Hi ,

The ORSO/402(b) upgrade "structure" took our legal team years to achieve. The U.S. Counsel for this structure has been two of the worlds largest law firms (attorney references available upon request), which is why we know we've got it right!

We're at your service, to meet or exceed your asset protection needs.

This Super Trust, domiciled in Hong Kong, is one of the most tax efficient pension structures available to the private investor. This registered retirement plan is in addition to being a QROPS, also an IRC 402(b). With this Hong Kong based Super Trust the investor has total freedom of investment, category, location and currency choice, all from offshore.

The Super Trust is an “onshore” Hong Kong registered “occupational Retirement Scheme” (ORSO) administered as a Trust under the Mandatory Provident Fund schemes Authority since 27th March 2006. With trusts becoming more expensive, this Super Trust gives a unique tax and pension planning opportunity at fair cost. Due to the HK ORSO tax regime and double taxation agreements, no matter what your residence or nationality the Super Trust can be one for the most cost effective and efficient ways of mitigating tax planning issues. The Super Trust will accept UK domiciled pension transfers and thus take full advantage of the HMRC Qualifying Recognized Overseas Pension Scheme rules.

The Super Trust can hold cash, property, land, mutual funds, stocks, stock options, bullion, private shares, hedge funds and bonds. It can fully mitigate taxes depending on your domicile, on both a current basis and death basis. The Super Trust can accept most foreign based transferred Pensions with no limits. It protects you and your assets against claims from Creditors including government. There is no Income tax, Capital Gains tax, on the underlying funds. No compulsory purchase of an annuity and lump sum payments are available on retirement age.

No tax on the scheme or its member. Reporting requirements costs are significantly less in Hong Kong than elsewhere and that helps to enhance absolute returns on investments. Client confidentiality. Choice for investment assets. No maximum investment restrictions. Mitigation of UK Stamp Duty Land Tax, Capital Gain or Income tax on the transfer of property. No UK IHT, death or estate tax. No profits tax on property traded within the Super Trust.

The Alternatives of Global Retirement Planning with a Super Trust

• The Alternative to Irrevocable Trusts. In fact, this Alternative has NO Attorney Fees
• The Alternative to LLC, IBC and Foundations and Again No Attorney Fees
• The Alternatives to Annuities - No Insurance Company fees!
• The Alternatives to Litigation - Never in front of a Judge or Judgement
• The Alternative to 184 page Tax Filings - You can do this filing in less than 10 minutes.
• The Alternative to a Tax Consultant - No Need.
• The Alternative to the S.E.C. . Why not!
• The Alternative to Forced Heirship - You are the Controller!

Global Retirement Plans can be set-up in USD, EUR, and GBP accounts and provide tax-free savings for you and your staff until their retirement. The main advantages of investing From Offshore is the Geo-Diversification as your investment is not located between San Francisco and New York. Your Outside Located Assets are protected by Governance from Government. Your Offshore located Regulatory Fiduciary requires a Segregated Account, therefor you have no Third Party Banking Risk. Plus. each year you are provided annually a 3rd Party Audit.

The Hong Kong ORS is arguably the most tax efficient pension structure available to high net worth individuals.

Hong Kong has established a rather unique vehicle, the Occupational Retirement Scheme (ORS), and its use is not restricted to Hong Kong. An ORS is capable of attracting pension assets from across Asia, Europe and North America. The ORS structure not only benefits from tax-free pension accumulation but it also works as a tax friendly repository, which is both creditor-proof and extremely flexible concerning the classes of assets it is allowed to hold.

Due to the attractive Hong Kong ORS tax regime and favourable use of double taxation agreements, one’s nationality and tax residency are not relevant to a scheme. Current rules allow for Income Tax and Capital Tax deferral that can operate as a perpetual Trust to assist estate and succession planning, and can accept most transferred pensions and/or registered plans with few restrictions. An ORS also allows a wide variety of assets to be held, giving an ORS trustee discretion to invest in a practically unfettered range of global asset classes.

Hong Kong has a straight forward, legitimate, long existent low tax system with attractive, genuine open pension planning for international and local clientele who wish to have safe/reliable capital to draw on when they retire.

While the effect of efficient pension planning is much lower taxes on your estate, this is not a scheme developed for tax avoidance. Instead, the Hong Kong pension regime will maximise the return on your wealth allowing for the efficient management of pension assets in order to benefit from double-taxation regulations, avoid overlapping taxes, and unnecessary taxation fees through poor future planning and unawareness of taxation law.

The real opportunity for the 402b is to be a start-up company plan in which the management and staff are all participating. The structure would hold the stock of the employees/management, would be pre-tax, and would be funded initially out of monthly employee contributions, and eventually out of performance-related options, grants or company matching payments (like a 401k often is).

The structure may invest in its own company stock, or even other investments because it is company plan, the costs of establishment should be low on a per member basis.

Members like one example who has significant assets and interest in more complex plans, could set up his own plan for those investments. But he is in a position to introduce these plans to the start-ups he helps set up. Furthermore, many of these existing investments he has are in options or zero-value grant shares. In other words, theses new assets really have no market value because the company is just starting up. Therefore, the tax consequences of moving these existing corporate assets into a 402b - a taxable event - might not cost a nickel in some cases, even if the "theoretical" value of the investment once the company meets its targets could be in excess of $1M.

This style of 402b is tax deferred on gains and accumulation. It is a foreign regulated, registered and recognized retirement plan that is also acknowledged in the Foreign Account Tax Compliance Act (FATCA) as exempt from withholding. It is recognized in the O.E.C.D. Common Reporting Standard Automatic Exchange of Information (AEOI) globally as tax rules compliant and exempt non-reporting Foreign Financial Institution and excluded for reporting account.

The money flow must go from the funder to the Anti Money Laundering (AML) Licensed and recognized 402(b) plan registered Occupational Retirement Scheme Overseas (ORSO) and US Global Intermediary Identification Number (GIIN)- regulated Trustee Account that is Automatic Exchange of Information (AEOI) tax rules compliant and exempt; non-reporting Foreign Financial Institution (FFI) and excluded.

So In a start-up environment, top managers are not really concerned about upfront tax liability at all. They would kill for something to protect them from the tax on the capital gains of future investments. Middle managers would be interested in pre-tax contributions out of their monthly pay-checks.

The 402b Opportunity is Now! This structure (type) can serve both classes of members, without challenging fundamental principles.