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CRS Advisory – Published by Lorman August 2017

CRS Advisory- Updated; August 2017

As many will already know, the automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, went global with the recently agreed; Common Reporting Standard or “CRS”.  The CRS provides for annual automatic exchange between governments of financial account information.  CRS sets out the financial account information to be exchanged, the financial institutions that need to report, the different types of accounts and taxpayers covered, as well as common due diligence procedures to be followed by financial institutions.

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Tax Planning for US Investors- Doubling Net Return on Investment

US investors can virtually double their net after-tax return on investments. How? By the compliant elimination of US Income, Estate and Gift taxes on the investment portfolio income with minimal or no reporting. It can, has, and is being be done by many US investors, both domestically and abroad.

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Offshore Investment Cover

Tax Planning Beyond the Grave- when you are worth more dead then alive

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Investment Tax Planning for U.S. and International Investors

What Should Investors Do To Protect Themselves?

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Is “offshore banking” really dead?

Re-print from 2002. What was true then is even more so now.

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U.S. Pre-Immigration Asset Protection

Foreign nationals planning on a move to the U.S. need consider pre-immigration planning to protect their assets from risk of attachment and the rising level of taxation on the wealthy. The following is a brief on planning that could exempt assets from such seizure and taxation.

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The Best Tax Haven Getaways

Forbes.com: It’s April 15, the day when all responsible citizens have to send in their annual pound of flesh to the Internal Revenue Service. Unless, of course, you are a tax exile.

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US Reporting 3520

Who Must File Form 3520: 1. You are the responsible party for reporting a reportable event that occurred during the current tax year, or...

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US Taxpayers & Offshore Accounts Tax Reporting Summary

US taxpayers are required to report offshore accounts: 1. IRS/Form 1040 (Schedule B) – Disclose Foreign Account, 2. Include income on Form 1040
(Foreign Account)...

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Asset Protection Revisited

Absent major tort reform, wealthy Americans (and increasingly, HMW individuals internationally), may actually see an increase in litigation from the current high levels; already far higher than any other country in the world on a per capita basis.

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Insuring Against Hedge-Fund Taxes

A small but growing number of wealthy investors have discovered a legal way to invest in hedge funds without paying income taxes on the gains.

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Trusts and Life Assurance: Complementary Vehicles in a 21st Century World

Practitioners are increasingly acknowledging the wisdom of combining two of the most effective wealth planning methods available today: trusts and life assurance.

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US Expatriation and the Ten Year Rule

Expatriates who left the U.S. prior to June 17, 2008 are covered under prior tax rules, contained in three separate Tax Acts, which each subject U.S. expatriates to a ten-year “alternative tax regime”...

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Offshore Tax Evasion – Another Perspective

After reading Gary Wolfe's excellent article entitled "Offshore Tax Evasion: File Leaks Expose Secrets of the Rich", it is important to note a few aspects of the reporting done to date...

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Gary Wolfe: Offshore Tax Evasion – File Leaks

On April 4, 2013 the Digital Journal, The Guardian and Spiegel online reported that an informational network of journalists (15 month research project), 86 journalists from 46 countries, working with a nonprofit organization...

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Insuring Against Hedge Fund Taxes

A small but growing number of wealthy investors have discovered a legal way to invest in hedge funds without paying income taxes on the gains...

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“Out-of-the-box” thinking by a foreign insurance carrier to avoid US taxation.

Article LISI Foreign Annuity PLR 200601007: Robert (Bob) Colvin discusses "out of the box" thinking by a foreign insurance carrier to avoid US taxation.

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Magistrate Recommends Repatriation of Offshore Trusts’ Assets

A US magistrate judge has recommended that the assets held in two offshore trusts should be repatriated because the government has a valid tax lien, and for repatriation, the corpus of a trust...

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An update of utilization of Life and Annuity Products in the International Tax Arena

The use of retail or “private placement” life insurance and annuity policies issued by insurance companies located in a country outside of the home...

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James (Jay) Walker of J.A. Walker and Assoc. provides an update in the use of life insurance and annuity products to mitigate international taxation of private wealth.

2004 Florida Speech. The use of retail or “private placement” life insurance and annuity policies issued by insurance companies located...

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Private Placement Insurance Arrangements: Recent Developments Dictate a Fresh Look

Private placement insurance planning has finally reached a level of maturity. Despite this coming of age, many structures remain haunted by the growing pains and foolish indiscretions of youth.

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