Hi there ,

Our team is growing, we now have more to offer you. An American Expat Authority has joined us, to provide expert advice on Health Insurance, as well as immigration for people moving overseas.

We love helping people and nothing is more satisfying that helping people make money. That's why we're excited about the Algorithmic Black Box FOREX Trading System called ALBRT (see below).

Please contact me to learn more about what ALBRT can do for you.

Aaron A Day

An analysis of both the Variable PPVLI (private placement variable life insurance) and 953(d) PPVLI. Comparing a Government Regulated, Tax Compliant structure (RAPS) to those Unregulated, non-registered structures. Similar to offshore trusts there are many offshore PPVLI's that need fixing!

1) Nobody sells offshore pure term life insurance (FATCA has no interest in term life policies) and for sure no foreign life company which sells term insurance has a price low enough to match USA Domestic Life Companys. Which means if someone is talking purchase of an offshore life policy they mean most probably a Non-MEC (MEC is a modified endowment contract):

2) All of the ''tax strategies'' are in the Non-MEC Life Policies. A PPVLI Foreign Life Policy offered as a Non-MEC US tax compliant policy has complicated rules to follow that are automatically in the US Domestic Life Company computers but not in the Foreign Life Company Computers such as the following four:

• a) Corridor risk coverage based on age (which simplified means the correct amount of life insurance coverage above the cash value of the policy which varies based on age..age is a moving target)
• b) institutional/non-retail investment funds (meaning there are rules about the types/class of investments which can be held-not likely static)
• c) investment diversification rules..now that is also not static as some investments go up and others go down so the % of the total for any investment is going to change, isn't it.
• d) investor control rules...meaning he has no control over investment choice.

And if any of those 4 rules, at any time, are broken then the policy is considered either a MEC policy or just not a life insurance policy at all from that day forward. Which means it can never again be a Non-MEC policy, can't fix it!...which means from the date of the error taxed as ordinary income, penalties, and interest.

Therefore, there is no such thing as a Foreign Life Insurance Policy that is US Tax Complaint. OH sure there could be a Foreign Life Insurance Policy which was tax compliant when it was issued at 09:57 on February 27, 2002 but then what.......subject to error and for sure a good target for an audit, isn't it. Makes no sense to audit a USA Domestic Life Insurance Company Policy but a Foreign Policy and particularly that Foreign Policies are huge...a PPLI policy is typically more than 10 million.....my goodness, if I was an IRS agent fishing for mistakes and taxes that is where I would look, wouldn't you...

A Trust provides asset protection that is exposed to Judges

IRS Hostility

The U.S. tax system is generally hostile to foreign trusts if there is a U.S. taxpayer involved. The hostility is understandable-trusts interfere with the government's ability to impose or collect tax. As a result, the laws are slanted against foreign trusts. Income is taxed punitively. The right paperwork must be prepared "just so" and filed on time, or massive penalties can result. Distributions to beneficiaries require the trustee to keep complex financial accounting records that satisfy U.S. tax requirements, even if under local laws the record keeping and accounting is unnecessary. U.S. beneficiaries may pay gigantic U.S. income tax bills when they receive distributions. And the government doesn't even have a proper U.S. income tax return for a foreign trust-we have to use Form 1040NR, the tax return for a nonresident individual.

With a RAPS plan the U.S. member reports his account annually on IRS Form 8938 as having Zero Value. Zero Value is reported because it is non-vested. The (PFIC) U.S. Passive Foreign Investment Company rule is irrelevant. Foreign registered Retirement funds are not constrained by S.E.C. Securities law nor do they require an S.E.C. registered broker, dealer or advisor. Investments of a foreign regulated retirement plan are not subject to S.E.C regulations or to U.S. Person investment constraints or restrictions.

NOTE:We recommend that the best way to learn how to invest offshore with a RAPS 402(b) is to schedule a free consultation and invite your tax adviser to join in on the call.

