Dear ,

Global Currency Reset (GCR) has 37 million references on Google. We don't make predictions of when the GCR will happen, we only predict that it will happen, and you will NOT be forewarned.

Canada and other countries are buying BitCoin to hold in Reserve. Banks are buying BitCoin and NYSE & TSX have embarked on trading this new instrument. Necessity is driving the use of BitCoin and the writing is on the wall. Cryptocurrency is here to stay.

We are BTC Big-Block Trading experts, with "Proof of Coins" (POC), now seeking Billionaire BitCoin Buyers with "Proof of Funds" (POF).

Outcome: 402(b) style Clean Nominee Bank Account trading is crucial

1. Trading is pre-authorized AML & KYC
2. Trading is tax law free
3. Trading is securities law free
4. Trades are tax free roll-up
5. Trades are exempt from tax reporting
6. Trades are excluded from tax liability
7. Account withdrawals in cash can be subject to capital gains tax

Operational trading with regulatory exemption.

How your operational trading, with regulatory exemption, would occur within the retirement plan or a part of a network is detailed after the Letter of Engagement and Fee Invoice are completed.

Background reasons registered security or exempted from registration is crucial: The Securities and Exchange Commission (SEC) has defined who can have liability in an unregistered offer of securities that is not exempted: "Those who have a necessary role in the transaction are held liable as participants".

So, for example, it will be illegal for a broker, dealer, or exchange to effect any transaction in a token which is a security unless the offering and sale of the security and the relevant exchange it is traded on are either registered or exempted from registration.

The SEC position of interest to all proponents of a token sale: "The touchstone of an investment contract [Note: an investment contract is a kind of security, and the SEC concluded that The Decentralized Autonomous Organization (DAO) was an example of an investment contract] is the presence of an investment in a common venture premised upon a reasonable expectation of profits to be derived from the entrepreneurial or managerial efforts of others."

Regulatory focus on ICO's:

There is increased regulatory focus on ICOs. Just to recap in very basic terms – the regulations we are dealing with differ between the various jurisdictions, but all are directed at the same policy objectives, namely investor protection from abuses that were rampant around the world before regulation was introduced.

Globally recognized government regulated, registered occupational retirement law is exempt from insurance and securities regulations, thus eliminating additional capital raising costs, while providing added tax benefits to your clients. Your investors will not be subjected to taxation within this Clean Nominee Bank Account structure.

This represents the ability to seamlessly invest and trade capital offshore through a prequalified deemed compliant KYC & AML retirement Trust that is approved secret and private by Governments. Clients can enjoy the benefit of accruing value tax-free and ultimately distributing the income to the member on a tax-exempt basis in many jurisdictions. Occupational retirement laws innovative solution enables issuer's to have a legal vehicle for their existing or new investment products. The investment products can range anywhere from cryptocurrency, real estate acquisitions, developments, forex, equities, mutual funds to commodities.

This is tax and reporting compliance that Governments enforce because they recognize it is excluded from financial reporting and an exempt beneficiary account. Appointing an offshore management company to provide investment services increases tax compliance risk Imagine a scenario in which a Hong Kong-based hedge fund manager establishes and appoints an offshore management company to provide investment management services for its fund. On one hand, the fund’s structure ensures a clear operational base. But at another level, key governance procedures are often neglected and tax compliance is at risk.

An offshore company comes at a steep price and exposes the fund manager to tax liabilities in the manager’s onshore jurisdiction. This is especially true in today’s environment, in which regulators and tax authorities everywhere are taking a closer look at the substance of offshore management companies by means of government foreign financial account exchange of information agreements.

It is imperative to get the tax compliance substance right. Not addressing the corporate governance and operations of the offshore management company is a far riskier proposal today than it ever was. Governments around the world are casting their tax nets far and wide, it’s an opportune time for fund managers to carefully assess their offshore structures and ensure that there is substance to them and not a mere shell.

How to mitigate tax compliance risk

So, how does a Hong Kong investment manager minimize exposure to tax risk? Merely setting up a fund manager in an offshore jurisdiction such as the Cayman Islands is not a sufficient structure to ensure tax compliance and increases the risk. Regulators have highlighted the risk of that approach.

First, ongoing questions from tax authorities point to concerns about central management and control issues regarding the fund, as well as the need to properly demonstrate that there is real substance to the offshore business structure.

By substance, we mean maintaining a proper operational structure that keeps the fund manager’s operations outside of the tax framework of the onshore entity. In other words, the offshore structure should be a government regulated, registered and recognized entity that meets compliance requirements and avoids tax liabilities.

Cryptocurrency trading is a registered security or exempted from registration: The Securities and Exchange Commission (SEC) has defined who can have liability in an unregistered offer of securities that is not exempted:

"Those who have a necessary role in the transaction are held liable as participants". So, for example, it will be illegal for a broker, dealer, or exchange to effect any transaction in a token which is a security unless the offering and sale of the security and the relevant exchange it is traded on are either registered or exempted from registration.

The SEC’s final word:

"Those who offer and sell securities in the United States must comply with the federal securities laws, including the requirement to register with the Securities and Exchange Commission (SEC) or to qualify for an exemption from the registration requirements of the federal securities laws.''

