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Fall/Winter
2003: This is the third
and final issue of OFU published in 2003 and also the final issue to be
published. It covers the period from
October to December 2003. There's no
doubt offshore banking has undergone many changes in the past several hundred
years, but none have likely been as dramatic as those that have taken place
recently in only a few years.
In June 2003, for example, the OECD's Committee on
Fiscal Affairs issued its 2003 Progress Report on Improving Access to Bank
Information for Tax Purposes. One of the
main objectives of the report was to establish a standard of access to bank
information, namely, that "all Member countries should permit access to
bank information, directly or indirectly, for all tax purposes so that tax
authorities can fully discharge their revenue raising responsibilities and
engage in effective exchange of information with their treaty partners."
Needless to say, these objectives have serious
implications for offshore banking clients, but, as Jason Lidero
explains in his article Bank Account Access, implementation of the objectives
has not been smooth.
The FATF was also active this summer issuing its
revised Forty Recommendations to combat money laundering. And, of course, recent changes under Patriot
Act have caused tricky reporting obligations for holders of foreign accounts.
Closer to home, Ralph Sherman let's us in on the well
kept secret of
Offshore banking is not the only product to emerge
from intense scrutiny with new opportunities.
The US Treasury Department issued two revenue rulings this summer
specifically designed to curtail private placement life insurance used as a so-called
"wrapper" for other investment income. Despite the new IRS rulings, Lewis Saret explains in his article PPLI: Alive and Kicking that financial planning involving private placement
life insurance still offers attractive opportunities.
Spring 2003: This is the second of three issues of OFU
published in 2003 and covers the period from May to September. If you ever wondered about the legitimate
uses of OFCs in legal offshore planning structures,
this is the issue for you.
In many cases, the standards of transparency in the
offshore financial centers now exceed those applicable in most OECD
jurisdictions. As stated in this issue
by
Certainly, there were individuals in the 1990s who relied on banking secrecy and opaque corporate
structures to avoid declaring assets and income to tax authorities. However, the overwhelming value of assets in
the offshore finance industry is attributable to legitimate uses of financial
structures and planning techniques.
In Protecting the Offshore Corporate Veil, we look at
the importance of respecting the corporate integrity of offshore special
purpose vehicles. And we examine the
benefits of creating a business presence in
Ever wondered about starting up an offshore fund? We have the five biggest mistakes made in
starting an offshore fund and how to avoid them.
We also look at the advantages and disadvantages of
holding intellectual property offshore and how modern companies can benefit
from the Internet and offshore financial centers.
The April 15th deadline to participate in the IRS's
Voluntary Compliance Initiative has come and gone. Now what?
We let you in on what the IRS didn't tell you about their tax amnesty
program. And you may be surprised by our
ten outrageous facts about the income tax.
Winter 2003: This is the first of three issues of OFU
published in 2003 and covers the period from January to April. In this issue, we report on many positive developments
for the offshore finance industry, ranging from a growing backlash against the
non-resident interest reporting rules and the anti-corporate inversions project
in the
OECD efforts to prevent offshore finance centers from
using tax rates as a competitive factor;
OECD efforts to seek exchange of information on
request in tax matters;
EU efforts to seek automatic information exchange in
tax matters;
FATF efforts to improve money laundering prevention
measures;
US efforts to hold the correspondent banking system as
a hostage for information on account holders;
US efforts to seize the system through which all
credit card transaction are processed; and
US efforts to negotiate tax
information sharing agreements with offshore finance centers.
Closer to home, the
You want to know how offshore insurance is being used
to provide sophisticated risk management solutions for corporations, agents,
insurers and re-insurers. We’ve got the
answers in this issue. And with more
than 100 new insurance companies having set up here in the past two years, we
tell you why
In our cover story on the art of safe offshore
planning, we look at new regulations that give guidelines for safe planning
using private annuity contracts. We also
look at the current situation of asset protection trusts as an offshore
planning tool. With the addition of
September/October
2002: This is third
and final issue of OFU published under the title of Vault magazine. It is also the last issue of OFU published in
2002. In this issue, we have a wealth of
stories to offer. One of the larger developments
of the summer was the Financial Action Task Force's 13th annual report. We tell you which four jurisdictions the
So, what exactly is all the fuss about? Well, Charles Dillon takes an in-depth look
at money laundering, by some accounts, the third-largest business by value in
the world. Dillon compares the
anti-money laundering regimes that exist in
Another thing that has been hot lately is gold. We explore whether gold and precious metals
are worth their weight. We also take a
trip Down Under to explain how the Perth Mint Certificate Program lets
investors stash their precious metals in
And for our Special Focus section, we visit
We sit down with Urs Roth,
chief executive officer of the Swiss Bankers Association, to talk about
Something else that has grown more popular in
Another country
investors are looking to is
They date back to medieval times and their concept has
been shaped over the centuries. Domestic
and international trusts are among the most flexible and efficient of legal
structures and are increasingly used in a wide range of private and commercial
applications. Even though the situation has
changed considerably over the past few years, as Jersey-based trustee G. Alan
Evans writes, "there are still many valid
situations where international trusts can play an important role in the
international structure of private wealth and commercial transactions."
