Warburg’s 100-year-old investment banking firm, Dillon Read (on Park Ave. NY) (now UBS Warburg) has offices in 39 foreign countries, including the Bahamas, the Little Cayman Islands, Hong Kong and the Channel Islands. Makes you wonder why, doesn’t it?
Nonresident foreign companies, trusts, banks and individuals can trade stocks, bonds, commodity contracts and options 100% tax-free on US capital gains.
Under the US Tax Code, only when a foreign company, foreign trust, or nonresident alien individual establishes permanent residence in the United States, will it be subject to US capital gains taxes. In the same way as national taxpayers. For a corporation, permanent residence would be an office or warehouse in the US Capital gains earned by foreign corporations and other non-residents “not engaged in trade or business within the United States” are exempt from Taxes under IRC Section 871 and IRC Section 881 and IRC Section 897 (c) (3). In addition, Section 864-2 (C) (1) and (2) of the United States Treasury Regulations establishes an exception for what involves “engaging in a trade or business within the United States.” Under US regulations, non-resident stock transactions conducted through a US stockbroker, independent agent, or employee are not considered.
Gains from the publicly traded stock market (from NYSE, NASDAQ, or AMEX listed stocks and bonds) accruing to an offshore company are tax-free on US capital gains. Under Tax Code statutes Insiders, but “US shareholders” They may have a tax liability (indirectly) if the offshore company is a “Controlled Foreign Corporation (CFC) (ie,” more than 50% of the voting and non-voting shares are owned by US SHAREHOLDERS). See IRC sections 951 to 958. See especially Section 951 (b) of the Code for the definition of US SHAREHOLDERS.
US taxpayers using tax havens are at higher risk (overall) than a nonresident alien (non-US citizen). Whether a U.S. citizen taxpayer has a tax liability on the profits of the offshore company depends on many things, including the type of income the company produces (i.e., subpart F or non-subpart F) and how many shares of the company. owned company, and if the offshore company is a CFC, as defined in the Internal Revenue Code in Sections 957 and 958.
More on the tax-free paradise of Anguilla. Click the link below for more details.
[http://www.geocities.com/taxhavens123/caribbeantaxhavens.html]
A Tribute to: Confidential Banking Ordinances in the Caribbean
[http://www.geocities.com/taxhavens123/bank_confidentiality.html]
Wealthy Dupont Nemours and Roosevelt families buy a tax haven
Want to know why and how the former wealthy Dupont Nemours and Roosevelt families were able to purchase 4,000 acres of waterfront property on Provindentcials Island in the duty-free crown colony (or “Overseas Territory”) of the Turks Islands and Caicos for 1 one hundred year acre?
This 4,000 acre sale (now a marina and resort town, with an airport for jumbo jets (the $ 50,000,000 airport was donated by the UK government) dwindled in the 1970s, not the 1870s! !?!?
Source: Government of Turks & Caicos 3 full page advertisement in Investor’s Daily (1985).
Was this the most profitable real estate investment of the 20th century? A quarter acre lot in the gated community of Sandyport here in Nassau, Bahamas sells for approximately $ 260,000 today. Half-acre canal lots on Lyford Cay sell for about a million dollars.
Do the math. With an initial investment of just $ 40, the 4,000-acre property could be worth nearly $ 4 BILLION today.
YOU ARE THE JUDGE … Is the use of the world’s tax havens a blessing or a detriment? Before you answer, take a look at some of the IRS loopholes in our “Tax Code,” which are discovered below for you to see, and which are buried within the tax law for taxpayers. There is a very important gap for the non-resident alien that you should not overlook!
