Entries by Christian Reeves

What is UBIT in an IRA?

UBIT in an IRA is a real pain in the rear… at least if you’re IRA is onshore. When you take an IRA offshore, UBIT is not big deal. Here’s an explanation of UBIT in an IRA and how to deal with it. UBIT stands for Unrelated Business Income Tax. We call this type of […]

How to operate an investment fund tax free from Puerto Rico

The best tax deal available to hedge fund traders and investment fund managers is Puerto Rico. There’s no tax holiday available anywhere in the world that can compete with the offer from Puerto Rico. Here’s how to setup and operate an investment fund tax free from Puerto Rico. First, let me explain why Puerto Rico […]

Trump’s Tax Plan for Expats

Most of Trump’s tax plans will help American expats. If you’re living abroad, and making more than the Foreign Earned Income Exclusion, or have significant capital gains, Trump might cut your US taxes significantly. First, I should point out that there’s been no indication Trump will attack the FEIE. I don’t expect this Exclusion to […]

Subpart F Income Defined

When a US citizen forms an offshore corporation in a low tax country different from his country of operation, he has a Controlled Foreign Corporation with possible Subpart F income issues. In this article, I’ll review the Subpart F rules and determining factors. First, let’s talk about a Controlled Foreign Corporation. Subpart F only applies […]

How self employment tax works when you’re offshore

If you’re living abroad and paid by a US company, you’ll pay self employment tax on your earnings. If you’re living offshore and operating a business without an offshore company or LLC, you’ll pay self employment tax on your profits. Here’s how self employment tax works when you’re offshore and how to avoid it. All […]

Offshore Trusts and Community Property Law

Here’s an overview of offshore trusts and community property law.  If you’re married, and live in a community property state, you and your spouse must work together to form the most efficient asset protection structure. An offshore trust must include special provisions for those in community property states. Let me frame the issue surrounding offshore […]

Panama Financial Services License

A Panama Financial Services Company is a licensed but unregulated financial entity which allows you to hold and manage client funds in Panama. The Panama financial services license is issued by the Panamanian Ministry of Commerce (Ministerio de Comercio and Industrias). It’s much easier to keep in compliance than a license issued by the banking […]