Offshore Trusts, Accounts & Tax Arrangements: Best solution for Black entrepreneurs/businesses

[greenz]

Propz on the good read ... its a damn shame people only read a couple of sentences and skimmed thru the rest.

This article examples transferring pricing pretty good i was just reading how Google and FB incorporate transfer pricing to duck outta taxes but couldn't understand the concept until i read this.

 

[Real2DaC0re]

fuck all that reading shit, huh!

Yea I said fuck reading all together when I came in here.

 

[Mello Mello]

@GAMETHEORY

Great post and extremely informative. Thank you for the insight into how offshore biz works.

Question. How do you set up these multi-nationals? Are there specific countries you should consider for the type of business you run or it doesn't matter?

 

[clitsational]

http://www.bgol.us/board/showthread.php?t=710833

thanks for the info

​

 

[GAMETHEORY]

Hey Gametheory, good read but...

Just not sure how this is a useful post and can even be more harm than good... Tax evasion is a serious offense and isn't something that should be toyed with by 'amateurs' or anyone with strong ties (no dual citizenship) to the US--the most aggressive international tax claimant in the world....

For a black business to be able to take advantage of this wouldn't they need to sell some kinds of goods/service overseas? IF that is the case they would already be aware of some of this... They would also need to have some sort of presence (whether they pay trusted accomplices or go themselves--costly ventures in themselves) overseas? How much revenue do you think a company needs to make for this venture to be worthwhile?

From my understanding multinationals with large presences in the US are doing a ton of these cross border transactions because American companies are making more money than ever before in emerging markets (sometimes more than 50% of their revenues)... The issues they have with these transactions revolve around the fact that they have a hard time bringing their profits back into the US (they'll be double-taxed, paying taxed in the country they do their business and back again in the US). So they have to keep reinvesting the cash overseas...

...Don't you think this transfer pricing is more useful for companies that are primarily overseas, run by 'international' blacks who may do significant business stateside but have stronger ties outside the US?... Just some thoughts....

Did you know that over half of world trade passes, at least on paper, through tax havens.1 Over half of all bank assets, and a third of FDI by multinational corporations, are routed offshore?

Some 85% of international banking and bond issuance takes place in the so-called Euromarkets, a stateless offshore zone.Nearly every multinational corporation uses tax havens, and their largest users—by far—are on Wall Street.

Tax havens don’t just offer an escape from tax. They also provide wealthy and powerful and mainly white elites with secrecy and all manner of ways to shrug off the laws and duties that come along with living in and obtaining benefits from society—taxes, prudent financial regulation, criminal laws, inheritance rules, and many others. Offering these escape routes is the tax havens’ core line of business. It is what they do.

Transfer mispricing is one of the most important reasons that multinationals are multinationals and why they usually grow faster than smaller competitors.

It is not just your bananas, of course. Much of the food you eat will most likely have taken a similarly twisted route into your home. The water in your tap may have travelled on a similarly ghostly paper pathway en route to your bathtub. Your television, its component parts, and many of the programs it shows also likely took offshore routes into your living room. The offshore world envelops us.

And no I'm not here to talk about morals but strict and pure business.

 

[GAMETHEORY]

@GAMETHEORY

Great post and extremely informative. Thank you for the insight into how offshore biz works.

Question. How do you set up these multi-nationals? Are there specific countries you should consider for the type of business you run or it doesn't matter?

This is like comparing apples to oranges. Which jurisdiction is the best depends on what you need, why you are going offshore, and what treaties there are between your country of tax residence and the various jurisdiction. There is no simple one-fits-all answer.

 

[incogneg]

u hope im wrong? ok.

i think that's a dope field if u have a way to diffrenciate urself from ur comp and have a strong network or way to drive new business. more power to ya.

found the book. check page 13 halfway down. i bet its a useful/good read even if u dont actually put the shit to use. like 48 laws...

Good find! I've seen similar things, but seems this is more of an 'expose'... These kinds of activities you don't learn in a book... With all his posts of Lamborghinis, Arabs in the UK, Yachts, St Barts, and now this, I think Gametheory is sending us a message of some sort...

 

[incogneg]

Did you know that over half of world trade passes, at least on paper, through tax havens.1 Over half of all bank assets, and a third of FDI by multinational corporations, are routed offshore?

Some 85% of international banking and bond issuance takes place in the so-called Euromarkets, a stateless offshore zone.Nearly every multinational corporation uses tax havens, and their largest users—by far—are on Wall Street.

Tax havens don’t just offer an escape from tax. They also provide wealthy and powerful and mainly white elites with secrecy and all manner of ways to shrug off the laws and duties that come along with living in and obtaining benefits from society—taxes, prudent financial regulation, criminal laws, inheritance rules, and many others. Offering these escape routes is the tax havens’ core line of business. It is what they do.

Transfer mispricing is one of the most important reasons that multinationals are multinationals and why they usually grow faster than smaller competitors.

It is not just your bananas, of course. Much of the food you eat will most likely have taken a similarly twisted route into your home. The water in your tap may have travelled on a similarly ghostly paper pathway en route to your bathtub. Your television, its component parts, and many of the programs it shows also likely took offshore routes into your living room. The offshore world envelops us.

And no I'm not here to talk about morals but strict and pure business.

Thanks for that. My thoughts are more centered around how it's applicable for Black American businesses in the sense of 'size' where it's profitable...

When I think Multinationals, I'm thinking about huge companies, with entire treasury depts that are undergoing cash management transactions on a daily basis. In your context I know recently speaking to a few CFOs, Senior VPs in Corp finance functions at Multinationals, their main issues were figuring out how to get the tons of cash they are making overseas back here as opposed to just reinvesting it overseas...

Also I was saying that 'tax avoidance' (as someone corrected me (as opposed to 'tax evasion' I used) is affordable to the wealthy, but Joe Schmoes business may not be able to take advantage? What size companies you think can actually do this?

I think these are good things to have in the back of your mind as you continue to grow and look forward to the day when you can start implementing some of these things... good just knowing how the world works around you...

 

[Spectrum]

Thanks for that. My thoughts are more centered around how it's applicable for Black American businesses in the sense of 'size' where it's profitable...

When I think Multinationals, I'm thinking about huge companies, with entire treasury depts that are undergoing cash management transactions on a daily basis. In your context I know recently speaking to a few CFOs, Senior VPs in Corp finance functions at Multinationals, their main issues were figuring out how to get the tons of cash they are making overseas back here as opposed to just reinvesting it overseas...

