Invest Offshore Newsletter

Published: Wed, 08/31/16

Newsletter Issue #106 Invest Offshore
 
 

August 31, 2016
Offshore Investment Guide

Hi ,

The IRC 402(b) income plan is recognized internationally as a compliant and excluded financial account. We wrote the book on the 402(b) asset protection structure, as a "Users Guide" to the best tax deferred overseas investment strategy and the only offshore freeway.

Contact us today for free consultation and a copy of the IRC 402(b) Exempt Beneficial Owner Users Guide.

Invest Offshore Freeway

Seeking Strategic Professional Partners

Are you a financial planner, advisor, consultant or independent agent?

We are expanding our global partner alliance and currently seeking new team members. Collateral marketing material will be provided.

Summary list of added value services that give reason for you to be the introducer to the IRC 402(b) Trustee.

Exempt Beneficial Owner target marketing:

  1. Capital Deductible Capital Raising (Hedge Fund example)
  2. Deferred Income Investing
  3. Investment Immigration Visa (EB-5 Pre-Immigration tax planning solution)
  4. Converting Royalty to Deferred Income
  5. Converting Profit Sharing to Deferred Income
  6. Raising Capital in the U.S. and E.U. Securities Law Free
  7. Make IRA Investing in an Active Business Not Subject to UBTI
  8. Deferred Income Entity for a Dealer of Capital Overseas
  9. Capital Gain Tax Free in US Real Estate and Infrastructure investments
  10. Give 457A Fund Carried Interest a Further Tax Holiday Beyond 2017

Specific details on (9)

Hedge Funds have a problem with their IRC 457A plans.

The total estimate of carried interest that will be taxed in 2018 is between one billion and one hundred billion.

Since 2009, hedge fund principals have known that deferred management and incentive fees retained offshore would become subject to tax in the 2017 tax year, whether or not funds are repatriated. Internal Revenue Code Section 457A, along with IRS Notice 2009-8 and Revenue Ruling 2014-18, sets forth the particulars for taxation of this deferred compensation. If you are a hedge fund manager who has accumulated a significant deferred compensation balance offshore, 2017 will be a tax year of reckoning. Any funds deferred and held offshore will become subject to tax at your highest marginal tax rates. The imposition of this tax can be avoided.

IRC 402(b) can provide a solution for those 457A plans.

The key to 457A is the promise of a carried interest by a U.S. Tax Indifferent Party.

The 457A has two criteria:

  1. Promise
  2. Tax Indifferent Party

If you have a promise you have current participation and you are taxable.

Remove the two criteria and you no longer have a 457A tax consequence.

The solution then becomes, ''How to make the transition under IRC 402(b) section and compliantly to tax avoidance law?''

The custodian for our current clients IRC 402(b) programs are both Northern Trust, Chicago and State Street Bank, Boston.

This solution requires a technical discussion with Tax Attorneys with experience (DLApiper).


The Only Offshore Freeway

The IRC 402(b) income plan

Income Deferred on Gains and Accumulations

Issue: How many people have enough savings for retirement now?

Today's statistic is that a person over age 50 who loses his job will have a 90% chance of not finding a job.

Please give consideration: to my talking about a pre-tax contribution, internationally registered and recognized, foreign retirement plan that is compliant internationally continuously

has simple one form reporting

is a tax free roll up investment account

is specifically recognized as deferred income on FOUR IRS reporting forms

At this point, many are thinking, ''Why have I never heard of this before?'' and my answer to them is ''You don't know that you don't know because you never read the information sheet on how to complete those FOUR IRS forms!''

At this point just take it that you read the IRS information sheets:

We will show you that investing pre-Tax with tax free roll up means that your retirement savings has two tax affected benefits immediately

  1. increases yield continuously so that future after tax values later beat anyone's yield and
  2. deferring large chunks of income pre-tax you can reach your retirement savings goal

The reason those two benefits are important is because:

Taxing your income later means that your net future value result is much higher, which is the result of tax affected yield increasing the speed to your retirement savings goal and This deferred income plan also permits an increased size of savings contribution to make retirement the best years of your life!

Control over your tax position is only what your investment account allows it to be.

Everyone has heard about a 401k, everybody knows about that, the 401k was never designed in 1974 to be the one retirement fund.

It was designed as a supplement to the old company final salary plan which has gone the way of the dodo bird.

The 401k ceiling on contribution size is too low.

It was never designed to be the one source of retirement income.