But that's not all!
This issue also features informative articles on the state of financial
services in the
July/August
2002: This is the
second issue of OFU published under the title of Vault magazine. Back by popular demand for our special focus
is
In the conclusion of a two-part series on captive
insurance, read about how to select a captive domicile. We also provide a comparison of three of the
leaders.
Despite the pressure the United States Internal
Revenue Service is placing on Visa to cough up the records of offshore credit
card holders, the cards still serve a useful purpose. In "Getting a Second Chance at
Credit," we take a look at the phenomenon of people who are looking at
offshore credit cards for credit solutions.
In the hands of the Organization for Economic
Cooperation and Development and the Financial Action Task Force, blacklists
have simply become a political tool.
Well, at least that's the argument David McNair puts forth in his
article, "Checking the List."
McNair calls the OECD harmful tax practices blacklist and the FATF
anti-money laundering blacklist a "misguided attempt at international
policy gone bad."
In this issue of Vault, you'll also find out which
country ranked as the most stable emerging market in the world in a recent
Lehman Brothers and Eurasia Group stability index. And we discuss
In addition, read about the IRS's latest fishing
expedition, and discover one of
May/June
2002: This is the
premier issue of Vault, which combined our popular and highly respected
Offshore Finance
We also take another look at the Enron debacle. The collapse of the Houston, Texas-based
energy trading giant has raised some more questions about offshore finance,
including the growing trend of companies relocating in offshore jurisdictions
like
In the first part of a two-part series, you will
discover the ins and outs of captive insurance.
If your corporate insurance goals consist of
reducing your annual premium payments, while still ensuring your insurance
coverage remains adequate, captive insurance might be the solution for you.
March/April 2002:
In our cover story, we profile Michael Ryan, who brings passion and professionalism
to offshore luxury resort development.
Ryan's latest project is the Ritz-Carlton, Grand Cayman Resort and
Residences in the
William Vigal and Mary Simon tell you how by using tax treaties,
the Spanish holding company allows for a very low overall net tax paid on
business profits. Sophia Harris explains
how structured finance transactions are breaking new ground in unconventional
markets.
A number of
jurisdictions have been celebrating their e-commerce accomplishments lately. E-banking in the
We also
visit
We take an
in-depth look at the USA Patriot Act, which creates unprecedented restrictions
on offshore banking and finance. Charles Dillon explains how the United States
Treasury requires businesses to fight terrorism.
Alternative
investments can be profitable and fun. We tell you how antique maps,
collectible toy cars and fine wine can make you rich.
Are
offshore funds too hidden to benefit from securities class action lawsuits in
the
And we look
at the collapse of American energy-trading giant Enron, which sent shock waves
offshore and ignited fears of another backlash against offshore finance
jurisdictions.
January/February 2002: We visit some countries that have hopes and
dreams of becoming offshore centers. We also take a look at some of the new and
emerging online gambling jurisdictions, such as the
More and
more online casino operators are also wising up to the importance of
responsible gambling. We profile the
Duluth, Minnesota-based North American Training Institute, a leading proponent
of responsible gambling that is leading the charge.
Are
economic citizenship programs doomed to become a thing of the past? We try to answer that question. But even if they're not, economic citizenship
programs must undergo some fundamental changes, according to some experts.
We also sit
down with Kevin Dunn of
In
addition, we examine intangibles, any type of which-trade name, patent,
copyright, franchise, customer, goodwill, etc.-can be useful when doing
offshore planning. We also explain a
number of the practical issues involved in licensing international intellectual
property.
And what's
the next emerging market hotspot? You
might be surprised. As you'll discover,
it could be right under our noses.
November/December 2001:
We examine the impact the September 11 terrorist attacks on the
A number of
offshore jurisdictions have taken steps to keep up with the dramatic growth in
e-commerce. The
We also
tell you about the International Monetary Fund becoming the latest
international organization to examine offshore finance centers.
Gyroplanes
have been called the "third wave" of transportation and they soon
could revolutionize the way international investors, offshore professionals,
business executives and others travel around the
And we take
a look at the fine art of naming international business companies, letting you
in on some of the tricks company formation agents use in their search for
names.
September/October 2001 (SOLD OUT):
We take a look at the commercial real estate market in the
Wayne and
Scott Turner are feeling the heat after the father-son team resigned from their
investment company in May to face fraud charges.
We take a
look at a new task force in the
And we
visit
July/August 2001 (SOLD OUT):
Some offshore jurisdictions are rolling out the red carpet for
May/June 2001 (SOLD OUT):
We take an in-depth look at the cryptography industry. Why aren't most
encryption software companies based in the
March/April 2001:
We focus on the varying aspects of offshore online gaming, from starting
an online gaming company to the incredible jackpots offered. Learn about the seven lucky steps to setting
up an online gaming business and how
We look at
Maxlotto.com, which is offering the world's first $100 million dollar jackpot
and we explore how an online gaming company can offer an "out of this
world" jackpot-think creative insurance policies.