Also I was saying that 'tax avoidance' (as someone corrected me (as opposed to 'tax evasion' I used) is affordable to the wealthy, but Joe Schmoes business may not be able to take advantage? What size companies you think can actually do this?

Agree with this man here.

 

[water]

Good drop.

Also look into countries that have double taxation treaties with the US which also you to not get taxed twice:

United States Income Tax Treaties - A to Z
The United States has tax treaties with a number of foreign countries. Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U.S. taxes on certain items of income they receive from sources within the United States. These reduced rates and exemptions vary among countries and specific items of income. Under these same treaties, residents or citizens of the United States are taxed at a reduced rate, or are exempt from foreign taxes, on certain items of income they receive from sources within foreign countries. Most income tax treaties contain what is known as a "saving clause" which prevents a citizen or resident of the United States from using the provisions of a tax treaty in order to avoid taxation of U.S. source income.

If the treaty does not cover a particular kind of income, or if there is no treaty between your country and the United States, you must pay tax on the income in the same way and at the same rates shown in the instructions for the applicable U.S. tax return.

Many of the individual states of the United States tax income which is sourced in their states. Therefore, you should consult the tax authorities of the state from which you derive income to find out whether any state tax applies to any of your income. Some states of the United States do not honor the provisions of tax treaties.

This page provides links to tax treaties between the United States and particular countries. For further information on tax treaties refer also to the Treasury Department's Tax Treaty Documents page.

http://www.irs.gov/Businesses/International-Businesses/United-States-Income-Tax-Treaties---A-to-Z


For small businesses, these resouces may be of use:

Learn how your company can tap into the Global Marketplace!
As part of the National Export Initiative, the Commerce Department’s Trade Information Center is offering a series of webinars on the basics of exporting.

These webinars have been specially designed to meet the needs of new exporters, and provide transaction-specific guidance on more technical matters. Each webinar will begin at 2:00 p.m. Eastern, and will last one hour. A nominal fee of $15 will cover slides, live audio, and question and answer session. Content is delivered

via computer and will be led by experts in their field.

New 2012-2013 Webinars on the Basics of Exporting!
http://export.gov/articles/eg_main_022213.asp



There are whole untapped markets for technology in developing countries.

Middle east countries love American cars, there is a brisk market for used cars.

Also international students are a good sources of co-founders.

 

[water]

Back to the topic at hand:

google "dutch sandwich" as well


Double Irish arrangement

The double Irish arrangement is a tax avoidance strategy that U.S. based multinational corporations use to lower their corporate tax liability. The idea is to use payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law does not include U.S. transfer pricing rules

Typically, the company arranges for the rights to exploit intellectual property outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement between the U.S. parent and the off-shore company, in the terms of U.S. transfer pricing rules. The off-shore company continues to receive all of the profits from exploitation of the rights outside the U.S., without paying U.S. tax on the profits unless and until they are remitted to the U.S.[2]

It is called "double Irish" because it requires two Irish companies to complete the structure. The first Irish company is the offshore company which owns the valuable non U.S. rights. This company is tax resident in a tax haven, such as the Cayman Islands or Bermuda. Irish tax law provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. The first Irish company licenses the rights to a second Irish company, which is tax resident in Ireland, in return for substantial royalties or other fees. The second Irish company receives income from exploitation of the asset in countries outside the U.S., but its taxable profits are low because the royalties or fees paid to the first Irish company are deductible expenses. The remaining profits are taxed at the Irish rate of 12.5%.

For companies whose ultimate ownership is located in the United States, the payments between the two related Irish companies might be non-tax-deferrable and subject to current taxation as Subpart F income under the Internal Revenue Service's Controlled Foreign Corporation regulations if the structure is not set up properly. This is avoided by organizing the second Irish company as a fully owned subsidiary of the first Irish company resident in the tax haven, and then making an entity classification election for the second Irish company to be disregarded as a separate entity from its owner, the first Irish company. The payments between the two Irish companies are then ignored for U.S. tax purposes.[1]
[edit]Dutch sandwich

The addition of a Dutch sandwich to the double Irish scheme further reduces tax liabilities.
Ireland does not levy withholding tax on certain receipts from European Union member States. Revenues from income of sales of the products shipped by the second Irish company are first booked by a shell company in the Netherlands, taking advantage of generous tax laws there. Funds needed for production costs incurred in Ireland are transferred there, the remaining profits are transferred to the first Irish company in the Cayman Islands or Bermuda. If the two Irish holding companies are thought of as "bread" and the Netherlands company as "cheese", this scheme is referred to as the "Dutch sandwich".[3] The Irish authorities never see the full revenues and hence cannot tax them, even at the low Irish corporate tax rates. There are equivalent Luxembourgish and Swiss sandwiches.
[edit]Companies using the arrangement

Major companies known to employ the double Irish strategy are:
Apple Inc.[4]
Eli Lilly and Company[5]
Facebook[6]
Forest Laboratories[5]
Google[5][6][7]
Microsoft[5]
Oracle Corp.[5]
Pfizer Inc.[5]
Adobe Systems[5]
[edit]


http://en.wikipedia.org/wiki/Double_Irish_arrangement

 

[OnSlaught]

Great read. As a few other readers of which I've had the opportunity to converse with over the years of being a member on this board have already stated, thank you for opening this up to discussion. I'll definitely read up on this and see if I can five further imput.

 

[incogneg]

Back to the topic at hand:

google "dutch sandwich" as well


Double Irish arrangement

The double Irish arrangement is a tax avoidance strategy that U.S. based multinational corporations use to lower their corporate tax liability. The idea is to use payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law does not include U.S. transfer pricing rules

Typically, the company arranges for the rights to exploit intellectual property outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement between the U.S. parent and the off-shore company, in the terms of U.S. transfer pricing rules. The off-shore company continues to receive all of the profits from exploitation of the rights outside the U.S., without paying U.S. tax on the profits unless and until they are remitted to the U.S.[2]

It is called "double Irish" because it requires two Irish companies to complete the structure. The first Irish company is the offshore company which owns the valuable non U.S. rights. This company is tax resident in a tax haven, such as the Cayman Islands or Bermuda. Irish tax law provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. The first Irish company licenses the rights to a second Irish company, which is tax resident in Ireland, in return for substantial royalties or other fees. The second Irish company receives income from exploitation of the asset in countries outside the U.S., but its taxable profits are low because the royalties or fees paid to the first Irish company are deductible expenses. The remaining profits are taxed at the Irish rate of 12.5%.

