To: Michael Bakunin who wrote (71822 ) 12/13/1999 2:46:00 AM From: nihil Respond to
Yes, one with foreign assets has notification requirements for foreign source and foreign trust income. But the object here is to avoid distribution of foreign source income. Conceivably the eventual beneficiaries might have to expatriate themselves to enjoy distribution (and avoid notification), but I doubt it. I can manufacture half a dozen loopholes myself, and I am not a lawyer. A trust, after all, is another tax entity from the grantor and the beneficiary. How about, I borrow $1,000,000 from my Channel Island bank and deposit it in a trust in another Cayman Islands bank (I may want to shuffle it through a few nominees). On the security of certain postage stamps which I deliver to the lender. I default in Jersey and they auction my stamps and pay the proceeds after expenses to Cayman bank. (If necessary we could stick any several dozen securities trades in there. None of these transactions appear in my US tax dossier because of CI and Cayman bank secrecy law. One must be careful to avoid money laundering (i.e. use real transactions). Unfortunately, I am not an international tax attorney, but such there are.