There is a ceiling on contribution size which means if you are behind in saving for retirement than you can never catch up!

US-based plans are not globally functional.

A 401k plan requires U.S. sourced employment income.

Do you work overseas? Foreign employment contributions to a U.S. 401k plan are not allowed.

By contrast,

The IRC 402(b) income plan is the one plan that delivers a truly international U.S. and Foreign employee solution to retirement savings without contribution size restrictions and with tax and reporting compliance globally.

This deferred income plan is not new, it was launched by Internal Revenue Service Tax Code back in 1986, Yes 30 years ago, and is recognized internationally as a compliant and excluded financial account. That is what we provide

Ok, So, everyone wants to ask us: what are the benefits your plan delivers to me immediately?

Tax affected yield that beats anyone's yield

what are my benefits along the way?

Simple tax and reporting compliance continuously

what are my benefits down the road?

Reduces the cost of tax by 50% and more

and what are my benefits upon disbursement?

You control your rate of withdrawal at your own retirement life style rate-Go-Go, Slow-Go and No-Go

Get the IRC 402(b) income plan Free White Paper


Bottom for the gold market?

Q: Is there an update on the bottom for the gold market?

A: Yes. On the bullion, it appears that the low was $1045 about 8 months ago. The shares made their lows mostly a month later. Some shares such as ABX, bottomed a half year earlier. It has been a fragmented market pattern.

Q: When do you think will be the best time to use your system?

A: When the shares and bullion are trading together and after a wave 2 corrections to the first up leg.

I expect that to be in the first quarter of 2017. Maybe as early as January. I admit to missing the bullion low at $1,045. I was looking for a contracting five wave diagonal triangle and missed the triple ABC. There will be plenty of opportunity to profit shortly. Wave 2 frequently retraces most of wave 1. Playing the bull market from the start of wave 3 will be safer and can be done without trading in and out. Pyramiding will be in order. Always keep in mind: this is not investing. It is speculation.

The Fixed System

All securities and cash stay with client’s broker or bank. We provide buy and sell orders to client. Client transmits the orders to his bank or broker for execution.

Q: What is the Fixed System?

A: The Fixed System is the application of economic law in a manner consistent with the scientific method to profit from price changes.

Q: What do you mean by scientific method?

A: Using observation to establish facts and then logic to reach useful conclusions that follow from the factually correct premises.

Q: What do you mean by economic law?

A: A useful description of human action related to economic activity. See Human Action by Ludwig von Mises and Man, Economy, and State by Murray Rothbard.

Q: Where do I begin if I want information about how to apply economic law?

A: Start with The Art of Speculation during Civil War — Sun Tzu Meets Jesse Livermore.

Q: These three books amount to over 2,000 pages and the material is sometimes difficult. Do I need to understand all of it before I can use the Fixed System?

A: No, but you'll get better results if you do. If you want to base your speculation on facts and not falsehoods, on valid conclusions and not fallacious reasoning, then read and study these three books.

Q: Which of the three should I read first?

A: Start with the Q&A in Sun Tzu Meets Jesse Livermore (Appendix A). Then read the entire book, then Mises, and then Rothbard.

Q: I understand that all value is subjective and that in a market economy, the current price will be bid up to the expectation of future price less cost of carry. The same process occurs in reverse when market participants expect the future price to be lower. You use four criteria to measure this and to call the low in the gold market: 1. a break to the downside in the general securities market, 2. extremely negative sentiment indicators, 3. ending wave pattern, and 4. specialist short covering. Is all of this part of the Fixed System?

A: Yes. That all value is subjective is a fundamental law of economics. The system is fixed because economic law and facts are fixed. You can ignore the facts and law but you will suffer the results of ignorance never the less. Economic law is just a binding as the law of gravity.

We invite you to request a Arthur Fixed Consultation at your convenience.

by Arthur Fixed

The Art of Speculation during Civil War

Invest Offshore

 

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Disclaimer: This document was produced by and the opinions expressed are those of Invest Offshore as of the date of writing and are subject to change. It has been prepared solely for information purposes and for the use of the recipient. It does not constitute an offer or an invitation by or on behalf of Invest Offshore to any person to buy or sell any security. Any reference to past performance is not necessarily a guide to the future. The information and analysis contained in this publication have been compiled or arrived at from sources believed to be reliable but Invest Offshore does not make any representation as to their accuracy or completeness and does not accept liability for any loss arising from the use hereof.

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