Two Resolutions for New Year 2017 that Guarantee to Reduce the Cost of Tax
1) Deferral of tax on carried interest reduces the cost of tax.
Here is how to extend the tax holiday on carried interest retained offshore.
The total estimate of carried interest that will be taxed in 2018 is between one billion and one hundred billion.
Hedge fund principals know that deferred management and incentive fees retained offshore would become subject to tax in the 2017 tax year, whether or not funds are repatriated.
Since 2009, hedge fund principals have known that deferred management and incentive fees retained offshore would become subject to tax in the 2017 tax year, whether or not funds are repatriated. Internal Revenue Code Section 457A, along with IRS Notice 2009-8 and Revenue Ruling 2014-18, sets forth the particulars for taxation of this deferred compensation. If Revenue Ruling 2014-18, sets forth the particulars for taxation of this deferred compensation. If you are a hedge fund manager who has accumulated a significant deferred compensation balance offshore, 2017 will be a tax year of reckoning. Any funds deferred and held offshore will become subject to tax at your highest marginal tax rates. The imposition of this tax can be avoided.
The solution then becomes, ”How to make the transition under IRC 402(b) section and compliantly to tax avoidance law?”
2) Deferral of Gains and Accumulations Reduces the Cost of Tax. Coming up in 2017 we have the ”Son of FATCA” which is the Automatic Exchange of Financial Information (AEoI) i.e. over 130 countries. This type of account is carved out as exempt from financial information reporting at the Institutional level and reporting of beneficiaries are excluded.
The solution then becomes, ”How to make this government regulated, tax rules compliant and excluded account is a financial account that individuals can use to defer income on gains and accumulations?”
The Only Type of Foreign Financial Account that U.S. Persons can use for Deferral of Income and Carried Interest on Capital Overseas – Get the Free Report Here.