For companies whose ultimate ownership is located in the United States, the payments between the two related Irish companies might be non-tax-deferrable and subject to current taxation as Subpart F income under the Internal Revenue Service's Controlled Foreign Corporation regulations if the structure is not set up properly. This is avoided by organizing the second Irish company as a fully owned subsidiary of the first Irish company resident in the tax haven, and then making an entity classification election for the second Irish company to be disregarded as a separate entity from its owner, the first Irish company. The payments between the two Irish companies are then ignored for U.S. tax purposes.[1]
[edit]Dutch sandwich

The addition of a Dutch sandwich to the double Irish scheme further reduces tax liabilities.
Ireland does not levy withholding tax on certain receipts from European Union member States. Revenues from income of sales of the products shipped by the second Irish company are first booked by a shell company in the Netherlands, taking advantage of generous tax laws there. Funds needed for production costs incurred in Ireland are transferred there, the remaining profits are transferred to the first Irish company in the Cayman Islands or Bermuda. If the two Irish holding companies are thought of as "bread" and the Netherlands company as "cheese", this scheme is referred to as the "Dutch sandwich".[3] The Irish authorities never see the full revenues and hence cannot tax them, even at the low Irish corporate tax rates. There are equivalent Luxembourgish and Swiss sandwiches.
[edit]Companies using the arrangement

Major companies known to employ the double Irish strategy are:
Apple Inc.[4]
Eli Lilly and Company[5]
Facebook[6]
Forest Laboratories[5]
Google[5][6][7]
Microsoft[5]
Oracle Corp.[5]
Pfizer Inc.[5]
Adobe Systems[5]
[edit]


http://en.wikipedia.org/wiki/Double_Irish_arrangement

Good post! It's still the issue of getting money back into the US. But as the world becomes more global, and business people become more global, it's becoming more and more ok to keep that money overseas and re-invest there. That's probably why so many multinationals are looking for people willing/able to live overseas these days... And requiring that of people looking to move up in organizations... Also probably why working in Corporate Finance (Treasury) is a good place to be...

Personally I would love to be in that position. I would have no problem keeping my earnings overseas...

...Realized some time back that my financial future would probably not be in the USA...

 

[RoomService]

props

 

[kwazdog]

Bookmarked

 

[sherminator]

Hey Gametheory, good read but...

Just not sure how this is a useful post and can even be more harm than good... Tax evasion is a serious offense and isn't something that should be toyed with by 'amateurs' or anyone with strong ties (no dual citizenship) to the US--the most aggressive international tax claimant in the world....

For a black business to be able to take advantage of this wouldn't they need to sell some kinds of goods/service overseas? IF that is the case they would already be aware of some of this... They would also need to have some sort of presence (whether they pay trusted accomplices or go themselves--costly ventures in themselves) overseas? How much revenue do you think a company needs to make for this venture to be worthwhile?

From my understanding multinationals with large presences in the US are doing a ton of these cross border transactions because American companies are making more money than ever before in emerging markets (sometimes more than 50% of their revenues)... The issues they have with these transactions revolve around the fact that they have a hard time bringing their profits back into the US (they'll be double-taxed, paying taxed in the country they do their business and back again in the US). So they have to keep reinvesting the cash overseas...

...Don't you think this transfer pricing is more useful for companies that are primarily overseas, run by 'international' blacks who may do significant business stateside but have stronger ties outside the US?... Just some thoughts....

thats the rub with me no one has stated how you get the money back so you could potentially have tens of thousands of dollars overseas that you could never use. Plus how does the average joe use this to his advantage, this seems like a trick for the big boys

Good post! It's still the issue of getting money back into the US. But as the world becomes more global, and business people become more global, it's becoming more and more ok to keep that money overseas and re-invest there. That's probably why so many multinationals are looking for people willing/able to live overseas these days... And requiring that of people looking to move up in organizations... Also probably why working in Corporate Finance (Treasury) is a good place to be...

Personally I would love to be in that position. I would have no problem keeping my earnings overseas...

...Realized some time back that my financial future would probably not be in the USA...

what would be some areas of concentration one might want to look into I have a little cousin starting college soon and I would want to steer her in a direction to make money and possibly be international

 

[GAMETHEORY]

Thanks for that. My thoughts are more centered around how it's applicable for Black American businesses in the sense of 'size' where it's profitable...

When I think Multinationals, I'm thinking about huge companies, with entire treasury depts that are undergoing cash management transactions on a daily basis. In your context I know recently speaking to a few CFOs, Senior VPs in Corp finance functions at Multinationals, their main issues were figuring out how to get the tons of cash they are making overseas back here as opposed to just reinvesting it overseas...

Also I was saying that 'tax avoidance' (as someone corrected me (as opposed to 'tax evasion' I used) is affordable to the wealthy, but Joe Schmoes business may not be able to take advantage? What size companies you think can actually do this?

I think these are good things to have in the back of your mind as you continue to grow and look forward to the day when you can start implementing some of these things... good just knowing how the world works around you...

In this day and age its as cheap as $5,000 to set up a subsidiary in a foreign country and you can legally use that for tax purposes

 

[water]

Good post! It's still the issue of getting money back into the US. But as the world becomes more global, and business people become more global, it's becoming more and more ok to keep that money overseas and re-invest there. That's probably why so many multinationals are looking for people willing/able to live overseas these days... And requiring that of people looking to move up in organizations... Also probably why working in Corporate Finance (Treasury) is a good place to be...

Personally I would love to be in that position. I would have no problem keeping my earnings overseas...

...Realized some time back that my financial future would probably not be in the USA...

Getting money back?


Man, growth is trickling in the foreseeable future in America

Get that money and flip that money in the emerging markets. I'm overseas right now making some moves.

Every decade a president will offer a tax amnesty

Same trick keep illegal immigrants coming in

 

[water]

Apple Income Taxes: Company Paid Only 1.9 Percent Tax On Earnings Outside U.S.



11/04/2012

Apple Inc. paid an income tax rate of only 1.9 percent on its earnings outside the U.S. in its latest fiscal year, a regulatory filing by the company shows.

The world's most valuable company paid $713 million in tax on foreign earnings of $36.8 billion in the fiscal year ended Sept. 29, according to the financial statement filed on Oct. 31. The foreign earnings were up 53 percent from fiscal 2011, when Apple earned $24 billion outside the U.S. and paid income tax of 2.5 percent on it.

The tech giant's foreign tax rate compares with the general U.S. corporate tax rate of 35 percent.

