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Our compliant structure is crucial for asset protection, deferral of tax, privacy and secrecy because it is legal non-disclosure at the financial institution level and recognized and registered tax compliant at the individual level. We are your "go-to" offshore consultant in 2017.

1) Deferral of tax on carried interest reduces the cost of tax.

Here is how to extend the tax holiday on carried interest retained offshore.

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

Hedge fund principals know that deferred management and incentive fees retained offshore would become subject to tax in the 2017 tax year, whether or not funds are repatriated.

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.

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

2) Deferral of Gains and Accumulations Reduces the Cost of Tax Coming up in 2017 we have the ''Son of FATCA'' which is the Automatic Exchange of Financial Information (AEoI) i.e. over 130 countries. This type of account is carved out as exempt from financial information reporting at the Institutional level and reporting of beneficiaries are excluded. This deferral of gains and accumulations account is formally recognized under the Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), Automatic Exchange of Information (AEoI) and specifically mentioned in Double Tax Agreements (DTA) and Intergovernmental Agreements (IGA); which means it checks all the tax and regulatory compliant boxes in the USA, OECD (including Canada, Mexico, the E.U.) and throughout Asia.

This compliant structure is crucial for asset protection, deferral of tax, privacy and secrecy because it is legal non-disclosure at the financial institution level and recognized and registered tax compliant at the individual level.

The solution then becomes, ''How to make this government regulated, tax rules compliant and excluded account is a financial account that individuals can use to defer income on gains and accumulations?''

The Only Foreign Financial Account that U.S. Persons can use for Deferral of Income and Carried Interest on Capital Overseas

This deferred income international retirement plan is formally recognized under the Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), Automatic Exchange of Information (AEoI) and specifically mentioned in Double Tax Agreements (DTA) and Intergovernmental Agreements (IGA); which means it checks all the tax and regulatory compliant boxes in the USA, OECD (including Canada, Mexico, the E.U.) and throughout Asia.

Additional Benefits:

• Deferring income on gains and accumulations reduces the cost of tax
• Deferring income can reduce social service cost of employees by 1/3 to 1/2
• Increase investment yield without an increase in risk
• Exclude investments from worldwide taxable assets
• Convert pre-tax profit into a tax deductible business expense
• A capital deductible and capital raising solution
• Tax free environment overseas
• No exposure to domestic or foreign country tax

We provide a turn-key facility for deferred income credential status globally; while you keep command and control of your own business.

Our Alliance constructs IRC 402(b) compliant deferred income retirement plans in a way that is optically good for U.S. Persons and U.S. Dollar transactions that is registered and recognized in the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) as an excluded from reporting and exempt beneficiary financial account.

This style 402(b) ''Exempt Beneficiary'' plan is income deferred on gains and accumulation. It is a foreign government regulated, registered and recognized retirement plan that is also acknowledged in the Foreign Account Tax Compliance Act (FATCA) as an exempt from withholding and an exempt beneficiary account. The member does not file a W-9 because the administrator of the plan files a W-8BEN-E box 29e.

The automatic exchange of financial information is data collection to counter parties for the purpose of worldwide taxation. There are rules on data collection and there are no rules on data management.

To receive access to your copy of the "Offshore Capital Structure White Paper" click here.

Your investment account gives you control Control over your financial situation is only what your investment account allows it to be. Control is owning a foreign investment account that is a deemed professional investor, foreign resident and non-U.S. Person. When you have done that, then you are in the clear and you do not need to explain yourself any further. Whether you are or are not a U.S. Person is exempt from foreign financial institution reporting; which means there is no U.S. Person blockage overseas.

Tax effected yield ''turbo-charges'' future values You want to save for retirement. Well, doesn't everybody? Then construct a foreign retirement plan registration that is integrated with your Self Directed IRA that has tax effected yield.

Control is this IRS and FATCA category foreign investment account entity The Internal Revenue Service, the U.S. Treasury and FATCA acknowledge this foreign investment account entity's FATCA reporting exemption on IRS Form 8957 and on W-8BEN-E. That all means you are free to deal without U.S. Person restrictions, restraints or blockage to investments globally.

Your IRA tax effected yield “turbo-charges” accumulations; which means higher after tax gains. Internationally recognized exempt entity This exempt reporting credential is also documented in Intergovernmental Agreement (IGA), Tax Information Exchange Agreements (TIEA) and Double Tax Agreements (DTA) which all define it exactly and other investment entities are not even mentioned anywhere. Tax effected yield ''turbo-charges'' future values You want to save for retirement. Well, doesn't everybody? Then construct a foreign retirement plan registration that is integrated with your Self Directed IRA that has tax effected yield.

Implementation provides:

• a foreign investment account Ordinary or Roth IRA
• access to all investment sources globally for income from capital which is the whole point and purpose of all retirement plans in perpetuity

The result of holding this specific foreign investment account is:

• no Unrelated Business Income Tax or Income (UBIT or UBTI)
• recognized exempt from tax in Common, Civil and Sharia law

The intended use of this recommendation is:

• to provide multi-jurisdictional investment choice without U.S. Person investment restrictions, restraints or blockages.
• to comply with disclosure reporting, tax compliance.
• to provide statutory asset protection acknowledged by the IRS.

A relevant foreign investment account must provide at minimum:

• Choice and control over investment class, type, currency and securities market
• No U.S. person restrictions, restraints or limitations
• Full disclosure reporting.
• Recognized asset protected by foreign domestic law, Double Tax Agreement (DTA) and Tax Information Exchange Agreement (TIEA)
• Pension law that preempts securities regulatory law
• Safety & Security in a multi-jurisdictional “Triangle of Security”
• An investment account pre-qualified as a professional investor
• Operational use to investment dealings both from inside or from outside the USA
• U.S. Person access to investing in the same manner as a tax-free foreign resident
• This puts your qualified plan assets under your control without a change in your tax consequence. and you will be able to purchase from offshore any registered, regulated and recognized security globally as a foreign investor.

Tax and regulatory protection is an ORS402(b) occupational pension which is Hong Kong Government regulated, registered and recognized by the People’s Republic of China (PRC). Contact us now about "How to move your 401k assets into an IRA offshore.

Contact us today for the corresponding white paper - 402(b) and/or a free consultation.

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