We also
cover the steps necessary for building a captive insurance company and look at
the advantages of setting one up. We
probe into the benefits of
January/February 2001 (SOLD OUT):
Offshore credit cards entered the spotlight in a big way when the IRS
obtained permission to access certain MasterCard and American Express
records. Will offshore centers waive
their bank secrecy laws and allow the IRS to investigate offshore accounts of
US taxpayers? Does the
November/December 2000:
We focus on the limited supply of private islands; buying one is a good
investment, but finding the best financial privacy still boils down to finding
the right jurisdiction.
We profile
September/October 2000:
We profile the newly-appointed John Bourbon as he guides the Cayman
Islands Monetary Authority in a time of unprecedented international pressure
for change in the regulation of offshore financial services. We take a look at
the struggles that Bourbon and the
We also
look at a showdown in the
July/August 2000:
A stunning report on the crime fighting financial duo Martin Kenney and
Irving Cohen. They carry out research and obtain information on big-time
financial criminals, and make it possible for the public to recoup their loses with asset recovery,
strategies. We also feature
May/June 2000:
Feature report on offshore Internet gaming, including the implications
of the first US federal prosecution of an offshore online sports gambling
operation, a profile of Antigua-based cybercasino
Intertops.com and a look at the bizarre case of Cynthia Haines who racked up
$70,000 in gambling debts and was then let off the hook - find out how she did
it; the future of economic citizenship programs in Belize and Dominica, where
the programs have come under considerable scrutiny by local authorities;
detailed profile of offshore e-commerce entrepreneur Reynald
Katz, who took a time-honored retail business (the
duty-free shop) and turned it into a successful offshore e-commerce
operation. Less than two years since the
start-up, he predicts annual sales of over $100 million.
March/April 2000 (SOLD OUT):
An in-depth
profile of offshore investigative reporter David Marchant
- from a humble career start in a small Welsh coal-mining town, this
fraud-busting journalist has become one of the more recognized names in the
offshore finance industry; multi-jurisdiction disclosure standards to
facilitate cross-border offerings; feature report on offshore reporting
obligations including the increasingly common practice of offshore institutions
requiring clients to sign bank secrecy waiver agreements; US reporting
obligations related to taxation and money laundering; comparative survey of
professional reporting obligations in 18 of the leading offshore jurisdictions.
January/February 2000:
Feature report on offshore e-commerce, including the nuts and bolts of
setting up an offshore e-commerce business; US and international taxation of
offshore e-commerce revenues; protection of confidential information in
offshore e-commerce transactions; the risks of offshore e-commerce and how to
insure them; technological challenges in the global regulation of offshore
e-commerce; jurisdictional profiles of the following e-commerce hubs: Anguilla, Bermuda, Barbados, Ireland, Isle of Man, Jersey
and Singapore; results from our comparative survey of the 14 leading offshore
e-commerce jurisdictions.<br>
November/December 1999 (SOLD OUT):
Feature report on offshore insurance and risk management including
offshore life insurance; the use of variable insurance contracts in financial
planning; US taxation of offshore captive insurance companies; the compliant
and legitimate offshore insurance structures; the impact of information
technology on the global insurance industry; results from our comparative
survey on offshore insurance in 12 of the leading offshore jurisdictions; the
use of offshore limited liability companies for asset protection planning; the
power of tax-deferred offshore annuities.
September/October 1999 (SOLD OUT):
Feature report on privacy and confidentiality in the offshore finance industry,
including the selection of a jurisdiction for financial privacy, privacy in
offshore banking, the protection of confidentiality in professional
relationships, data encryption in e-mail communications and privacy concerns in
the use of offshore bank cards; offshore tax planning and tax avoidance on IRA
distributions; asset protection planning and avoiding the sham trust argument;
offshore trusts and estate planning and the reporting obligations of
beneficiaries.
July/August 1999 (SOLD OUT):
Feature report on international tax planning and tax treaty networks
including the selection of a treaty or non-treaty domicile for the
establishment of international business activities; the interplay of free trade
zones and tax treaties; international tax competition and a survey of tax
features in the leading offshore finance jurisdictions; the regulation of
offshore banking in Grenada; offshore securities regulation and the domestic
issuer safe harbor; tax planning opportunities with
offshore trusts; white lists and black lists of offshore finance centers.
May/June 1999 (SOLD OUT):
Feature report on asset protection and wealth preservation, including
life insurance in wealth preservation plans, practical tips in offshore asset
protection, guidelines on whether an offshore asset protection strategy is the
right choice, domestic asset protection trusts, the critical choice of an
offshore trustee, asset protection in offshore investments and offshore
annuities in the wealth preservation strategy; the lawful avoidance of US
assertion of jurisdiction over offshore financial Web site; and the IRS
crackdown on abusive offshore structures.
March/April 1999 (SOLD OUT): Feature report on offshore investment funds including the regulation
of offshore offers and sales of securities, taxation of investment income from
offshore trusts and other foreign entities, investor protection legislation and
a jurisdictional survey of offshore fund domiciles – capitalization
requirements, restrictions on fund investments, restrictions on foreign
investors, margin and liquidity requirements, etc; offshore confidentiality in
the premier financial privacy jurisdiction of St. Vincent; and strategies for
international financial planning.