Apple may pay some income taxes on its profit to the country in which it sells its products, but it minimizes them by using various accounting moves to shift profits to countries with low tax rates. For example the strategy known as "Double Irish With a Dutch Sandwich," routes profits through Irish and Dutch subsidiaries and then to the Caribbean.

Other multinational corporations also use such tax techniques, which are legal.

Like other big companies, Apple leaves cash overseas.
If it brought it home to the U.S., it would have to pay U.S. corporate taxes on the money. The cash that Apple has left overseas as of Sept. 29 has mounted to a stunning $82.6 billion, up from $74 billion as of June 30.

Where Apple does differ from other companies is that it sets aside a portion of the foreign profits, marking them as subject to U.S. taxes sometime in the future.

When Apple reports quarterly results, it records that portion of the taxes as a liability, which is subtracted from its profits even though it hasn't actually paid the taxes.

Tax experts say the company could easily eliminate these "phantom" tax obligations.
That would boost Apple's profits for the past three years by as much $10.5 billion, according to calculations by The Associated Press reported in July.

While investors might rejoice if Apple suddenly added $10.5 billion to its profits, unilaterally erasing a massive U.S. tax obligation could tarnish its reputation as a relatively responsible payer of U.S. taxes.
Instead, the company is lobbying to change U.S. law so that it can erase its liabilities in a less conspicuous fashion.

Overall Cupertino, California-based Apple had net income of $41.7 billion, or $44.15 per share, in fiscal 2012. That was up 61 percent from $25.9 billion, or $27.68 per share, in fiscal 2011.


http://www.huffingtonpost.com/2012/11/05/apple-income-taxes-paid-outside-us_n_2073238.html

 

[Diomedes3000]

 

[GAMETHEORY]

Apple Income Taxes: Company Paid Only 1.9 Percent Tax On Earnings Outside U.S.



11/04/2012

Apple Inc. paid an income tax rate of only 1.9 percent on its earnings outside the U.S. in its latest fiscal year, a regulatory filing by the company shows.

The world's most valuable company paid $713 million in tax on foreign earnings of $36.8 billion in the fiscal year ended Sept. 29, according to the financial statement filed on Oct. 31. The foreign earnings were up 53 percent from fiscal 2011, when Apple earned $24 billion outside the U.S. and paid income tax of 2.5 percent on it.

The tech giant's foreign tax rate compares with the general U.S. corporate tax rate of 35 percent.

Apple may pay some income taxes on its profit to the country in which it sells its products, but it minimizes them by using various accounting moves to shift profits to countries with low tax rates. For example the strategy known as "Double Irish With a Dutch Sandwich," routes profits through Irish and Dutch subsidiaries and then to the Caribbean.

Other multinational corporations also use such tax techniques, which are legal.

Like other big companies, Apple leaves cash overseas.
If it brought it home to the U.S., it would have to pay U.S. corporate taxes on the money. The cash that Apple has left overseas as of Sept. 29 has mounted to a stunning $82.6 billion, up from $74 billion as of June 30.

Where Apple does differ from other companies is that it sets aside a portion of the foreign profits, marking them as subject to U.S. taxes sometime in the future.

When Apple reports quarterly results, it records that portion of the taxes as a liability, which is subtracted from its profits even though it hasn't actually paid the taxes.

Tax experts say the company could easily eliminate these "phantom" tax obligations.
That would boost Apple's profits for the past three years by as much $10.5 billion, according to calculations by The Associated Press reported in July.

While investors might rejoice if Apple suddenly added $10.5 billion to its profits, unilaterally erasing a massive U.S. tax obligation could tarnish its reputation as a relatively responsible payer of U.S. taxes.
Instead, the company is lobbying to change U.S. law so that it can erase its liabilities in a less conspicuous fashion.

Overall Cupertino, California-based Apple had net income of $41.7 billion, or $44.15 per share, in fiscal 2012. That was up 61 percent from $25.9 billion, or $27.68 per share, in fiscal 2011.


http://www.huffingtonpost.com/2012/11/05/apple-income-taxes-paid-outside-us_n_2073238.html

un bloody believable

the kind of games only whites play

 

[water]

un bloody believable

the kind of games only whites play

 

[Give Me 3ft.]

damn, this thread is getting better & better!

big up to all that contributed. i know i dont come across this

type of info on a daily basis. shit is truly eye-opening on how

corporate finances are handled & avoided!

 

[water]

Google Dodged $1.6 Billion In Taxes – 'It's Called Capitalism,' Says Chairman




Web giant Google avoided £1billion in tax by using the island of Bermuda as a tax haven, official documents reveal, as David Cameron calls for a global crackdown on multinationals' tax arrangements.

In an open letter to fellow leaders of the G8, written as the UK takes over the presidency, Mr Cameron asked his fellow leaders to coordinate global efforts to stop tax avoidance by multinational businesses.

Google funnelled £6billion through Bermuda last year, halving its 2011 tax bill and paying £1billion less to government coffers.

The company paid £6million in UK tax last year, funnelling 80 per cent of its global revenue through the tiny island of Bermuda, twice as much as three years ago.

Mr Cameron said co-ordinated action is needed to make major corporations and wealthy individuals pay their fair share of tax. “I do believe we all have a common interest in being able to tell our taxpayers who work hard and pay their fair share of taxes that we will make sure others do the same,” he wrote in an open letter to the G8.

Eric Schmidt, Google ’s executive chairman, has said that he is “very proud” of the way that the company arranges to pay as little tax as legally possible, saying it “is called capitalism”.
The Bermuda arrangements, first revealed last year, show the lengths to which companies will go to minimse their tax bills.

“We pay lots of taxes; we pay them in the legally prescribed ways,” he told Bloomberg. “I am very proud of the structure that we set up. We did it based on the incentives that the governments offered us to operate.”

The tax arrangements add fuel to accusations made by British MPs that Google and other firms including Starbucks and Amazon, have been “immorally” minimising its tax bills.

Matt Brittin, Google’s UK boss, said MPs were blaming companies for a system that they had designed. “Google plays by the rules set by politicians,” he said. “The only people who really have choices are politicians who set the tax rates.”

Last year, Starbucks caved into public pressure and promised to pay £20m to the Treasury over the next two years. However it was also the trigger for more criticism of “optional” tax payments.

Google sent £2.6billion of British revenue via Bermuda, legally reducing its UK tax bill by over £200million.

