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re: 77,000 different foreign banks in 70 countries reporting to IRS now
Posted on 6/5/14 at 10:40 am to Tiger n Miami AU83
Posted on 6/5/14 at 10:40 am to Tiger n Miami AU83
If you aren't an attorney you aren't prepared an shouldn't be doing planning. Be an accountant. That is what you are trained for If you want to plan go to law school then get your LLM. If an accountant is doing any planning hopefully it's not for anyone with substantial assets. That would be dangerous. I would imagine the lawyers at your job do the heavy lifting.
1
Posted on 6/5/14 at 11:11 am to BBONDS25
Dunno. Is 50-100 million substantial to you?
And yeah, I write structuring memos for investors, setting up holding structures in "tax havens" considering numerous treaties,jurisdictions, ftc's, withholding requirements and so forth. And I've written withholding structuring and analysis for a fortune 500 companies with independent contractors who were athletes and entertainers all over the globe. And it's me that does the heavy lifting.
Not to mention inbound investment structuring including multi tier pships with foreign trusts and corps with two classes and earnings stripping for foreign investors. Not to mention ICS disc set up for arbitrage.
I'm a bit unique. And it is usually the attorneys asking me questions in these areas, not the other way around. And yeah, I probably make more than some of them.
And yeah, I write structuring memos for investors, setting up holding structures in "tax havens" considering numerous treaties,jurisdictions, ftc's, withholding requirements and so forth. And I've written withholding structuring and analysis for a fortune 500 companies with independent contractors who were athletes and entertainers all over the globe. And it's me that does the heavy lifting.
Not to mention inbound investment structuring including multi tier pships with foreign trusts and corps with two classes and earnings stripping for foreign investors. Not to mention ICS disc set up for arbitrage.
I'm a bit unique. And it is usually the attorneys asking me questions in these areas, not the other way around. And yeah, I probably make more than some of them.
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