CRS articles published on Linkedin
|
29 |
|
|
|
|
29
|
A dozen loopholes why Democrat-led Congress FATCA reciprocal reporting under will fail
|
Untaxed Financial Institution vs. untaxed Passive NFE. The jurisdictions for CRS are completely different.
|
A waste of effort for OECD to track crypto. Easy to hide your tokens.
* * TO BE PUBLISHED SOON * *
|
|
28 |
Argentina attacks foreign-held assets: Tax planners using trusts to avoid this are like a worm in an apple - to them the world is an apple.
|
Well that didn't take long, at all. Argentina comes after foreign-held savings. "Bring it home" is the message.
|
Argentina - Dec 28, 2019 - Public Emergency Law 27,451 on tax and repatriation of foreign-held assets. Repatriate 5% each year or pay 2.25% p.a. tax
|
Cayman black listed by EU due to deficient Economic Substance legislation
|
27 |
Fake retirement funds... OECD is so naive regarding the easiest CRS loophole.
|
EU Officials Press Treasury Over FATCA Reciprocity Efforts
|
An irrevocable trust for a civil-law jurisdiction client is a shaky house of cards built on quicksand. Rather consider revocable Dutch charities.
|
Global Transparency Forum is crazy to rate US largely compliant on automatic exchange information. OECD ignorant on useless FATCA IGA exchange.
|
26 |
CRS should never have allowed a trust to qualify as a holding Active NFE as it provides a commonly used loophole.
|
CRS: Proceeds from ICO sale make the ICO a Passive or Active NFE? ICO token sales considered financial income? Tokens financial assets?
|
Argentina individual declared foreign assets under attack. What can be done? Hint: irrevocable trusts are not the solution advocated.
|
The 6 categories of Netherlands foundations seem double Dutch to foreign planners. A Stichting is a tax efficient, respectable, flexible structure.
|
25 |
CRS Knowledge Test
|
Clowns at the OECD must fix the broken CRS allowing loopholes.
|
Forced repatriation and surrender of offshore declared assets? Argentinian Halloween arrives just in time.
|
EU Council concludes USA meets EU tax transparency criteria on Automatc Exchange of Information and Exchange on Request.
|
24 |
Hiding your money in the USA from CRS? Is Pasquantino vs. US Govt a practical threat regarding federal wire fraud if evading foreign tax?
|
Is a personal listed ETF a viable CRS avoidance solution or a major misunderstanding?
|
Does the OECD understand how tax evaders exploit the inane CRS exemption of untaxed operational companies as Active NFE ??
|
For CRS, when is a foundation an SPV Custodial Institution? Warning: severe mental gymnastics ahead without answers.
|
23 |
Law firms warp semantics to continue the hoax CRS loophole regarding zero cash value insurance policies
|
How to block FATCA reciprocity for US cash value Insurance
|
CRS question for lawyers - Where is equity interest of untaxed Investment Entities maintained? Determines jurisdiction enforcing AEoI reporting.
|
Reporting Financial Institutions tell the OECD where to stick their CRS anti-avoidance residence-by-investment recommendations.
|
22 |
How to block FATCA reciprocal reporting for corporate bank accounts
|
How to block FATCA reciprocal reporting for trusts
|
Twit promoting circumvention of CRS based on false premise that Hungarian foundations do not have settlors or beneficiaries.
|
U.S. Won’t Be Included in EU’s List of Tax Haven Countries.
|
21 |
How can intangible assets help convert an entity's status to an Active NFE?
|
US-Malta tax treaty on pensions is tax-shelter for wealthy US persons. If you think IRS will let this continue unpunished I have a bridge for sale.
|
Does the Turkish Republic of Northern Cyprus provide opportunity for non-reporting of automatic exchange of Inrformation
|
Part I - Trusts: How USA FIs can easily fall outside FATCA full reciprocal reporting if ever legislated.
|
20 |
Nervous About Trump : EU Fearful of Including U.S. on Tax-Haven List
|
The top 6 CRS loopholes the OECD should whack on the head
|
Naive OECD muppets copied FATCA's Investment Entity definition allowing family-owned entities to be in charge of reporting. IFRS says not so fast...
|
EU to revive money laundering blacklist with new criteria
|
19 |
If your CRS legal opinion concludes the reportable surrender value of a zero cash value policy is nil, get those legal fees back pronto...
|
If assets aren't professionally managed, a foundation with a corporate director is Passive NFE. A trust with corporate trustee is an Investment Entity
|
CRS carve-out of managed Investment Entities is a senseless loophole that needs to be shot down
|
The OECD must explain in kindergarten language two clauses of the CRS that banks invariably get wrong
|
18 |
Argentinian current events may support the argument against the automatic exchange of information
|
Oops, don't drop a CRS clause that makes all the difference whether to report or not.
|
So, you think a foundation is the same as a trust for the Common Reporting Standard? Think again buddy...
|
Thank the lucky stars that Mr Magoo at the OECD allows Broad Participation Retirement Funds to be non-reporting Financial Institutions for CRS
|
17 |
Taiwan can't get away from CRS
|
Why do so many incorrectly believe a corporate director means your entity is a managed Investment Entity? No, no, no. Well rarely yes...
|
Canadian international insurers laughing their heads office at the inane exemption from automatic exchange of information
|
Insurers use batcrap crazy logic to justify reporting a nil value for irrevocable insurance for Common Reporting Standard
|
16 |
Avoided Common Reporting Standard by wiring money to the USA? You violated the US federal wire fraud statute with criminal incarceration penalties.
|
Which jurisdictions can be used to avoid CRS without being beat up?
|
Swiss bank relationship managers, desperate to stop clients fleeing to US banks, tell clients how to avoid CRS with incorrect information.
|
Fat bastard global services providers help their clients lie to avoid BVI Economic Substance laws
|
15 |
How OECD can crush CRS jurisdiction wealth managers looking after assets placed with US Custodial Institutions, such as Pershing LLC or US Trusts
|
Trying to educate investment entities that not having to report on themselves for CRS is crappy advice
|
How offshore jurisdictions have fooled the EU's Economic Substance requirements on holding businesses
|
Will America go from hunter to hunted in cross-border tax evasion
|
14 |
Mandatory Disclosure Rules for CRS as useful as a chocolate teapot? It's not a minimum standard, has major exemptions and legallycan't be retroactive.
|
Untaxed investment entities, other than trusts, are the single most misunderstood section of the Common Reporting Standard
|
Prepare to be smacked open like a piñata if hiding your money in the USA. John Doe summonses assisting foreign governments to be used frequently.
|
Banks make up ludicrous rules who can discretionarily manage assets of an investment entity. Licenced? What percent of assets? What jurisdiction?
|
13 |
Using loopholes in FATCA legislation for CRS clients? Then you are unaware the OECD has closed these loopholes. .
|
Hiding from automatic exchange of information by placing your money in USA? We interrupt your peaceful sleep now that John Doe is active again.
|
OECD crowing about the success of automatic exchange causing a 25% fall in offshore deposits. It mostly fled to the USA, you muppets!
|
There are two strategies to hide clients from CRS: Use a fake weakness or exploit a real loophole
|
12 |
Banks are ignorant when proposing a prevalent so-called CRS loophole
|
Is a trust a custodial Institution if its not an investment entity? See impact of OECD CRS FAQ Feb 2019 on SPV Custodian.
|
Does the Investment Entity term exclude holding companies? Depends if its FATCA or CRS
|
For CRS, who is the reportable account holder when a trust is a Custodial Institution? Can the dearth of definition be exploited to hide settlor?
|
11 |
Quick quiz on CRS
|
Banks wrongly advise untaxed investment entity companies that there is no CRS reporting if the owner and director are in the same jurisdiction
|
The single most misunderstood issue of CRS / FATCA. The asset test of a trading Active NFE.
|
Many banks conjure a non-existent CRS rule that to qualify as an investment entity, the assets must be managed by a "regulated" wealth manager
|
10 |
 Singapore and Hong Kong banks categorise your business as a non-reportable Active NFE even though it is highly likely a Passive NFE
|
If USA ever enacts 'full reciprocity' of information exchange, it will be a failure as FATCA is rife with loopholes
|
CRS reportable value of a Zero Cash Value policy for the policyholder is not null. It is the full cash value.
|
Wrong Advice By Bank to avoid CRS
|
9 |
 Investment Entity Carve Out
|
Zero surrender value policies
|
Endowment funds are not exempt from CRS
|
Where is untaxed BVI entity located
|
8 |
 US rejects CRS
|
OECD, fix up loopholes
|
Where is an untaxed entity located
|
CRS can oblige wealth managers or its parent to report on accounts in the USA by piercing the corporate veil
|
7 |
 Quiz
|
Trying to circumvent CRS with orphan structures
|
Zero cash value policies
|
Global trust firms hiding in Dakota
|
6 |
 Been advised your untaxed Investment Entity managed by yourself avoids CRS? Oops, that is wrong...
|
Zero tax jurisdictions dislike economic substance? No problem, they've surreptitiously escaped its main impact.
|
The misplaced self-confidence of banks to move clients' assets to USA and continue servicing the portfolio
|
If an entity holds a Passive NFE subsidiary and collects the dividends, is it a Custodial Institution, Investment Entity or a Nominee?
|
5 |
 Peddling surety bonds or Long term care policies to avoid CRS. It isn't out of scope despite providers assuring such.
|
What's with Gibraltar trustees mistakenly advising that some retirement funds avoid the CRS?
|
Exploiting the term 'related' to avoid the CRS
|
Big 4 misinterprets a CRS clause and subsequently trustees exploit a non-existent loophole for thousands of trusts
|
4 |

