Arnold Cornez - The Offshore Money Book

To JUDIE, MY WIFE.
MY THANKS FOR YOUR SUPPORT
DURING THE SOLITARY PROCESS OF
WRITING THIS BOOK.

Acknowledgments
Introduction to the Revised Edition A Note from the Author

TerminologyAre You a Reluctant American?

The Structures
The Participants
The Costs
International Services and Setup

WHY GO OFFSHORE? Reasons to Stay Onshore Reasons to Go Offshore

Guidelines for Evaluating Offshore Options Legal Issues and Terminology
Transferring Assets
APT Costs

Basic Offshore Entities

What Can an IBC Do?
IBC Features
Applying for Company Formation and Agreement An IBC Comparison Checklist
Other Forms of Companies

The U.S. Living Trust
The Evolution of the Trust Who Needs an APT?
The Parties to the APT
A Trust with a Dual Nationality Costs
Trust Terminology
Technicalities

Industry Trends
The Swiss Banking System
The Caribbean and Neighboring Nations Other Offshore Financial Centers Offshore Credit and Debit Cards General Banking Rules

Private and Numbered Accounts
Monetary Policies and Exchange Controls
Swiss Postfinance Services
Offshore Foreign Currency Accounts
Private Banking
Privacy

Going Offshore-the The Private Annuity

Offshore Exempt Companies Demystifying Residence: Domicile, Citizenship, and Passports Renouncing U.S. Citizenship The Living Trust The Family Limited Partnership Real Property Equity Stripping: An Asset Protection Tool The Unincorporated Organization or Unincorporated Business Organization Proprietary Triple-Trust Structure Contemporary Three-Tier Structure The Pure Trust Scam The Business Trust The Pure Equity Trust Providing for a Child in a High-Risk Profession Offshore Charitable or Private Foundations Bankruptcy with an Asset Preservation Plan Foreign Income Exclusion Determining Where Your Tax Abode Is Located Viatica1 Settlements Foreign Sales Corporations Offshore Betting and Gaming Licenses

Tax Implications for U.S. Persons Tax on the U.S. Grantor Special Tax Concessions by Local Jurisdictions Excise Tax Taxes on Annuity Proceeds

U.S. Taxes on the IBC Investing in the U.S. Stock Market 174 Tax on Renouncing U.S. Citizenship I I74 IRS Requirements for an Offshore Principal Office 176 Applicable IRS Forms I77 Classifying Tax Havens Based on Tax Attributes 185

Passport Review and Travel Agent Records Telephone Records
Frequent Flyer Programs
Wastebaskets and Garbage Cans

Computer Files
Business Associates
Encryption

Costs, Formation Fees, and Capitalization Typical Statutory Requirements
Global Insurance Resource on the Web

A Case Study: Putting the Pieces Together A Test for the Reader 203 Avoiding Offshore Scams: Greed-0-Nomics IOI 204 Pitfalls of Bribery 215 Farewell to the Reluctant American 215

Selected Tax Havens of the World 220I WAS THE "coach," and this book is my "team's" effort, though

most of the people involved didn't even know they were players on my team. They were my mentors and skeptics; they flattered me in discussions, but were the very advocates of the devil. And indeed, the credit for this revised book should go to the hundreds of people who have most graciously shared their priceless knowledge and secrets with me over the last fourteen years. and this book is the essence of the efforts of those years, my "give back" to those who have helped me along the way. From simple grape juice comes lut; and from sifting through my daily journals and lifetime experi- ences for grains of knowledge comes the update to Money Book.

During the final, formative months, the following persons onshore and offshore directly contributed to this work, and my acknowledgments are in order.

Vernon K. Jacobs: Village, Kansas. My unending thanks for your major contribution on the complex issue of taxes in Chapter

David S. Lesperance; barrister and solicitor, Dundas, Ontario, Canada. My thanks for a major rewrite of Chapter ject of second passports and citizenships.

xii THI OFFSHORE tiOH[Y BOOK

My thanks also to the following for materials used in this book:

Jay D. Adkisson, Esq., Irvine, California
E. L. Bendelow, Basel Trust Corporation, St. Helier, Jersey
Terry Coxon, Petaluma, California
J. Richard Duke, Esq., Birmingham, Alabama
Barry S. Engel, Esq., Engelwood, Colorado
L. Burke Files, Tempe, Arizona

And last, but certainly not least, my thanks to my loving wife of nearly thirty-five years, Judie, who served as editor in chief (with due apologies to Danielle Egan-Miller, my editor at ~~clcontemporary Publishing Group, without whom this revised edition could never have been finalized). Judie was my unabashed critic and distant com- fort during the periods of necessary solitude for the research and drafting of this revision-everything I needed my best friend to be.

So MUCH HAS of this book vices business, has grown at a hyperbolic rate. ing; you will see for yourself.

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