''These requirements apply to those who offer and sell securities in the United States, regardless whether the issuing entity is a traditional company or a decentralized autonomous organization, regardless whether those securities are purchased using U.S. dollars or virtual currencies, and regardless whether they are distributed in certificated form or through distributed ledger technology.

Register as a national securities exchange or operate pursuant to an exemption from registration.

[Note: blockchain is a particular type of distributed ledger technology (DLT)]. In addition, any entity or person engaging in the activities of an exchange, such as bringing together the orders for securities of multiple buyers and sellers using established nondiscretionary methods under which such orders interact with each other and buyers and sellers entering such orders agree upon the terms of the trade, must register as a national securities exchange or operate pursuant to an exemption from such registration."

Invest Offshore Solution:

The Clean Nominee Bank Account is not a tax haven, insurance product, company or a personal trust. International recognition is carved out under the Foreign Account Tax Compliance Act (FATCA), carved out under Common Reporting Standard (CRS), Automatic

Many countries have laws imposing secrecy on information about retirement plans and this is in essence why FATCA allows for the ‘limited conditional’ category.

By their very nature, retirement plans are viewed and governed differently. There are sanctions on dealing with retirement plan information which only a Regulator can decide on. There are so many organizations with powers of search and seizure these days that might otherwise demand access to sensitive information. Preventing this is important because retirement plans are proprietary.

Moreover, the US Treasury has formally determined that pensions carry a low risk of tax evasion and they are therefore exempt from FATCA reporting.

Simplified Tax Reporting

The rule is simple: no W8 BEN-E, no transactions in U.S. dollars, but what exactly is a W8 BEN-E Declaration? A W8 has been in existence for a long time. It is a declaration by a non-U.S. individual concerning their tax status for U.S. tax purposes. The W8 BEN declaration used to be very simple: a foreign company would declare that it was not a U.S. company, not U.S. controlled and that it didn’t have U.S. income. This was all that was necessary to allow any foreign company's U.S. counterparty to remit gross income rather than deducting the required amount.

This has all changed since the introduction of FATCA, which has resulted in the introduction of the new W8 BEN-E declaration. Unless the investment platform is able to sign a W8 BEN-E on behalf of the individual, they cannot be party to any U.S.-dollar investment without having some level of FATCA registration.

The FATCA status ‘limited conditional’ means that the institution is exempt from reporting because it is deemed to be compliant and restricted information secrecy laws override FATCA.. This is explicitly for foreign retirement plans as exempt beneficial owners and also for administrators of FATCA identification number pension funds.

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A Clean Nominee Bank Account structure is not an off-the-shelf product and can be tailor-made in compliance to a statutory tax law mechanism and the clients financial situation.

How To Extend The Tax Holiday On Carried Interest

1. Private Equity because they could be caught by the carried interest definition and three year tax holiday; which means they could suffer to pay tax on money not yet received
2. Captive Insurance Passive income solution
3. Hedge Fund specific solution to continue deferral of carried interest.

Private Equity caught by the carried interest definition; which means they could pay tax on money not yet received.

This structure extends the tax holiday indefinitely.

This structure makes overseas passive income rules irrelevant.

That means the top marginal tax rate applies to overseas passive income because the general tax rate deductions and the new participation exemption rules reductions do not extend to Passive income and gains. (See 4501 and 1297)

The 2018 ''participation exemption'' in tax law changes makes the way an American Company financed their business no longer tax neutral.

Carried Interest

• The Tax Reform Act did not eliminate the tax advantages of carried interest but instead adjusted the holding period for private equity funds and real estate partnerships.
• The Act treats carried interest gains on partnership assets held for three years or less as short-term capital gain and as long-term capital gain if held more than three years. The three year timeline limitation begins at the start of the Fund.

The non-contentious part of that limitation is repatriation of carried interest for Corporations and Funds. Funds will suffer a ''double whammy'' of taxation and loss of yield. Which means funds not only kiss investor money away and suffer a huge tax bill.

Summary of 402(b) solutions for the 2018 overseas tax problem.

1. Extend the tax holiday on private equity, hedge funds and stock options.
2. There are no time limits to a tax holiday

• Removal of a promise by a US tax indifferent entity to pay a carried interest and replacement with a possibility of later payment
• In exchange, the certainty of taxation in 2018 is replaced by the certainty of taxation sometime later: in other words, deferral

The economics

• Tax deferred is tax saved
• The return on deferred tax is always better that the return on the 457A after-tax residue

The legal framework

• Use of a 402(b) compliant non-qualifying unvested deferred compensation plan organized under Hong Kong law with existing hedge fund clearer's as asset-holder of the plan
• Transfer of existing carried interest assets to the plan by the existing US tax indifferent entity as plan sponsor
• Vesting schedule by means of a generic award plan by which plan administrator decides on allocation to plan members, which is a tax event.

Additional benefits

• By-passes probate, useful for business succession planning
• Creditor-proofing
• Not a discretionary trust and 409A and 83 compliant

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