The US Internal Revenue Service was feeling rather proud of itself yesterday; IRS Commissioner Doug Shulman held a press conference to release the final results of 2009 amnesty program.
Over 7500 taxpayers came forward this year to confess hiding income in overseas bank accounts; this number is substantially greater than the several hundred which usually step forward.
Obviously, the unity of insolvent western governments against overseas ‘tax havens’ coupled with the UBS/Swiss banking debacle has lit a fire under noncompliant taxpayers… and of the 7500 individuals who came forward under the amnesty program, their bank account sizes range from $10,000 to over $100 million.
To be clear, having an overseas bank account is not illegal… it’s actually a smart thing to do. Generating offshore income, hiding it in an overseas bank account, and not telling the government about it, though, is illegal.
The Obama administration continues to beef up the IRS with financial and manpower resources– 800 new agents are currently being trained specifically to go after international tax evaders. They have even announced opening up new offices in places like Beijing and Panama… though I’ll believe it when I see it.
With their new mountain of resources, I expect the IRS to go after a few noteworthy tax dodgers (Wesley Snipes, Bradley Birkenfeld) in highly publicized trials. My prediction, however, is that most people the IRS finds will more than likely be subject to financial penalties, probation, and suspended sentences.
Why? Because incarceration costs money, and the government needs tax revenue. Someone who can make $100 million and stash it away in a Swiss bank account is more useful to the government creating jobs in society rather than playing the harmonica behind bars.
Regardless of the penalties, though, trying to ‘hide’ money in offshore accounts is just a dumb thing to do. There are a lot of people out there who think that their trustees and banking secrecy will protect them from tax authorities.
They won’t. Depending on the discretion and secrecy of another human being is a sure-fire way of getting caught. No banker or trustee in the world can withstand the pressure of the federal government and its limitless resources.
There is a bit of good news in all of this, though.
The Obama administration has recently abandoned its plans to go after overseas corporate income. Current tax code allows US corporations to defer paying taxes on income earned overseas until that money is repatriated to the United States. Obama wanted to change this law, but has recently abandoned his plans.
I’m sure that US companies threatened the administration with another round of deep job cuts if the tax hike were passed… and considering that Obama needs their support for changes to climate, healthcare, and financial regulations, he walked away from the idea altogether.
Entrepreneurs with overseas income can greatly benefit from this tax rule; with a properly planned business structure, businesses can defer paying taxes on overseas income, indefinitely, until the funds are brought back to the US.
Let me know if you’re interested and I can refer you to some knowledgeable and by the book tax attorneys who will give you expert advice.
THE BEST GAME IN TOWN:
Legitimate tax deferral strategies are often the cornerstone of good tax planning. Find out what options are available for your particular situation and take action right away.
For individuals, an easy way to do this is with the self-directed IRA structure that I have mentioned a few times. I don’t want to beat a dead horse, but it’s a no-brainer strategy.
We negotiated a subscriber discount with Checkbook IRA, whom I have worked with in the past to set up a self-directed IRA. Due to extremely heavy call volume, the good guys over at Checkbook have agreed to extend the discount for one more week to make sure that they have a chance to answer everyone’s questions.
{ 37 comments… read them below or add one }
Please forward info on tax attorneys who will give me expert advice.
Hey, Simon.
Long time reader. Thx for your service!!!
Could you please refer me to some good tax attys?
Thx!
Simon,
In respones to “Let me know if you’re interested and I can refer you to some knowledgeable and by the book tax attorneys who will give you expert advice.”
I have an interest. Thank you.
Kindest Regards,
Mark
Yes Mr. Black, I’d like more information regarding what you wrote:…..
….. “Let me know if you’re interested and I can refer you to some knowledgeable and by the book tax attorneys who will give you expert advice.”
I know you’ve mentioned Mark Nestmann at times …is he one of your go-to guys per chance?
Thank you
Simon,
Please expound on what a ” properly planned business structure” means to you from your experience. Does this mean IBC, trust or foundation, or one of these preceeding entities, has to be a part of it.
Incidentally, in your travels and time spent what would be the two top locations you would pick “if” you chose to live in any one place. First being the cost of living in that geographic location is not a factor and secondly that the cost of living is the biggest factor yet having qualified infrastructure.
Jim
I would definitely like to be referred to a by the book tax attorney who could help me form a company overseas and thus defer most of my income. Thanks in advance.
Four year ago my husband and I sold our N.California home and used the resulting funds to purchase a working dairy in Uruguay (complete shift in gears for both of us). We are not yet making a profit as the property was fairly rundown, so there is no tax liability from the IRS perspective, yet. I will be receiving an inheritance soon which we would like to invest in the property. I would really appreciate your offer of referral to a tax attorney to insure we set ourselves up to shelter as much of our money and potential future earnings as possible.
Martha,
Where are you in Ururguay? We are looking at buying property in Punta del Este and would love to know where to get organic raw milk, organic meats and vegetables. So you would be our first contact.
