Family Limited Partnerships, hereinafter “FLP’ are a special type of limited partnership, that can be used in conjunction with an estate plan, an asset protection plan, as well as a financial plan.
What is this wondrous vehicle and how does it work? The purpose of this article will be to address these concerns.
IRS NOT ALWAYS CORRECT
In Center vs. Commissioner, 1995 TCM 311, the Tax Court ruled that an IRS Notice of Deficiency is not entitled to a presumption of correctness, if the IRS does not produce any evidence in support of its determination. In Center, the taxpayer did not provide any proof of his income during the year at issue. He had not filed a tax return. The IRS took the earnings from a prior year and used the consumer price index to compute the alleged income for a subsequent year. The taxpayer denied he had made that much money. The taxpayer petitioned the Tax Court saying that the amount of income was wrong.
Offshore Asset Protection Trusts are becoming the rage of the nineties. The setting up of an Asset Protection Trusts involves the initial structure of a trust in an offshore jurisdiction. Properly drafted this gives one protection against creditors and eliminates the creditors abilities to attach assets.
For those of you who are a bit skeptical on the usage of offshore trusts and entities, please be aware that recently reported in the Business & Economics Section of the European, a European-based weekly newspaper, that London-based, Price Waterhouse and Ernst & Young have been consulting with the Island of Jersey to promote new laws allowing limited liability partnerships to become part of the Jersey legal systems. This would limit the partners from those UK firms that have set up limited partnerships on the Island of Jersey to only be liable for the amount of their interest in the firm. Current United Kingdom law indicates partners that they are personally liable for any claims against the partnership.
Continue reading “ASSET PROTECTION SOUGHT BY BIG SIX ACCOUNTING FIRMS”
In James F. Boccardo vs. Commissioner, 56 F.3d 1016 (9th. Cir. 1995) the 9th Circuit Court of Appeals modified well established case law and benefited personal injury lawyers. The 9th Circuit Court of Appeals held that all preparation and trial costs paid by the Boccardo personal injury firm, were deductible in the year paid, even through the cases might be settled years down the road. It might not seem like a big change for the public, but there are many ramifications for allowing the deductibility of expenses that might later be repaid. This article will analyze the Boccardo case and its meaning.
Good morning. My name is Nicholas Prouty, and I am the Managing Partner of Putnam Bridge an investment firm located in Santurce. I appreciate the invitation to speak today and share some thoughts with regard to the role technology will play in the economic turn-around of Puerto Rico. However before beginning, let me first address the recent ratings downgrade by Standard & Poor’s. My fundamental belief in Puerto Rico remains absolutely unchanged – Puerto Rico is in the process of a great reinvention and the smart money knows it and that money will soon make its way into your hands.
Captive insurance companies have been growing by leaps and bounds. A captive is an insurance company that insures the risks of its parent company. It is owned by a parent or at times by the shareholders of the parent company. The operating entity insures all or part of its risks with its captive company. The captive may reinsure some or all of such risks, or may retain such risks. The benefits of a captive may be many, but the primary goal is to retain the profit that would have been made by an outside third party insurance company or to provide coverage where coverage would not be available. There are many differing types of captives, based upon what the needs of the parent company or its owners are. The most commonly encountered types of captives according to Wikipedia are as follows:
Continue reading “CAPTIVE INSURANCE COMPANIES FOR CLOSELY HELD BUSINESS AND THEIR OWNERS”
It seems almost everywhere you look these days, bankrupt governments are raising taxes.
But no matter where you are, there are always solutions to do something about it.
For example, if you’re an Australian taxpayer, you can move to Norfolk Island and pay minimal tax. If you’re British, you can structure your assets in Gibraltar or the Channel Islands.
Continue reading “How You Can Move To Puerto Rico and Pay Almost Zero Tax”
Congratulations to incoming President Trump. Yet many have questioned what happens to income tax planning?
First, 2016 tax rates are at 39.6% for individuals and 39% for Federal Corporate rates. State taxation has not changed and has a top rate of 13.3% in California. The additional Medicare taxes are still the law, but will hopefully be eliminated in coming years.
As the U.S. Treasury Department continues to tighten its noose around offshore accounts, a new tax haven has sprung up under its nose in the Caribbean. Welcome to Puerto Rico–island of tropical breezes, and (for new arrivals only) a 0% tax rate on certain dividends, interest and capital gains.
Puerto Rico is about the same size as Connecticut but with more palm trees, twice the unemployment rate, a third the median household income and a tiny fraction of the hedge funds–a deficiency the financially teetering territory aims to correct by turning itself into a refuge for tax-oppressed millionaires and billionaires.
Continue reading “Puerto Rico Bids To Become New Age Tax Haven”
Despite Puerto Rico’s massive debt crisis, Paulson sees big profits ahead. He has plowed “quite a bit” an estimated $1.5 billion of his personal wealth into buying hotels, a resort and office buildings on the island. Paulson compares Puerto Rico today to Miami in the 1980s.
“It’s similar to that period in Miami’s history,” Paulson said Thursday at the Puerto Rico Investment Summit. “There was a lot of real estate on the beach, lots of abandoned buildings and vacant lots. That was definitely the best time to buy [in Miami].”
Continue reading “Billionaire to Put His Money in Puerto Rico”