Dear ,

The purpose of this email is to describe both the legal and banking cash flow; how money moves to the Clean Nominee Bank Account. The legal cash flow provides a tax free roll-up which increases yield.

What is your current regulatory reporting and tax position?

Everything is subject to reporting and tax except that which is specifically in government and governance documents stated that it is not subject to reporting and tax.

This Clean Nominee Bank Account is exempt from Financial Institution reporting and the end beneficiary is deemed tax compliant. The legal term documented is a ''non-reporting financial institution and exempt beneficiary financial account''.

Verbal words are of no use to prove reporting and tax compliance to Automatic Exchange of Financial Information , Anti-Money Laundering (AML) & Know Your Customer (KYC) rules or any Country Tax Counsel, International Tax Counsel, Hong Kong Tax Counsel, Bank, Financial Institution, Clearing Bank or Custodian.

Financial Action Task Force (FATF) rules extends to everybody and leads to freezing up non-compliant banking, people and businesses. Banks are scared of a hiding and therefore only accept transfers from compliant financial institutions.

Anti-Money Laundering (AML) & Know Your Customer (KYC) rules include but are not limited to proof documentation in these areas:

1. An explanation by contract, service agreement or other documentation of how the money was earned. For example services performed, product delivered or other as document description between you and the party paying these funds

2. Documentation showing exactly from whom and from where the money is coming

3. Documentation on the source of funds

4. Documentation of the tax jurisdiction of anyone connected to the money as receiver or beneficiary.

For lack of a clean AML & KYC no financial institution would transfer or receive money or bank instruments. In the past few weeks alone I had three experiences of rejected AML & KYC; which means an attempt to transfer or receive is blocked continuously.

1. 90 million blocked

2. 450 million blocked

3. 1.5 Billion blocked

There are uncountable sums of money blocked inside of banks. Action to block money increased since the enforcement of the Automatic Exchange of Financial Information (AEOI), Foreign Account Tax Compliance Act (FATCA) in July of 2014 and the Common Reporting Standard (CRS) began from September 2017.

When a bank would tell you that we have no problem with AOEI, FATCA or CRS is because they only deal with compliant financial institutions; which means the counter-party bank has performed the automatic exchange of financial information , AML & KYC.

We direct your attention to non-reporting financial institution and ''exempt'' in an extensive list of documents sent to you previously.

That list of regulated, registered, and recognized documents includes laws of governments and in Governmental Agreements registered and recognized compliant.

The spoken word alone is worthless to Financial Institutions, Financial Service providers,  Tax Attorney and Accountants in over 200 Countries. Our Clean Nominee Financial Account plan administrator will accept only funds compliant to AEOI, CRS, FATCA, AML & KYC rules and regulations.

When AML & KYC are approved and a legal basis for the Clean Nominee Financial Account has been set-up banking cash flow begins. There is a difference between legal cash flow and banking cash flow. Legal cash flow is the 3rd Party Administrator in Hong Kong. Banking cash flow goes directly to the Clean Nominee Bank Account that is not located in Hong Kong.

Therefore, the legal structure must be set-up prior to the movement of money.

Here is a brief summary of why cash flow is crucial:

The Automatic Exchange of Financial Information (AEOI), Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA) are each a Classification System.

All cross-border cash flows and all foreign financial accounts, both the accounts and the cash flow is reported continuously except the category which is not reported. Account holders, Trusts, Companies and Foundations are reported continuously to the tax jurisdiction of the beneficiary/s. So we look at a classification that is not reported because it is recognized pre-qualified tax compliant.

The largest investors in the world are Occupational Retirement Funds which have a Clean Nominee Bank Account.

This retirement plan represents the ability to seamlessly invest and trade capital by means of an acknowledged non-reporting financial institution and exempt beneficiary investment account recognized tax compliant. This legal retirement plan framework is available to anyone, living anywhere, working in any occupation for the dominant purpose of providing a retirement plan.

The universal anti-avoidance rule for income tax broadly states: did you carry out a series of steps, arrangement or plan for the sole or dominant purpose of obtaining a tax benefit. The sole and dominant purpose is a retirement plan.

The difference between a bank account with a retirement plan label on it and an occupational retirement Clean Nominee Bank Account is defined in AEOI the CRS and FATCA. The International Organization of Pension Supervisors( IOPS's), a 2nd world government, sets down how a government regulated, registered and recognized retirement plan should look, IOPS has defined the qualified retirement plan classification.

A qualified retirement plan is fully regulated by governments, has a registered certificate of zero tax residency, formal and legal recognition worldwide.

The only way to transfer money gross rather than subject to tax is to place a specific type of plan structure between you, your business and the source of the money.

The money flow is described in two ways:

1. Legal Cash Flow- is in Hong Kong. Cash flow never goes to Hong Kong.

2. Banking Cash Flow- is to the Custodian.

This Clean Nominee Bank Account segregates the 3rd Party Administrator and the Custodian (two separate businesses), which means the legal cash flow and the banking cash flow are different.

Our recommendation on legal cash flows is the proposed plan administrator legally receives the money directly rather than recycled through one of the your companies because it raises additional reporting issues if we do it via a company outside the legal framework. The legal cash flow provides a tax free roll-up which increases yield.

The legal flow is fundamental to your regulatory reporting and tax compliant solution because the legal ownership of projects, assets, investments, income and cash are by legal title your retirement plan 3rd Party Administrator.

The retirement plan function as sponsor and investment vehicle does not affect the your command and control of the money. Two separate agreements; management and ownership. The plan administrator has a legal ownership and an obligation to follow your management. Fortified by a grant of proxy the plan administrator would necessarily refer to your management on cash flow and on voting.

The legal flow, is a structure like a triangle, has three segregated parts:

• a) In one corner is the source of the money which flows to
• b) the Plan Administrator which flows to
• c) the Investments, projects and payroll (your taxable income)

The Banking flow, is a structure like a triangle, has three segregated parts:

• a) Source of the money goes to
• b) U.S. Custodian/Administrator to
• c) Investments, projects and payroll

How money is deployed from the Clean Nominee Bank Account is in three parts:

• a) Capital projects
• b) payroll taxable in the year received
• c) investments and accumulations

To summarize:

Description: Clean Nominee Bank Account (IRC 402(b) compliant)

Primary Purpose: Retirement Plan

Function: Non-reporting and exempt beneficiary financial account

Outcome: Instead of having reduced income to invest and losing investment earnings to yearly taxation, you put one hundred percent of the income to work and compound the accumulations at the pre-tax rate of return.

The retirement plan can itself own other businesses and in addition when income from businesses owned or investments comes back into the plan it is deferred income and rolls up free of tax. Capital funding into the plan rolls up free of tax.

The Automatic Exchange of Financial Information world recognizes this cash flow is not income and deemed tax compliant. Any money you withdraw from this plan becomes subject to tax in the year of the withdrawal; which means money re-invested within the plan is not subject to tax and that result is an increase in yield.

Yours sincerely,
Aaron