
The most common use of a properly structured non-controlled Foreign
Corporation (i.e. one that is typically owned by a Foundation or
Trust) is tax deferred investing. The difference between losing
one third or more in taxes annually and tax-free compounding over
20 or 30 years is so compelling, that no one in their right minds
would choose the former option. Even worse, annual taxes can be
due on profits that have accrued in an investment situation (such
as a real estate partnership), but for one reason or another have
not actually been realized.
Of course, there are government recognised retirement
vehicles in most western countries, but in reality the choices of
investment are limited and the funds can be easy prey for would
be litigants, who have no problem tracking down a potential target's
assets, since financial privacy provisions are non-existent in most
countries today.
U.S. Investors have a special hard time because
of the aggressive nature of U.S. regulators, who are apt to impose
their authority on foreign based investment providers. Many offshore
funds and other investment options are not even open to U.S. persons
and entities. Most of these have a track record way in excess of
what investors (in particular U.S. investors) are accustomed to.
U.S. securities regulations are so onerous, that even offshore investment
companies can be forced to comply with U.S. regulations, if they
accept funds from U.S. based investors. Moreover, U.S. authorities
have been known to harass these offshore investment companies, making
it very unpleasant to try do business under those circumstances.
Many of these companies have therefore decided that they would prefer
not to deal with U.S. regulators and consequently routinely exclude
U.S. investors.
An offshore IBC provides the alternative, since
that IBC is in a jurisdiction other than the U.S., regardless of
where it's managers or officers are domiciled. Consequently, the
offshore fund managers will not be subject to pressure from U.S.
based regulators. However, be warned that many compliance officers
in foreign brokerage and fund companies now will not even accept
a U.S. passport holder as a signatory on the account, even if they
can show they are neither an officer or shareholder of the company.
Sometimes the only way round this problem is to avail oneself of
professional third party account
signatory services.
For those who are currently holding stocks that
have a large built in capital gains, an independently managed non-controlled
Foreign Corporation used in conjunction with a private annuity can
help defer and/or lower those taxes significantly. This strategy,
however, must be implemented before the securities are actually
sold.
To set up an IBC owned by a Foundation for the
purpose of tax-deferred investing order
online now. |