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Providing essential tax news and information for globally
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'Low-tax' business and investment in the top 50 jurisdictions covered in
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A topical guide to offshore e-commerce focused on tax and regulation.
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Offshore
Investment: Country-by-Country
Analysis of Offshore Investment Funds;
Stock
Exchanges and Trusts, with an Analysis of
the US QI Regime
Each
Lowtax Intelligence Report opens with a series of
recent relevant news highlights.
Descriptive Notes And Contents List
The
first section of the report studies the booming
offshore funds sector. We analyse the growth
of offshore funds from humble beginnings until
now they challenge their onshore competitors,
using the Internet to keep up with innovation
in marketing and product development. For the
eighteen top offshore jurisdictions we describe
the funds sector and its legislative base, noting
recent developments.
The
second section of the report studies offshore
stock markets, making the controversial claim
that one day they will rival and even eclipse
their grand onshore counterparts by linking
with electronic newcomers to develop pools of
liquidity in low-tax jurisdictions. There are
thirteen offshore stock-markets and for each
one we describe its history, its regulatory
environment, its size and its growth pattern.
The
Trusts section of the report studies the 20
top jurisdictions which offer trust regimes.
It's a fairly well known fact that the trust
originated in England many hundreds of years
ago, and that its purpose was to preserve assets
against depredations occurring through death,
matrimonial and family squabbles, spendthrift
descendants and the like. Taxation at death
was one of the incidents that trusts were effective
against, but they were not particularly designed
to guard against the taxation of income or capital
during the settlor's life, because such taxes
were not a major threat to wealth at the time,
and anyway a domestic trust was a taxable person
in itself. Now the trust is a major component
of asset protection structures, as well as having
many business uses.
The
final section of the report studies the draconian
new US withholding tax rules and qualified intermediary
status which applied from January 1 2001. The
new regime affects every non-US based investor
with US source income, and every non-US based
financial institution which handles such income.
We explain the legislation and give its full
text, along with a copy of the contract qualified
intermediaries sign with the IRS, which effectively
turns them into tax collectors! We also set
out the rules to be followed in each of the
countries 'approved' by the IRS.
CONTENTS
Offshore
Investment Funds
Introduction: What is an Offshore Investment
Fund
Characteristics
of the Offshore Fund Industry
Recent
Developments in the Offshore Fund Industry
Onshore Responses To The Hedge Fund Boom
The Internet's Role In The Offshore Investment
Process
Offshore
Investment Funds: The Jurisdictions
Bahamas,
Bermuda, British Virgin Islands, Cayman Islands,
Cyprus, Gibraltar, Guernsey, Hong Kong, Ireland,
Isle of Man, Jersey, Luxembourg, Malta, Mauritius,
Netherlands Antilles, Seychelles, Switzerland
and Turks & Caicos Islands.
Offshore Stock Exchanges
Introduction: The Evolution of Offshore Stock Exchanges
Enter the Internet
Enter the OECD
The Jurisdictions with Stock Exchanges
Bahamas
Bermuda
Cayman Islands
Costa Rica
Cyprus Guernsey Hong Kong
Ireland
Luxembourg
Malta
Mauritius Panama Switzerland
Offshore Trust Regimes
Introduction: The History of Offshore Trusts
Development of Professional Competence in the Jurisdictions
What Future for the Trust
The Jurisdictions
Bahamas
Barbados
Bermuda
British Virgin Islands
Cayman Islands Cook Islands
Cyprus Gibraltar Guernsey
Isle of
Man
Jersey
Liechtenstein
Madeira
Malta
Mauritius Monaco Panama Seychelles Turks &
Caicos Vanuatu
The
US Qualified Intermediary Regime
Introduction: What The Legislation Does
Annex I: Full Text Of IRS Tax Code Section 1.1441
Annex II: 'Attachments' For 48 Approved Countries
All Intelligence Reports are updated on a weekly
basis with the latest relevant information,
and constitute the most complete authoritative
material available in their various subject
areas.
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