Just to be clear are you saying, that in general, it is possible to get around CFC rules by Investing through foreign trust? If so is that because the trustee is seen as the "owner" and controller? Lets say a settlor set up an offshore trust and ALSO a LLC that would be provided with certain management functions over the trust assets and the settlor would be the "manager" of the LLC. In such a scenario would that still avoid CFC rules?
This is a very technical question, depends on a lot of specifics and nuances as well as varies by the country. Yes, often when you can't get around CFC rules the right type of trust can get you around it because you don't own the assets but this often requires very specific structuring. If you've got specific questions about that the best option is to book a call and we can go over it as it applies to you.
Would be great to see a review of Stripe Atlas for non-US residents. Only benefits I saw possibly was they have partner US banks, but I still think you can gain access to their partner banks with just an LLC formed elsewhere. And then use Stripe through your LLC without going through Atlas.
Yeah they aren't doing anything special they are just packaging it for you though without some other pieces that could be useful to you. Nothing wrong with it I love Stripe great company, nothing really special about Stripe Atlas though.
And of course people I know think I'm crazy but I'm doing a lot of the 6 things which I've discovered Iver the years by trial and error. These would be incredibly valuable to a young entrepreneur. Perhaps you can create a young entrepreneur course for different countries or scenarios? I view you as the foremost expert on this topic even ahead of Andrew Henderson
Hi do you have experience looking after us Australians? Just asking because you reference US alot :) We are getting ready to be between countries and need some structure help
Thanks for the notes in the info at the bottom. Appreciate the Canadian pov. intro needs to be shortened, always skip this and you lose people in the first 1.40 min.
Excellent content and very pertinent to planning our move.
Wow, all the points mentioned in the video were really straight forward
Glad to be of service :)
Just to be clear are you saying, that in general, it is possible to get around CFC rules by Investing through foreign trust?
If so is that because the trustee is seen as the "owner" and controller?
Lets say a settlor set up an offshore trust and ALSO a LLC that would be provided with certain management functions over the trust assets and the settlor would be the "manager" of the LLC. In such a scenario would that still avoid CFC rules?
This is a very technical question, depends on a lot of specifics and nuances as well as varies by the country.
Yes, often when you can't get around CFC rules the right type of trust can get you around it because you don't own the assets but this often requires very specific structuring.
If you've got specific questions about that the best option is to book a call and we can go over it as it applies to you.
Your vlogs are becoming better and better
Thank you! Glad you enjoyed 😎
Another great video, you're doing a great job on your vids mate
Thanks! Appreciate the support.
Anything you'd like to see in the future?
Michael, you are on fire these days! Keep them coming! And where's the trust/foundation topic you promise you are going to do :)
Thanks!
Still on the list, coming soon.
Nice one Michael! :) great info! :)
Thank you. Glad to be of service.
Anything you'd like to see in the future?
Great ideas Michael. On the idea of borrowing against stocks, who offers stock backed loans?
There are some specific lenders we deal with but aside from that you can often just get it from IB.
Would be great to see a review of Stripe Atlas for non-US residents. Only benefits I saw possibly was they have partner US banks, but I still think you can gain access to their partner banks with just an LLC formed elsewhere. And then use Stripe through your LLC without going through Atlas.
Yeah they aren't doing anything special they are just packaging it for you though without some other pieces that could be useful to you. Nothing wrong with it I love Stripe great company, nothing really special about Stripe Atlas though.
very good info
Thank you! Glad to be of service
incredible knowledge! thank you for sharing
You're welcome! Always a pleasure :)
Anything you'd like to see in the future?
And of course people I know think I'm crazy but I'm doing a lot of the 6 things which I've discovered Iver the years by trial and error. These would be incredibly valuable to a young entrepreneur. Perhaps you can create a young entrepreneur course for different countries or scenarios? I view you as the foremost expert on this topic even ahead of Andrew Henderson
Whom is taking the risk when extending loans against public stock as you describe it ?
I do not understand, who are these type of players ?
Specific lenders will offer those terms. Don't be too excited though they obviously aren't going to do that if they think it's a real risk.
Schedule H-Form 5471 will adjust from foreign book income to US taxable income/loss. Stuck forever with US tax laws.
Hi do you have experience looking after us Australians? Just asking because you reference US alot :)
We are getting ready to be between countries and need some structure help
Most definitely! Feel free to contact us, and we'll be happy to assist you! www.offshorecapitalist.com/
which brokers let youborrow against your portfolio without the threat of margin call?
No one will let you do it without a margin call possibly. The best thing to do is to hedge out your risk with a long vol on your stocks.
Genius!!!
Thank you for the continuous support, Jose. Appreciate it
"A man's got to know his (tax) limitations." - Clint Eastwoood
Thanks for the notes in the info at the bottom. Appreciate the Canadian pov. intro needs to be shortened, always skip this and you lose people in the first 1.40 min.