One more time ...Regulated, Registered, Recognized .........there is no other (or better) choice than RAPS! (Regulator Asset Protection Structure).

The Algorithmic FOREX Server named ALBRT (ADX Linearly-Balanced to RSI Trading) is a unique "black box" FOREX trading network of proprietary hardware and software that serves second-by-second FOREX trading instructions to your own currency trading platform. This 6 year old, fully verifiable trading system, trades your account and has no authorization to withdraw or transfer your funds.

ALBRT's algorithms are based on nine different strategic programs (eight proprietary). ALBRT systematically monitors the international currency markets, analyzes 30-years of historical data, incorporates daily charts and live dynamics, and performs thousands of calculations per second across the globe to detect 'outbreaks' in key currency pairs. When the ALBRT algorithms determine that the currency pair outbreak has ended, the server automatically instructs your platform to close positions and re-balance the portfolio.

Results vary depending on tolerance risk settings. Please contact us for actual account statements from myFXbook.

Securities Lending (aka Stock Loans)

Securities Lending is legal and clearly regulated in most of the world's major securities markets. Whether you're looking to raise capital to pay down a debt, make an alternative investment, leverage your existing one, or simply take some capital off the table as a hedge against unforeseen events, we can structure a loan for you.

• Minimum loan size: HK $500,000 (or €50,000)
• Minimum trading volume: HK $200,000/day (or €20,000)
• Deals close fast, usually within 1 week
• Stock loans are non-recourse loans

*NOTE: Previously not offered to US citizens, certain conditions may apply. Please contact us for more information.

Created in 1984, the St. Kitts & Nevis CIP is the longest established program of its kind in the world and requires a minimum property purchase of $400,000 US in an approved development such as the Marriott Residences. Additional Government processing fees are due depending on the size of the family and upon application, buyers must undergo third-party security and medical checks before approval. Processing time to citizenship ranges from 3 to 6 months.

Marriott Residences - Prices starting at $420,000 US

Fully-fitted studios and one-bedroom apartments. Superb quality, built to exacting Marriott standards. Full use of Marriott Resort facilities. Part of a multi-million dollar expansion.

Marriott Residences - Owner Benefits

The Marriott Residences are in a prime beachfront location within the 37-acre St. Kitts Marriott Resort grounds and combine the advantages of a second home with the amenities and personal service of a luxury resort.

As an owner of a Marriott Residence, a wide range of St. Kitts Marriott Resort amenities and activities are available to you including:

• Preferred tee times and fees at the 18-hole Championship Royal St. Kitts Golf Course
• Royal Beach Casino; one of the largest and most luxurious casinos in the Caribbean
• Staffed Business Center with 9 meeting rooms and conference services
• A variety of casual and upscale restaurants and lounges
• Numerous pools and private beach access
• State-of-the-art fitness centre featuring fitness classes, cardio and weight equipment, personal trainer on-staff
• Emerald Mist Spa offering massages, body treatments, full-service hair and nail salon, beach massage cabanas and nourishing skin care services
• Tennis courts, table tennis
• Kids Club with supervised recreational and educational activities
• Concierge services
• In-residence dining
• Retail stores

The Marriott Residences, Citizenship Investment Program brochure, available upon request.

Angra dos Reis - Rio de Janeiro - Brazil

Private, gated community home. For Sale: $299,000

A US & Brazilian Citizen, living in the San Francisco Bay area, has large house with stunning sea view in "Angra dos Reis", a prime vacation area in Brazil situated approximately 70 miles South of Rio de Janeiro (http://www.angra-dos-reis.com/ingles/index.htm). The property is in a gated, private and small community (condominium) with security, a private beach, and common areas cleaning and gardening services. The house, needs some renovation, furniture and appliances.

All documented, clear and subject to verification, appraisals, etc. Property documents, additional photos, house blue prints, etc. are all also available to interested parties.

Request more information about Brazil properties.

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