Thank you.
Simon,
We have a gaggle of attorneys but always interested in ones that might help with a new perspective on overseas taxes.
Thanks for newsletter.
Simon:
If US citizens are taxed on worldwide income, how can the following be true: “Entrepreneurs with overseas income can greatly benefit from this tax rule; with a properly planned business structure, businesses can defer paying taxes on overseas income, indefinitely, until the funds are brought back to the US.”
Thanks,
Tom
Hello. Very timely article in that I am in the process of setting up a new company. My partner and I are considering different jurisdictions for the corporation, and your referrals to plan the business structure would be greatly appreciated.
Interested in establishing a Real Estate Investment Corporation/Trust
in the countries of Central (and possible South) America, i.e. to actually purchase land/lots, improved land/agricultural land, beach & mountain property, in general all types of Real Estate, with no intentions of ever remitting to the homeland.
Looking to eventually setting up a legacy structure for the kids & grandkids.
P.S. I have no problem with paying taxes to any gov’t.
D.T.
Thanks for the info Simon.
I’m interested.
Please point me in the right direction.
My future might be in need of some good tax advice.
Dear Mr. Black,
I’m interested in your referral.
Thank You,
Quantella Owens
Yes,
I would be interested in knowing appropriate tax attorney.
Thanks, Leonid Faybusovich
We are excited about checkbookira.com and are in the process of setting up an LLC through them. We would very much like to know the names of some good tax attorneys. My husband would like to get some corroboration on the legality of protecting your IRA through an LLC.
We get more good information from you than any other source.
THANK YOU!
WOULD THERE BE A CANADIAN EQUIVALENT TO THE U.S. IRA? COULD WE DO THE SAME WITH CDN. RRSP’S
I’m sure your recommended tax attorney will be overwhelmed, but I too, would like his/her/their name(s).
Thank you for helping us to keep up our defenses.
Ben
Definitely of interest. Please send these contacts.
Ernest
Dear Mr. Black,
I’m interested in your referral for a tax attorney.
cruzer
Thanks for all the great info. Please forward info on recommended tax attorneys for off-shore corporations.
Mr. Black,
Please send me the list of attorneys you referred to in your article.
Edgen
Simon,
I’m interested in your referrals for good tax attorneys.
Kind Regards,
Eugene
Please send referrals to ” by the book” tax attnys who could assist in setting up an offshore corp to DEFER taxes. Thank You.
I am definitely interested in learning more about how I can take advantage of the deferred foreign income rule and being referred to some knowledgeable and by-the-book tax attorneys who will give me expert advice. Thanks a million. Chris
Please add me to the growing list! I wish to learn of the “silver lining”.
This is sooo important and timely as the window is slamming shut!
Sir:
Definitely of interest. Please send these contacts. Thank you.
Please send list of recommended attorneys. Thanks!
I too would be interested to hear of knowledgeable, reputable US tax attorneys who could answer questions & give reliable tax advice regarding foreign corporations and foreign accounts.
Earlier this year, I had asked my longtime CPA about tax implications of a Panamanian corporation, but this was new to him. Apparently, other than a couple people who’ve had Canadian accounts, none of his other clients have attempted to set up a foreign corporation.
PS – Thank you for your insightful & very interesting daily commentaries. I sure enjoy them!
Simon, great article; very informative. I am also responding to your kind offer, as in “Let me know if you’re interested and I can refer you to some knowledgeable and by the book tax attorneys who will give you expert advice.” I have a strong interest in acquiring this information, doing all this nice and legal and by the book. Thanks very much.
Tax attorney for Canadian, re Panama? no mention in Black paper.
Opinion please. 20 year mortgage at 7% good idea or stay 1 year.
Thanks for the good work.
Mr. Black – can you pls refer me to the right tax attorney in Panama and thank you in advance Bob steele
I am interested in a tax attorney in Panama as well. If you know of one please forward the information. We have an attorney doing our residency but no one for taxes. Thank you.
Need good advice on International income and tax planning. Thanks
Please forward contact for tax attorney specializing in overseas companies owned by US residents. Thanks.
FAO: US & (other) EXPATS WORLDWIDE
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ISLE OF MAN, BRITISH ISLES
(an Island located between Great Britain and Ireland, protected by the UK, but with completely separate laws,(based on English Common Law) government etc, and is neither a member or an associate state of the EU, but is an independent, self governing dependent territory of the English Crown, and is not part of the UK and maintains special tax laws for international investors….basically none)
(rated BEST OFFSHORE FINANCIAL CENTRE 2006)
The Investment vehicle: OFFSHORE LIFE ASSURANCE INVESTMENT BONDS
The Company? Voted Best as well, in every major aspect, 7th largest investment group in Europe.
Write me!
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Hope this may be of interest to your readers Simon.
please send some names of internationally minded tax people.. i have 2 properties in argentina, one more owned partially by my sep ira also in argentina and two passports US and Ireland.
Thanks
simon- when will we be hearing about this?