommended that Moving her 401k and your Peru Pension Plan OUT will save on taxes and provide broader and deeper investment choice. The client rolls over their IRA or old 401K into a Self-Directed IRA. The Self-Directed IRA owns an LLC which holds the assets. The LLC opens an account with an offshore investment firm and invests the asset for growth. But the good idea does not stop there so please continue reading this quote from my USA Attorney:

"The LLC route is tried and true. The best way to shore up the process is to go one further step and have the LLC sponsor an International Retirement Plan, 402(b), and contribute the assets to it. This will create a deferral for employees indefinitely and allow a payout on retirement under the International Plan (Tax Treaty) rather than IRS rules. In other words, it is a transfer to the International Retirement plan which is non-reportable (Form 3520 see attached exemption) as it becomes a 402(b) and is a tax recognized regulated foreign retirement plan for IRS and OECD and EU purposes. The International Retirement Plan network Double Tax Agreement will then also confer deferral and potential tax advantaged payouts"

Request more information about International Retirement Plan, 402(b).

Now, we are going to change direction slightly, and talk about creating your own life policy -- no special tax advantages here (other than generally found in life insurance: (a) tax-free growth, and (b) no income tax on the receipt of the death benefit). However, creating your own policy gives you flexibility regarding how the assets are invested, instead of leaving that decision up to the insurance company.

Life insurance comes in two basic varieties: term and cash-value insurance (which itself has various forms: whole life, universal life, variable life). Cash-value insurance is sometimes simply explained as "buy term, invest the difference." While this explanation is too simple, it does assist the layperson in understanding what cash-value insurance is.

For example, if the monthly insurance premium of a variable life produce is $1,000, $150 of this amount might go to purchase "pure insurance," while the remaining $850 would purchase bonds, stocks, mutual funds, etc. In this way, the life insurance policy has a "cash value" component that grows over time, as the assets inside the portfolio grow. For U.S. life insurance companies, the "$850" (in our example), can be invested only in some of the 10 - 20 mutual funds that are pre-selected by the insurance company -- you have a very limited choice.

However, the benefit to foreign life insurance is that you direct the life insurance company which investments you want inside your policy.

The concept of "foreign variable universal life" can be effectively used even if the client does not own an appreciated assets. The benefit to foreign life insurance over domestic life insurance is one of flexibility: the client has a much larger role in picking the mutual funds and other investments that are part of the variable life contract. For example, if you really like the "ABC" mutual fund, you can purchase foreign variable life insurance, and direct the life insurance company to buy the ABC mutual fund. You simply do not have that type of flexibility with U.S. insurance companies.

A big second benefit, is that foreign life insurance can be obtained at less expensive M&E charges (mortality and expense charges), than a comparable U.S. policy.

Of course, there are various rules that must be followed to ensure that the foreign life contract is valid, among them are the cash-value corridor test, the guideline premium test, and the modified endowment contract test. Our insurance experts can help you to "build your own" insurance policy. The minimum monthly premium is $5,000, or quarterly minimum of $15,000, or yearly minimum premium of $50,000. Please Contact Us for more information.

Request an introduction to an foreign life insurance adviser.

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The Republic of the Marshall Islands (RMI) has one of the finest bodies of corporate law in the world, having closely modeled their laws after the top corporate haven in the world: the State of Delaware. The RMI is a former U.S. dependency in the Pacific Ocean which is now entirely independent.

One of the most innovative and useful business entities provided for in RMI Law is the Series Limited Liability Company (LLC).

The RMI LLC Act provides for the creation of a "series" of segregated asset containers within a Series LLC whose debts and other liabilities are enforceable against that asset container alone. The Act also provides that classes or groups of members can be established. This allows each asset container to be treated as if it were a separate company. Thus, the RMI LLC Act allows for the creation of separate sub-companies within one umbrella limited liability company without the need to create separate entities. The concept is similar to the protected cell companies used by many insurance companies within the U.S. and elsewhere.

