Hi ,

The Regulator Asset Protection Structures (RAPS) that we've released, have undergone very strict due dilligence, by seperate legal teams, in different jurisdictions. The verdict is in! These new asset protection structures are a transparent, tax efficient and compliant method, to invest offshore.

"Wonder is the beginning of wisdom." ~ Socrates

A Registered Investment Advisor is ready, when you are, to learn how you can use RAPS.

Aaron A Day

402(b) Regulator Asset Protection Structure

Feedback From Legal Compliance Due Dilligence

QUESTION: On the topic of Passive Foreign Investment Company (PFIC) wouldn't it be possible to avoid the draconian PFIC regulation, PFIC filing, PFIC 36.9% annual tax and potential penalties by holding foreign stocks, funds, and other passive investments in an IRA?

ANSWER: There are no tax prohibitions or penalties against investing in a passive foreign investment company by a self directed IRA LLC. IRS Regulations recognize that a tax exempt entity may own a PFIC and do not prohibit such an arrangement. (See http://www.irs.gov/pub/irs-regs/td8750.txt )

Apart from the tax issues, there are two obstacles.

First, it can be difficult for a U.S. investor to buy any kind of foreign security without doing so through a foreign account. Clearly, an S.E.C.registered/licensed USA Broker or Dealer would be in violation of his license to sell Securities not registered with the S.E.C. That is the blockade from the USA viewpoint. From the other side, The Foreign Security provider- foreign registered security or fund doesn't want to get into any disputes with the U.S. SEC or with the securities department of the state where the investor resides. AND MAY NOT WANT to get involved with FATCA withholding and reporting. Thus, the first step for most U.S. investors who want to invest in foreign securities and mutual funds is to solve the Foreign viewpoint that "NO USA PERSON'S OR BENEFICIARY'S ALLOWED!"

1. You can Buy and Sell from wherever you want the security you want (Onshore or Offshore)
2. Your investment choice is NOT a "Fund Menu". Buy any Financial product with an ISIN, or Stock or Bond.
3. You can Diversify your investment currency.
4. Protect your retirement from any potential USA Government requirement to hold US Government Securities.
5. Take full advantage of Institutional Purchasing Power that is usually only available to the super-wealthy.
6. Access the out-performing power of global hedge funds...and do it for far less than the normally-prohibitive minimums.
7. Broaden your asset diversification choice to maximize your portfolio's safety and security.
8. Take advantage of special institutional "only" investment programs.
9. Expand your wealth manager selections both in terms of strategies you'll use for income and capital growth as well as the Global contacts you need to implement them.
10. Take no chances with your money. Diversify does not mean many eggs in ONE basket; it means Different locations, financial institutions, managers etc!
11. Discover that the most lucrative fund managers are Offshore.
12. Pack your portfolio with fund selections from a pool 5 times larger than U.S. funds alone.
13. Expand your portfolio to include international stocks your broker will never tell you about.
14. Take advantage of business and entrepreneurial Funds around the world.

In summary, The IRA Passive Custodian in the USA and an Active Custodian overseas Investment Account. The Tax Deferred Foreign Active Investment Account current value is reported on FBAR and on IRS 8938 the value is reported as "Zero Value" unless a withdrawal has been made during the year.

This particular Foreign Investment Account Administrator is specifically excluded from reporting under FATCA. Therefore the Active Custodian has no USA reporting or withholding requirement. No withholding or reporting requirement is the reason the Active Custodian is willing to open an account for a USA person.

NOTE: There are no USA Person Offshore Fund Choice Restrictions and no PFIC nor FATCA issues.

Free no-obligation consultation, available upon request.

Investment Description

The IQS Futures Fund offers investors the potential to achieve a high rate of return in the medium to long term, while keeping the level of risk within acceptable limits.

The assets of the Fund are traded by IQS Capital Management Limited utilising the IQS Diversified Program. The program trades a diversified portfolio of outright futures contracts, including interest rates, currencies, energy and both hard and soft commodities, using an objective approach which employs a series of computer programs.

Since its inception in 1995 the Program has achieved returns comparable with those of the best performing traders in the industry.

The IQS Futures Fund is the only fund currently managed by IQS Capital Management Limited.

The IQS Futures Fund brochure, available upon request.

The opportunity to become a citizen of Antigua and Barbuda is truly unmatched. A member of the British Commonwealth and world-class destination as evidenced by its growing international population over the last decade, thousands of international travelers visit annually and leave the islands harbouring dreams of having a home here.

Citizenship of Antigua and Barbuda presents diverse benefits such as visa-free travel to over 120 countries including Europe and Canada, and the opportunity to reside in one of the most desirable destinations in the Americas. Relaxed, yet sophisticated, families can enjoy superior education amongst a mosaic of cultures, and the lifestyle is idyllic.

The Government will limit the number of citizenships available each year, and the program will be offered solely to select individuals who invest in approved tourism projects.

Papaya Hotel & Spa will be one of the first approved projects under the Citizenship Investment Program.

Currently Available Fifty five one- and two-bedroom hotel villas will be available for purchase from May 2012. Prices start at $759,000 USD.
How Does The Program Work?
The inaugural Antigua & Barbuda Citizenship Investment Program has been passed by Cabinet and will soon be accepting its first applications. The main criteria of the program are: Minimum $500,000 US investment in an approved property.

Background information and medical certificate required for a thorough security processing. If approved for citizenship, government processing fees will be required of $40,000 US per adult and $20,000 US per child. A final interview will take place in Antigua before citizenship is granted. Passports will be issued for a five-year period. There is a residency requirement of 150 days in Antigua & Barbuda during that five-years.

Invest Offshore is offering you the opportunity to be first to apply for the limited spaces in the new program through investment in Papaya Hotel & Spa villas in Rendezvous Bay, Antigua. Please email us to be added to the Papaya Hotel & Spa Villas reservation list.

The Karatbars group based in Germany, Belize and Thailand are bank-independent trading houses for merchandise and precious metals, especially Gold bullion in the form of a card in small denominations.

Karatbars International is an Internet trading company and its products are shipped worldwide to an expanding list of countries. They offer one of the most extraordinary range of products on the market. "Atasay Sanayi Ve Ticaret AS Kuyumculuk" of Turkey are the producer and supplier of the one-gram gold bars of the brand "ATAkulche".

Karatbars International is listed with the London Bullion Association Market (LBMA).

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