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Showing posts from May, 2019

Flag Theory aka The Perpetual Traveler

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This week, I did my first Live Stream interview (https://www.facebook.com/RobertOKrukPage/videos/610478799470904/) and for the first time, I heard of the concept of Flag Theory.
What is Flag Theory?  According to Wikipedia, Flag Theory is a term used to describe the perpetual traveler.  An idea which proposes that individuals live in such a way that they are not considered a legal resident of any of the countries in which they spend time or operate. By lacking a legal permanent residence status, the theory goes, they may avoid the legal obligations which accompany residency, such as income and asset taxes, social security contributions, jury duty, and military service.  The idea has been described as a "late capitalist nomadism".
The perpetual traveler idea has been presented in terms of flag theory, wherein each flag represents one of the legal jurisdictions under which the perpetual traveler operates. The Three Flags Theory is credited to investment pundit Harry D. Schultz, …

10 Countries that are Super Easy to Migrate to (excluding expensive economic citizenship/residency programs)

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EcuadorAustriaBelgiumParaguayCanadaBelizeNicaraguaPanamaMexicoSvalbard (Norway)                  click - https://youtu.be/k9G_jNf0Xkw https://youtu.be/k9G_jNf0Xkw

IRS Announces Higher 2019 Retirement Plan Contribution Limits For 401(k)s And More

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Get ready to save more for retirement in 2019! The Treasury Department has announced inflation-adjusted figures for retirement account savings for 2019, and there are a lot of changes that will help savers stuff these accounts. After six years stuck at $5,500, the amount you can contribute to an Individual Retirement Account is being bumped up to $6,000 for 2019. The amount you can contribute to your 401(k) or similar workplace retirement plan goes up from $18,500 in 2018 to $19,000 in 2019. Catch-up contribution limits if you’re 50 or older in 2019 remain unchanged at $6,000 for workplace plans and $1,000 for IRAs. That means that many high earners and super-savers age 50-plus can sock away $32,000 in these tax-advantaged accounts. If your employer allows aftertax contributions or you’re self-employed, you can save even more. The overall defined contribution plan limit moves up to $56,000, from $55,000. Do these limits seem unreachable? During 2017, 13% of employees with retirement plan…

Thoughts on VAT

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Value Added Tax (VAT) is levied on the sale of goods or services by UK businesses. 
VAT is collected on behalf of HM Revenue & Customs by companies. A company pays VAT to HMRC by calculation the amount of VAT charged to customers minus any VAT they have paid on their own purchases.
All goods and services are either VAT-rated or VAT-exempt. VAT-exempt items include rent, private education, health services, postal services, finance and insurance, and gambling.
A business must register for VAT once the sales exceed £82k (as of 1st April 2015) in a year, or else you can make a voluntary registration even before hitting this threshold.
VAT is charged on goods at different levels. The current standard rate of 20% applies to most items.
A Reduced Rate of 5% applies to many items including mobility aids for the elderly, smoking cessation products (nicotine patches and gum), electricity and gas for domestic and residential use, children's car seats, booster seats and booster cushions …

Loose Filed Forms 5471

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Please read this first - http://www.mooresrowland.tax/2019/04/new-form-14457-voluntary-disclosure.html

Then Read - https://www.irs.gov/businesses/corporations/irs-announces-the-identification-and-selection-of-three-large-business-and-international-compliance-campaigns


On April 16th, the IRS identified 3 additional compliance campaigns



One of them is the - Loose Filed Forms 5471


Practice Area: Withholding & International Individual Compliance

Lead Executive: John Cardone, director of Withholding & International Individual Compliance

Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, must be attached to an income tax return (or a partnership or exempt organization return, if applicable) and filed by the return’s due date including extensions. Some taxpayers are incorrectly filing Forms 5471 by sending the form to the IRS without attaching it to a tax return (or partnership or exempt organization return, if applicable). 
If a Form 5471 is require…

Offshore Private Banking Campaign

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Please read this first - http://www.mooresrowland.tax/2019/04/new-form-14457-voluntary-disclosure.html

Then Read - https://www.irs.gov/businesses/corporations/irs-announces-the-identification-and-selection-of-three-large-business-and-international-compliance-campaigns


On April 16th, the IRS identified 3 additional compliance campaigns



One of them is the - Offshore Private Banking Campaign


Practice Area: Withholding & International Individual Compliance

Lead Executive: John Cardone, director of Withholding & International Individual Compliance

U.S. persons are subject to tax on worldwide income from all sources including income generated outside of the United States. It is not illegal or improper for U.S. taxpayers to own offshore structures, accounts, or assets. However, taxpayers must comply with income tax and information reporting requirements associated with these offshore activities.
The IRS is in possession of records that identify taxpayers with transactions or accounts at off…

Captive Services Provider Campaign - Transfer Pricing

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Read - https://www.irs.gov/businesses/corporations/irs-announces-the-identification-and-selection-of-three-large-business-and-international-compliance-campaigns


On April 16th, the IRS identified 3 additional compliance campaigns



One of them is the Captive Services Provider Campaign


Practice Area: Treaty and Transfer Pricing Operations

Lead Executives: Jennifer Best, director, Treaty and Transfer Pricing Operations; and John Hughes, director, Advanced Pricing and Mutual Agreement

The section 482 regulations and the OECD Transfer Pricing Guidelines provide rules for determining arm’s length pricing for transactions between controlled entities, including transactions in which a foreign captive subsidiary performs services exclusively for the parent or other members of the multinational group.
The arm’s length price is determined by taking into consideration data available on companies performing functions, employing assets, and assuming risks that are comparable to those of the captive subs…