Mr Cameron said he wanted to get agreement on tackling cross-border tax avoidance at this year’s G8 meeting in Northern Ireland.
He told his fellow world leaders that they must start work now on preparing “bold steps” to take when they meet in Northern Ireland in June for the annual summit.
“It is clear that in 2013 the world will continue to face grave economic uncertainty.”
He said that his first priority would be to deal with the challenges in the UK but wanted the G8 to work together to “make a tangible difference by firing up economies and driving prosperity, not just in our own countries, but all over the world”.
The summit will see US president Barack Obama, Russian president Vladimir Putin, German chancellor Angela Merkel and other world leaders gather for two days at the Lough Erne golf resort in Co Fermanagh.
George Osborne has already pledged to give the OECD “more resources” to fund a clamp-down to ensure global firms pay their “proper share of taxes.” Pascal Saint–Amans, the director of the OECD’s centre for tax policy and administration, said that the issue of tax avoidance is now recognised as a “political concern.”
Google’s UK chief Matt Brittin has claimed that it is right Google pays the bulk of its taxes in America rather than Britain because it was invented there.

It claims its UK operation is “a service arm” and collects advertising revenue, the bulk of its income, via Ireland where taxes are lower.

The Irish company in turn pays them to a company in the Netherlands which is registered for tax purposes in Bermdua.

Google’s tax rate outside of the US was 3.2 per cent in 2011, its official documents disclose.



http://www.businessinsider.com/google-dodged-16-billion-in-taxes-2013-1

 

[water]

Special Report: Amazon's billion-dollar tax shield




Thu Dec 6, 2012

In 2005, Amazon rented a historic five-storey building in Luxembourg's Grund quarter, right at the bottom of a steep rock-walled valley below the old town.

By setting up in Luxembourg, and channelling sales through its units there, the world's biggest online retailer could minimize corporate taxes.

It was a move with big financial consequences.

Amazon's Luxembourg arrangements have deprived European governments of hundreds of millions of dollars in tax that it might otherwise have owed, as reported in European newspapers. But a Reuters examination of accounts filed by 25 Amazon units in six countries shows how they also allowed the company to avoid paying more tax in the United States, where the company is based.

In effect, Amazon used inter-company payments to form a tax shield for the group, behind which it has accumulated $2 billion to help finance its expansion.

Amazon revealed last year that the U.S. Internal Revenue Service (IRS) wants $1.5 billion in back taxes. The claim, which Amazon said it would "vigorously contest", is linked to its foreign subsidiaries and payments made between them.

The issue highlights the way multinationals reduce their taxes by parking intellectual property in tax havens and charging affiliates big fees for using it. Politicians in rich countries are beginning to target such practices, which have been used by other multinationals including Google and Microsoft.

U.S. Senator Carl Levin has called the tactics "gimmickry." Michael McIntyre, a tax expert at Wayne State University in Michigan, said that while Amazon's arrangement, and others like it, looked like commercial transactions, they actually only served to reduce taxes.

"The IRS shouldn't be happy about this," he said. "It sounds like they're not."

Amazon declined to answer questions about its tax affairs for this story, the latest in a Reuters series on corporate tax avoidance. In an emailed statement a spokesman said that "Amazon pays all applicable taxes in every jurisdiction that it operates within."

The group has come under scrutiny from tax departments in at least six countries over the past six years. Tax authorities in the United States, UK, Germany, France and Luxembourg declined to comment, citing rules on taxpayer confidentiality.

The Luxembourg structure, outlined by media including the Guardian newspaper in April, fulfils a corporate obligation to shareholders to maximize returns. There is no suggestion the company has broken any laws; Amazon, which started out selling books and now offers everything from tools to toys, paid an average 44 percent tax on its U.S. earnings in the last five years.

This is an examination of how Amazon set up its tax shield, and how it works.

MARKET SHARE

Amazon's first foray abroad came in 1998, when it bought online retailers in Britain and Germany and rebranded them Amazon.co.uk and Amazon.de. In 2000, it launched a French website, Amazon.fr.

At first it did little to integrate these foreign units, former senior executives say. Even product purchasing - where Amazon would later squeeze huge savings by negotiating hard with suppliers - was handled independently in different markets.

"There were no real operational synergies in our early years. The units operated largely independently," said Todd Edebohls, current CEO of recruitment website Inside Jobs, and Amazon's Director of Business Development and Sales between 1999 and 2007.

But in late 1999, accounts for the UK business show, the UK unit's principal activity changed from "marketing and selling of books via the Internet" to "the provision of services to other group undertakings."

People shopping on Amazon.co.uk would now do business with a U.S. unit registered in Delaware. There were similar changes at the German business: in effect, the fast-growing European units had become fulfillment operations just to distribute packages and offer customer support. Amazon's accounts show the bulk of its overseas revenues were now attributed to the U.S. parent.

That shift helped with a problem it faced at home.

Founded in 1995 and listed two years later, the company lost money every year until 2003. This was standard practice for a dotcom startup: Amazon focused on market share rather than profit.

But by the end of 1999 Amazon's accumulated losses were so large - more than $1 billion - that its own accountants would not let the firm recognize them as a tax asset, because it was unclear it could ever make enough profit to use them up. Bringing foreign profits home allowed Amazon to set them against U.S. losses, so the company did not have to pay tax on overseas profits, according to Stephen Shay, a professor of tax law at Harvard University.

SERVICES, NOT BOOKS

That changed in 2003, when Amazon started making a lot more profit in the United States. There was a chance the foreign earnings would now increase its global tax bill, according to Shay, because U.S. corporate tax rates were higher than in other markets such as Britain.

Amazon turned to the tiny country of Luxembourg. The Grand Duchy has a population of 500,000 - half the size of Rhode Island - and offers a variety of advantages. It's a member of the European Union, so businesses based there can sell across EU borders with less red tape. Then there's the tax rate.

Luxembourg has a headline charge on corporate income of 29 percent, but under certain circumstances it will exempt income a company earns through intellectual property by up to 80 percent, a government spokesperson said. This cuts the effective tax rate to below 6 percent. Tax advisers and academics say rates close to zero can be achieved using other methods.

In June 2003, Amazon registered Amazon Services Europe SARL in Luxembourg, establishing an office in a drab grey concrete building overlooking the central bus depot. The initials stand for Societe a Responsabilite Limitee - a limited company, liable for tax.

A month later, it told clients in the UK its terms were changing. Contracts with third-party retailers who used Amazon to sell their products would no longer be handled in the United States but with the Luxembourg unit.

In June 2004, Amazon established another Luxembourg entity - Amazon Europe Holding Technologies - whose purpose was to hold shares in Amazon group companies and "to acquire ... any intellectual property rights, patents, and trademarks licenses and generally to hold, to license the right to use it solely to one of its direct or indirect wholly owned subsidiaries."

