2019

Crypto-Currencies and Asset Protection

A crucial facet to using foreign trusts to protect wealth is ensuring that the trustee and trust assets remain outside of any jurisdiction where the grantor might be sued. With crypto assets, asset protection may simply involve the transfer of a private key to an offshore trustee (or manager). Properly selected offshore trustees are unlikely to

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Nevis: one of the worlds most secretive offshore havens

In terms of Caribbean jurisdictions, I’ve previously mentioned –  The BVI – https://www.mooresrowland.tax/2019/09/economic-substance-requirements-in.html The Caymans – https://www.mooresrowland.tax/2019/11/economic-substance-in-cayman-islands.html These are the two most popular but there are probably dozens of attractive offshore jurisdictions to consider.  Including Nevis.  The title is derived from an article published in the Guardian in 2018 – https://www.theguardian.com/news/2018/jul/12/nevis-how-the-worlds-most-secretive-offshore-haven-refuses-to-clean-up In the article, the Guardian explains that

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How to Qualify for Foreign Earned Income Exclusion

If you meet certain requirements, you may qualify for the foreign earned income and foreign housing exclusions and the foreign housing deduction. You can use the IRS’s Interactive Tax Assistant tool to help determine whether income earned in a foreign country is eligible to be excluded from income reported on your U.S. federal income tax return. If you

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The U.S. Gift and Estate Tax

We previously wrote about determining status for estate and gift taxes – https://www.mooresrowland.tax/2019/12/determining-status-for-estate-tax.html The annual federal gift tax exclusion allows you to give away up to $15,000 in 2019 to as many people as you wish without those gifts counting against your $11.400 million lifetime exemption. (After 2019, the $15,000 exclusion may be increased for inflation.)

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Combating Aggressive Tax Planning Through Disclosure: A Comparison of U.S. and EU Rules Applicable to Tax Advisors

The efforts to bridge the information gap between tax authorities and taxpayers is ongoing. We have discussed FATCA and CRS before –https://htj.tax/2019/11/fatca-automatic-exchange-of-information/ But aggressive tax strategies remain popular.  They range from sophisticated shelters and structures, to simple nominee arrangements – https://www.mooresrowland.tax/2019/02/avoiding-us-cfc-status-using-nominees.html To that end, over the past several decades, governments have sought to enlist the very

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