Unlike every offshore protected cell company law of which we are aware, there are no special limitations on the creation of an RMI LLC, so it could be used for any purpose except for banking, trust or insurance services.

The Act allows a Series LLC agreement to provide for separate members, managers, interests, business purposes, rights and/or duties with respect to the property or obligations held within each asset container. An asset container can be terminated without affecting the other asset containers within the Series LLC. An asset container can make distributions to its own members without regard to the financial condition of the other asset containers or the umbrella LLC.

Most importantly, the Act provides that debts, liabilities and obligations incurred, contracted for or otherwise existing with respect to a particular asset container are enforceable against that asset container only, and not against the assets of the Series LLC generally or any other asset container within the LLC.

The RMI Limited Liability Company Act provides for Series LLCs in Section 79, from which the following excerpts have been taken:

• ...A limited liability company agreement may establish or provide for the establishment of designated series of members, managers or limited liability company interests having separate rights, powers or duties with respect to specified property or obligations of the limited liability company or profits and losses associated with specified property or obligations, and,
• ... any such series may have a separate business purpose or investment objective.
• ...the debts, liabilities and obligations incurred, contracted for or otherwise existing with respect to a particular series shall be enforceable against the assets of such series only, and not against the assets of the limited liability company generally or any other series thereof...

Another obvious use for the series LLC is to hold multiple properties, businesses or other investments. Forming and maintaining ten separate LLCs would cost several thousand dollars in the year of formation and several thousand dollars each subsequent year. Instead, a series LLC can be used and each property, business or investment can be transferred to a separate series. This would achieve the goal of segregating the properties for asset protection purposes while saving several thousand dollars in startup costs and another several thousand dollars a year in ongoing administrative costs.
AND, if it became appropriate, any Series within the Series LLC could be "spun off" as a separate new LLC

Another use for the series LLC might be to facilitate an equity compensation program in a business with multiple divisions. If each division were segregated into a separate series, the LLC could give the key employees of each series some sort of equity interest tied to that series only rather than equity interests in the entity as a whole. That rewards employees at productive divisions and protects them from the potential downside of another division.

Yet another use for the series LLC might be to make a de facto transfer that avoids gain that would otherwise be recognized on a transfer from one LLC to another LLC. For example, an existing LLC creates a new series within it, then issues 100% of the membership of the series in part for cash, and finally transfers a parcel of the land it already owns to the new Series. If the LLC is respected as a single tax partnership (i.e., the new Series is not treated as a separate partnership for tax purposes), the current income tax gain on the cash portion of the land exchange that otherwise would have been triggered in a transfer to a new LLC will have been avoided. In addition, since the transfer of the land was entirely inside the LLC, depending on local law, there may be no real estate transfer tax on the transfer whereas there may have been tax on the transfer of the land to a new LLC.

RMI Series LLCs can usually be formed within 1 business day. No client information needs to be given to the Registry so complete confidentiality can be maintained.

Request more information about Incredible Series LLC. formation.

Paradise isn't lost, it's still possible to retire in a dream destination, and Invest Offshore can show IRA investors some of the ways to get there with "Offshore Real Estate Investing". The self-directed IRA owns an LLC which holds the assets. The LLC opens an account with an offshore investment firm and invests the asset for growth. We refer to these as IRA LLC's.

Many people may think that offshore IRA real estate investing sounds complicated. Like any other offshore investment, it takes research and due diligence and we aim to provide investors key information to assist with informed decision making. International investment opportunities abound for those with the skill and patience to work their way through the process. Our goal is to educate and empower individuals to take charge of their retirement through the use of self-directed IRAs and tax-advantaged plans. Write to request more information.

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There are four cottages, all impeccably located in the hub of the Caribbean yachting community and are in walking distance to the cafes, bars and restaurants. You will find the historical Nelson's Dockyard is just around the corner, and in the other direction you will find a beautiful white sandy beach just down the road.

This property is ideal for private holiday rental or could be transformed into a tranquil spa retreat or boutique resort. See: Google Map

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