This group was set up as a "Societe en Commandite Simple" or SCS, a type of limited partnership that a Luxembourg government spokesman said is exempt from income taxes.
It has not had any operational staff or premises, its registered address being the offices of a trust services company in an upmarket residential area west of Luxembourg's old town.

A month later, this company established a third Luxembourg company, Amazon EU SARL, whose principal purpose was to "sell, auction, rent or otherwise distribute products or services of all types" via Amazon websites.

This taxable unit was to become, on paper at least, the supplier of all goods and services to Amazon's European customers.

FROM NEVADA TO LUXEMBOURG

To be tax efficient, though, Amazon needed to shift the profit this unit would make into its untaxed parent. The easiest way to do this was for Amazon EU SARL to pay Amazon Europe Holding Technologies a fee to license the Amazon technology it would use to sell things.

There was just one problem: Amazon Europe Holding Technologies had no technology to license. Amazon's patents - including the Amazon brand and its ‘1-click' ordering software - were held by Amazon Technologies Inc, a unit registered in Nevada, Patent and Trademark Office records show.

In early 2005, Amazon did an inter-company deal that solved this problem.

Exact details of the arrangement have never been made public and Amazon declined to clarify them. Chief Financial Officer Tom Szkutak told analysts on a conference call a few weeks afterwards that the deal to create the Luxembourg operation involved shifting "certain operating assets" offshore and that it would boost the group's 2005 tax bill by $58 million but "beneficially impact our effective tax rate over time."

Amazon's Luxembourg arrangements have helped it pay an average tax rate of 5.3 percent on overseas income over the past five years, less than a quarter of the average rate across its major foreign markets.

Company accounts show that since 2005, Amazon Europe Holding Technologies started to make payments to Amazon Technologies Inc in Nevada of up to 230 million euros ($300 million) each year. At the same time it received up to 583 million euros each year from its European affiliates.

The difference stayed in Luxembourg.

Had Amazon remitted all that to the United States and then paid the headline U.S. corporate income tax rate on it, the firm would have incurred taxes of more than $700 million. But it has not and the deal has allowed Amazon's Luxembourg unit to accrue tax-free cash worth more than $2 billion.

Historically, such inter-company payments might have been treated as a taxable dividend under U.S. tax law, but a provision introduced in 1997 known as ‘check-the-box' allowed companies to have them disregarded by the IRS. Senator Levin, a Democrat, is among many U.S. politicians who want this loophole rescinded.

"HEADQUARTERS OF NIGHT LIFE"

For Amazon's tax-free money-making machine to work, it had to show it had more than a nameplate in Luxembourg.

To benefit from favorable taxation, the Grand Duchy says firms "must ensure that they give adequate substance to their presence in the country in terms of both logistics and staff." At the end of 2005, Amazon had just a dozen staff there. If tax departments around the continent were to recognize the arrangement, Amazon needed a meaningful corporate presence.

In February 2006, it transferred ownership of its UK, German and French businesses to Amazon EU SARL, and ownership of its UK and French web domains to Amazon Europe Holding Technologies. It also moved some U.S. executives to Luxembourg, hired more locals and began to call Amazon EU its European headquarters.

Filings show that in December 2006, the group relocated its Luxembourg operating units into the rented building on Plaetis Steet, a stone's throw from the English and Irish bars that lead the city-state's tourist office to describe the Grund and neighboring Clausen as the "Headquarters of Luxembourg's night life."

CASH PILE BUILDS

As the cash built up in Amazon Europe Holding Technologies, the firm started to lend to Amazon EU SARL. Besides funding international expansion, this has generated up to 45 million euros a year in interest since 2005 - all untaxed.

Today, Amazon calls its 300-person Luxembourg operation the nerve-centre of an operation which employs tens of thousands of people across the continent. It expanded into a new building, opened by Luxembourg's Finance Minister, Luc Frieden, in October.

"All the strategic functions for our business in Europe are based in Luxembourg," Amazon's head of public policy, Andrew Cecil, told UK parliamentarians in November.

At home in the United States, though, the Internal Revenue Service seems unconvinced.

Amazon disclosed in October 2011 that the IRS wanted $1.5 billion in unpaid taxes. It has declined to say exactly what transactions the charge relates to but said it was linked to "transfer pricing with our foreign subsidiaries" over a seven-year period from 2005.

"We disagree with the proposed adjustments and intend to vigorously contest them," Amazon said at the time. "If we are not able to resolve these proposed adjustments ... we plan to pursue all available administrative and, if necessary, judicial remedies."

Shay, the Harvard professor who contributed to a recent Congressional committee investigating tax avoidance, said the fact the Luxembourg unit charged a much higher price than it paid for the right to license Amazon intellectual property could open the company to an investigation into whether it is engaging in abusive transfer pricing.

"The price originally paid to the U.S. for the rights is something the IRS should want to look at," he said.

Transfer pricing is the way corporations trade goods or services between their units. Many multinationals use it.

The Organisation for Economic Co-operation and Development, which lays down the rules on transfer pricing, stipulates that it should not be used to shift profits from high tax jurisdictions to low tax jurisdictions.

The IRS declined to comment.


http://www.reuters.com/article/2012/12/06/us-tax-amazon-idUSBRE8B50AR20121206

 

[WorldEX]

There is a cost of doing business. A min $ amount is need for you to move to this level of tax haven or no one touches you.

 

[incogneg]

thats the rub with me no one has stated how you get the money back so you could potentially have tens of thousands of dollars overseas that you could never use. Plus how does the average joe use this to his advantage, this seems like a trick for the big boys





what would be some areas of concentration one might want to look into I have a little cousin starting college soon and I would want to steer her in a direction to make money and possibly be international

Take his language courses seriously. Do at least 1 semester abroad/do projects abroad... Industry, if he's into engineering, petroleum engineering, otherwise if he's not, he can major in finance or something--just do well... That's about it, unless someone has more detail...

 

[GAMETHEORY]

 

[incogneg]

So do we think that money will ever make it back into the country?

If not do we think the US economy benefits by double taxation, or if it should allow companies to bring that money back into the US?

Man, every day it seems that our financial futures lie overseas... But it pays to move on this... I've got to figure out how to accelerate

 

[LordSinister]

I'm trying to go the ex-pat route for that very reason.

 

[water]

I'm trying to go the ex-pat route for that very reason.

I know some people who used www.jobserve.com


Check it out

 

[GAMETHEORY]

So do we think that money will ever make it back into the country?

