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Showing posts from September, 2014

Pre-immigration Planning for Singaporeans Moving to the USA

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Singaporeans are known for being world travelers.  Many Singaporeans visit the U.S.  Some even decide to temporarily / permanently move to the U.S.  Well known Singaporeans in the states include names like Tila Tequila, Sharon Tay, and Neeraj Khemlani.  Careers in the media aside, one would imagine that Singaporeans decide to temporarily / permanently move to the U.S. for varying reasons including –
1.To work – particularly those transferred by an MNC employer; 2.To study in the U.S. at either undergraduate or post graduate level – some decide to remain in the U.S. after   graduation to get work experience in the much larger American market; and 3.To retire - especially for those with family who live in the U.S.

Immigration under any circumstance can be a stressful and confusing time.  Migration to the U.S. can be particularly challenging because of the far reaching financial and tax implications.  To make matters more confusing, the type of visa may also have tax consequences.  Neve…

IRS: Partners' Share Of LLC Income Is Subject to Self-Employment Tax

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So once upon a time, many of us were comfortable thinking that it was possible to have Private equity fund managers take a share of the profits of the partnership as the equity portion of their compensation. The tax rules for compensating service partners created a planning opportunity for managers who receive the industry-standard “two and twenty” (a two percent management fee and twenty percent profits interest).

By taking a portion of their pay in the form of partnership profits, fund managers deferred income derived from their labor efforts and converted it from ordinary income into long-term capital gain.




But now IRS Chief Counsel has issued ILM 201436049 dated 5/20/2014, released on 9/5/2014, which is based primarily on the ruling in the case of Renkemeyer vs Commissioner 136 TC 137 (2011).  It suggests that "Partners earnings are not in the nature of a return on a capital investment, but rather are a direct result of the services rendered on behalf of a management compan…

FBI Charge 6 With Running $500 Million Offshore Laundering Scheme.....Rule of Thumb - If it Seems To Good to be True? Don't walk away....RUN!!!!

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Federal prosecutors charged six men Tuesday with running a complicated offshore scheme that allegedly enabled clients to manipulate stocks, avoid U.S. taxes and launder hundreds of millions of dollars. An indictment unsealed in federal court in Brooklyn alleged the men laundered some $500 million in proceeds from fraudulent securities transactions for more than 100 U.S. citizens and helped commit tax fraud. A person briefed on the probe said the amount of laundered money and the number of clients could be much larger and the investigation is ongoing. The indictment didn’t name any of the U.S. clients. The men—all of whom reside in Belize, according to the indictment—concealed their U.S. clients’ ownership in offshore shell companies over a five- year period. Some of the clients used the entities to mask transactions in order to manipulate stocks, and then launder the proceeds through the offshore accounts, prosecutors alleged. The indictment came after a two-year undercover investigat…

Are Singapore's financial institutions keeping up with FATCA?

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