Dear ,

The purpose of a Tax Treaty is to define which of two countries has the rights of taxation. You are now free to invest offshore.

Upon retirement when there is a Tax Treaty with the USA then it is possible for the 3rd Country national to receive withdrawal from his IRC 401a or IRA without tax or a reduced tax from the USA side but that does not prevent the foreign country from taxing the amount received into that country?

Rights of taxation:

In the absence of a tax treaty exemption, nonresident aliens, nonresident alien beneficiaries, and foreign estates generally are subject to a 30% withholding tax under section 1441 on an IRA distribution.

In the presents of a tax treaty exemption from US Tax the foreign country will tax the withdrawal as income. A tax treaty exemption from US tax means that the foreign country of the individual's current tax residency will subject the withdrawal to income tax.

Beware: Foreign taxing authorities sometimes require certification from the U.S. Government that an applicant filed an income tax return as a U.S. citizen or resident, as part of the proof of entitlement to the treaty benefits.

Pre-Retirement Withdrawals:

IRC 401a withdrawals incur a 20% federal tax penalty unless the employee is 59 1/2, dies, retires, is disabled or rolls over the funds into a qualified IRA or retirement plan.

Employees can transfer their funds to 401(k) plans or individual retirement accounts (IRAs) when they switch employers.

However, if an employee switches employers on his own accord, retires before the plan's defined retirement age or needs the money for a financial hardship, the employee incurs a 10% early distribution penalty.

Vesting:

A 401(a) plan allows 100% vesting of funds regardless of an employee's years of service. Any contributions an employee makes and any earnings are fully vested. Some employers link vesting to years of service as an incentive for employees to stay with the company.

Beware: Depending on Country of residency, vesting may subject annual growth to be reported as income. Vested plans are not automatically asset protected from claims, creditors, or court order.

There is no off-the-shelf ORS (retirment plan) product that will deliver all of the below results:

1. Capture company pre-tax profits while providing extra risk protection
2. Business expense deductible retirement plan contributions
3. Employee deferred income capital raising
4. Employee income excluded retirement plan contributions
5. Securitize your company value in the shortest period of time; In which growth is all a tax free roll-up

In which you increase your tax free future income.

Sometimes small businesses are small because they think small.

For example, there’s a “War Chest” strategy that many large companies use. It generates billions in profits pre-tax while providing extra risk protection. This strategy is available to those who want to reap the rewards of ''thinking big'' even if on a small scale.

The news for you here is that all five results above can be achieved with a tailor made ORS402(b) to increase your tax free future capital.

The Power of Compounding Pre-Tax Contributions and Accumulations:

For example, a 10% return over 30 years will produce over 4 times the accumulation of a 5% return.

With tax rates approaching or exceeding 50 percent, interest in tax reduction is high. Many are familiar with the opportunity and the advantages of investing business profits pre-tax.

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 compounds the accumulation at the pre-tax rate of return.

The 130 page User's Guide in Mandarin or English is specifically for persons subject to PRC tax reporting and compliance.

Nearly two-thirds of international tax professionals are preparing for transition to territorial system

NEW YORK, Oct. 13, 2017 /PRNewswire/ — Seventy percent of respondents to a 36^th Annual Ernst & Young LLP (EY) International Tax Conference poll indicated that they believe tax reform is likely to occur within the next six months and 63% are taking action to manage a transition to a territorial system. EY announced the results of the poll conducted during this year’s “What’s after what’s next?” conference, addressing implications of evolving tax regulations in the US and Europe as they may affect corporations.

The survey also found that most concerning to international tax professionals was the potential increase in disclosure, reporting and transparency requirements globally, with 99% of survey respondents anticipating an increase or substantial increase. Even now, the increased need for processes that identify and comply with global reporting changes is challenging.

• More than two-thirds of respondents (68%) have implemented global documentation.
• Ninety-seven percent considered it a burden or significant burden to maintain the business processes necessary to manage changing requirements.

“Tax directors must wear many hats these days as they focus on getting ahead of challenges such as increasing tax controversy, aggressive tax authorities jockeying for revenue and ever-changing transparency requirements globally,” said Kate Barton, EY Americas Vice Chair of Tax Services. “In addition to these demanding technical responsibilities, tax leaders also own the role of tax diplomat, explaining their positions every time the regulatory and policy winds shift. And as the digital age rapidly transforms the relationship between tax authorities and taxpayers, they are also becoming tax technologists – responding to and using new technologies to meet the demands for real time global transparency, accuracy and consistency.”

In terms of the impact of major changes to tax policies recommended by the Organisation for Economic Co-operation and Development (OECD):

• One-third (33%) of respondents anticipate significant impact from European Union’s Anti-Tax Avoidance directives and implementation of the multilateral instrument.
• About two-thirds (64%) foresee significant impact on their businesses from any new digital tax regime.

Forty-five percent rate compliance with changing requirements at the top of their priority list, followed by managing risk (37%). Only 11% put “staying ahead of digital” at the top of their list.

“Keeping up with perpetual changes to international tax laws has become too cumbersome, driving the trend toward enhanced technology and the use of outside services,” said Jeff Michalak, Partner, Ernst & Young LLP and EY Americas International Tax Services leader. “Clients are focused on building or gaining access to the newest technologies that report efficiently and accurately, that respond in real time to new requirements and that automate data and document sharing with services for seamless alignment.”

This year, 73% of survey respondents claimed their global transfer pricing documentation meets the requirements outlined in the OECD’s base erosion and profit shifting (BEPS) project recommendations. This preparedness reflects an evolution from past surveys. Three years ago, 79% of conference respondents projected an impact and only 28% expected to make any changes due to BEPS in the following two years. Yet among respondents that had faced audit issues reflecting BEPS at that time, 60% ranked transfer pricing overall as the number one audit focus area.

About the survey

Among the attendees at the EY 36^th Annual International Tax Conference, the 355 survey respondents represent senior tax practitioners with international tax responsibilities.

About EY

EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities.

EY refers to the global organization, and may refer to one or more of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com.

SOURCE EY

Gold Market Speculation

Blog