If not do we think the US economy benefits by double taxation, or if it should allow companies to bring that money back into the US?

Man, every day it seems that our financial futures lie overseas... But it pays to move on this... I've got to figure out how to accelerate

David Ricardo’s theory of comparative advantage elegantly describes principles that lead different jurisdictions to specialize in certain things: fine wines from France, cheap manufactures from China, and computers from the United States. But when we find that the British Virgin Islands, with fewer than twenty-five thousand inhabitants, hosts over eight hundred thousand companies, or that more than 40 percent of foreign direct investment into India comes from Mauritius, Ricardo’s theory loses its traction. Companies and capital migrate not to where they are most productive but to where they can get the best tax break.

 

[K Luv]

one of those not so bright guys!

Your sig is a Scarface quote on a blimp my bad master of the universe

 

[GAMETHEORY]

Special Report: Amazon's billion-dollar tax shield




Thu Dec 6, 2012

In 2005, Amazon rented a historic five-storey building in Luxembourg's Grund quarter, right at the bottom of a steep rock-walled valley below the old town.

By setting up in Luxembourg, and channelling sales through its units there, the world's biggest online retailer could minimize corporate taxes.

It was a move with big financial consequences.

Amazon's Luxembourg arrangements have deprived European governments of hundreds of millions of dollars in tax that it might otherwise have owed, as reported in European newspapers. But a Reuters examination of accounts filed by 25 Amazon units in six countries shows how they also allowed the company to avoid paying more tax in the United States, where the company is based.

In effect, Amazon used inter-company payments to form a tax shield for the group, behind which it has accumulated $2 billion to help finance its expansion.

Amazon revealed last year that the U.S. Internal Revenue Service (IRS) wants $1.5 billion in back taxes. The claim, which Amazon said it would "vigorously contest", is linked to its foreign subsidiaries and payments made between them.

The issue highlights the way multinationals reduce their taxes by parking intellectual property in tax havens and charging affiliates big fees for using it. Politicians in rich countries are beginning to target such practices, which have been used by other multinationals including Google and Microsoft.

U.S. Senator Carl Levin has called the tactics "gimmickry." Michael McIntyre, a tax expert at Wayne State University in Michigan, said that while Amazon's arrangement, and others like it, looked like commercial transactions, they actually only served to reduce taxes.

"The IRS shouldn't be happy about this," he said. "It sounds like they're not."

Amazon declined to answer questions about its tax affairs for this story, the latest in a Reuters series on corporate tax avoidance. In an emailed statement a spokesman said that "Amazon pays all applicable taxes in every jurisdiction that it operates within."

The group has come under scrutiny from tax departments in at least six countries over the past six years. Tax authorities in the United States, UK, Germany, France and Luxembourg declined to comment, citing rules on taxpayer confidentiality.

The Luxembourg structure, outlined by media including the Guardian newspaper in April, fulfils a corporate obligation to shareholders to maximize returns. There is no suggestion the company has broken any laws; Amazon, which started out selling books and now offers everything from tools to toys, paid an average 44 percent tax on its U.S. earnings in the last five years.

This is an examination of how Amazon set up its tax shield, and how it works.

MARKET SHARE

Amazon's first foray abroad came in 1998, when it bought online retailers in Britain and Germany and rebranded them Amazon.co.uk and Amazon.de. In 2000, it launched a French website, Amazon.fr.

At first it did little to integrate these foreign units, former senior executives say. Even product purchasing - where Amazon would later squeeze huge savings by negotiating hard with suppliers - was handled independently in different markets.

"There were no real operational synergies in our early years. The units operated largely independently," said Todd Edebohls, current CEO of recruitment website Inside Jobs, and Amazon's Director of Business Development and Sales between 1999 and 2007.

But in late 1999, accounts for the UK business show, the UK unit's principal activity changed from "marketing and selling of books via the Internet" to "the provision of services to other group undertakings."

People shopping on Amazon.co.uk would now do business with a U.S. unit registered in Delaware. There were similar changes at the German business: in effect, the fast-growing European units had become fulfillment operations just to distribute packages and offer customer support. Amazon's accounts show the bulk of its overseas revenues were now attributed to the U.S. parent.

That shift helped with a problem it faced at home.

Founded in 1995 and listed two years later, the company lost money every year until 2003. This was standard practice for a dotcom startup: Amazon focused on market share rather than profit.

But by the end of 1999 Amazon's accumulated losses were so large - more than $1 billion - that its own accountants would not let the firm recognize them as a tax asset, because it was unclear it could ever make enough profit to use them up. Bringing foreign profits home allowed Amazon to set them against U.S. losses, so the company did not have to pay tax on overseas profits, according to Stephen Shay, a professor of tax law at Harvard University.

SERVICES, NOT BOOKS

That changed in 2003, when Amazon started making a lot more profit in the United States. There was a chance the foreign earnings would now increase its global tax bill, according to Shay, because U.S. corporate tax rates were higher than in other markets such as Britain.

Amazon turned to the tiny country of Luxembourg. The Grand Duchy has a population of 500,000 - half the size of Rhode Island - and offers a variety of advantages. It's a member of the European Union, so businesses based there can sell across EU borders with less red tape. Then there's the tax rate.

Luxembourg has a headline charge on corporate income of 29 percent, but under certain circumstances it will exempt income a company earns through intellectual property by up to 80 percent, a government spokesperson said. This cuts the effective tax rate to below 6 percent. Tax advisers and academics say rates close to zero can be achieved using other methods.

In June 2003, Amazon registered Amazon Services Europe SARL in Luxembourg, establishing an office in a drab grey concrete building overlooking the central bus depot. The initials stand for Societe a Responsabilite Limitee - a limited company, liable for tax.

A month later, it told clients in the UK its terms were changing. Contracts with third-party retailers who used Amazon to sell their products would no longer be handled in the United States but with the Luxembourg unit.

In June 2004, Amazon established another Luxembourg entity - Amazon Europe Holding Technologies - whose purpose was to hold shares in Amazon group companies and "to acquire ... any intellectual property rights, patents, and trademarks licenses and generally to hold, to license the right to use it solely to one of its direct or indirect wholly owned subsidiaries."

This group was set up as a "Societe en Commandite Simple" or SCS, a type of limited partnership that a Luxembourg government spokesman said is exempt from income taxes.
It has not had any operational staff or premises, its registered address being the offices of a trust services company in an upmarket residential area west of Luxembourg's old town.

A month later, this company established a third Luxembourg company, Amazon EU SARL, whose principal purpose was to "sell, auction, rent or otherwise distribute products or services of all types" via Amazon websites.