OECD misquotes the FATF recommendation and subsequently accepts there is no need to identify Controlling Persons of certain entities
|
What's with the insurance industry not comprehending Zero Cash Value policies are not a CRS solution?
|

FIs are not listening to the OECD initiative to tackle abuse of residence by investment
|
OECD FAQ update February 2019 - Yeah, you're a managing Investment Entity even if you don't get paid fees
|
3 |

Common Reporting Standard becoming different standards
|
Don't confuse the EU Commission's failed blacklist vs. EU Code of Conduct Group's blacklist of USA
|
Fleeing the BVI due to Economic Substance
|
Automatic exchange of information's gap regarding non-participating Institutions
|
2 |

EU Code of Conduct Group closes the Investment Entity CRS loophole - perhaps
|
Listing on an exchange is a CRS loophole which OECD can easily tackle
|
Banks are ignorant when proposing a prevalent so-called CRS loophole
|
EU Code of Conduct Group strategy coalesces against USA as an uncooperative tax haven
|
1 |

Pointless for UK Territories resisting public Registers of Ownership
|
Singapore's irrevocable trusts help Settlors hide undeclared assets by reporting zero. CRS participating jurisdictions should be furious.
|
Financial alchemy - Passive NFE becomes Active NFE / Investment Entity
|
Pros and cons of circumventing automatic exchange of information by by hiding your money in the USA
|