This taxable unit was to become, on paper at least, the supplier of all goods and services to Amazon's European customers.

FROM NEVADA TO LUXEMBOURG

To be tax efficient, though, Amazon needed to shift the profit this unit would make into its untaxed parent. The easiest way to do this was for Amazon EU SARL to pay Amazon Europe Holding Technologies a fee to license the Amazon technology it would use to sell things.

There was just one problem: Amazon Europe Holding Technologies had no technology to license. Amazon's patents - including the Amazon brand and its ‘1-click' ordering software - were held by Amazon Technologies Inc, a unit registered in Nevada, Patent and Trademark Office records show.

In early 2005, Amazon did an inter-company deal that solved this problem.

Exact details of the arrangement have never been made public and Amazon declined to clarify them. Chief Financial Officer Tom Szkutak told analysts on a conference call a few weeks afterwards that the deal to create the Luxembourg operation involved shifting "certain operating assets" offshore and that it would boost the group's 2005 tax bill by $58 million but "beneficially impact our effective tax rate over time."

Amazon's Luxembourg arrangements have helped it pay an average tax rate of 5.3 percent on overseas income over the past five years, less than a quarter of the average rate across its major foreign markets.

Company accounts show that since 2005, Amazon Europe Holding Technologies started to make payments to Amazon Technologies Inc in Nevada of up to 230 million euros ($300 million) each year. At the same time it received up to 583 million euros each year from its European affiliates.

The difference stayed in Luxembourg.

Had Amazon remitted all that to the United States and then paid the headline U.S. corporate income tax rate on it, the firm would have incurred taxes of more than $700 million. But it has not and the deal has allowed Amazon's Luxembourg unit to accrue tax-free cash worth more than $2 billion.

Historically, such inter-company payments might have been treated as a taxable dividend under U.S. tax law, but a provision introduced in 1997 known as ‘check-the-box' allowed companies to have them disregarded by the IRS. Senator Levin, a Democrat, is among many U.S. politicians who want this loophole rescinded.

"HEADQUARTERS OF NIGHT LIFE"

For Amazon's tax-free money-making machine to work, it had to show it had more than a nameplate in Luxembourg.

To benefit from favorable taxation, the Grand Duchy says firms "must ensure that they give adequate substance to their presence in the country in terms of both logistics and staff." At the end of 2005, Amazon had just a dozen staff there. If tax departments around the continent were to recognize the arrangement, Amazon needed a meaningful corporate presence.

In February 2006, it transferred ownership of its UK, German and French businesses to Amazon EU SARL, and ownership of its UK and French web domains to Amazon Europe Holding Technologies. It also moved some U.S. executives to Luxembourg, hired more locals and began to call Amazon EU its European headquarters.

Filings show that in December 2006, the group relocated its Luxembourg operating units into the rented building on Plaetis Steet, a stone's throw from the English and Irish bars that lead the city-state's tourist office to describe the Grund and neighboring Clausen as the "Headquarters of Luxembourg's night life."

CASH PILE BUILDS

As the cash built up in Amazon Europe Holding Technologies, the firm started to lend to Amazon EU SARL. Besides funding international expansion, this has generated up to 45 million euros a year in interest since 2005 - all untaxed.

Today, Amazon calls its 300-person Luxembourg operation the nerve-centre of an operation which employs tens of thousands of people across the continent. It expanded into a new building, opened by Luxembourg's Finance Minister, Luc Frieden, in October.

"All the strategic functions for our business in Europe are based in Luxembourg," Amazon's head of public policy, Andrew Cecil, told UK parliamentarians in November.

At home in the United States, though, the Internal Revenue Service seems unconvinced.

Amazon disclosed in October 2011 that the IRS wanted $1.5 billion in unpaid taxes. It has declined to say exactly what transactions the charge relates to but said it was linked to "transfer pricing with our foreign subsidiaries" over a seven-year period from 2005.

"We disagree with the proposed adjustments and intend to vigorously contest them," Amazon said at the time. "If we are not able to resolve these proposed adjustments ... we plan to pursue all available administrative and, if necessary, judicial remedies."

Shay, the Harvard professor who contributed to a recent Congressional committee investigating tax avoidance, said the fact the Luxembourg unit charged a much higher price than it paid for the right to license Amazon intellectual property could open the company to an investigation into whether it is engaging in abusive transfer pricing.

"The price originally paid to the U.S. for the rights is something the IRS should want to look at," he said.

Transfer pricing is the way corporations trade goods or services between their units. Many multinationals use it.

The Organisation for Economic Co-operation and Development, which lays down the rules on transfer pricing, stipulates that it should not be used to shift profits from high tax jurisdictions to low tax jurisdictions.

The IRS declined to comment.


http://www.reuters.com/article/2012/12/06/us-tax-amazon-idUSBRE8B50AR20121206

Laundering Money through a Front Company​

The Case of Pavel Lazarenko, Former Prime Minister (Ukraine)The European Federal Credit Bank (EuroFed) featured prominently in the U.S.

prosecution and conviction of former Ukrainian Prime Minister Pavel Lazarenko on charges of money laundering and conspiracy to commit money laundering.a In early 1997, when Lazarenko faced corruption allegations in Ukraine and believed that he soon would lose his post, he and his coconspirator Peter Kiritchenkob learned that EuroFed, an offshore bank domiciled in Antigua, was for sale and agreed to buy it. According to an opinion issued by the U.S. District Court for the Northern District of California, “Lazarenko opened his own personal account at EuroFed, and in August 1997, Lazarenko and Kiritchenko purchased a 67 percent interest in the bank.” The indictment against Lazarenko had alleged that “It was further part of the conspiracy that in May of 1997, Kiritchenko and Lazarenko began negotiations to purchase, and by August 7, 1997, purchased, a [67 percent] share of European Federal Credit Bank in St. John’s, Antigua, in order to facilitate the transfer of money and to further conceal and disguise the nature, origin, location, source, ownership and control of the money that was paid for the benefi t of Lazarenko.” The indictment added that “etween May and September 1997, Lazarenko transferred approximately US$70 million into accounts he and Kiritchenko
controlled” at EuroFed.

In 2005, the U.S. Department of Justice filed a civil asset forfeiture case to seize Lazarenko’s assets, including approximately US$85.5 million alleged to have been formerly on deposit in accounts held for his benefit at EuroFed.

white moves....

 

[Problematic]

fire drops fellas

I'm trying to go the ex-pat route for that very reason.

http://www.sovereignman.com/