I Streber too. @dw31583 If you are not a US citizen or not a US citizen anymore, ironically it's the USA. FATCA is in practice a 1 way street. You may want to have a look at HK and possibly Japan as well, depending on your residency location they aren't inclined to share even if they are a signatory(I think HK currently only shares with UK + 1 other country).
You may still get numbered accounts just like in Switzerland but now they have to identify you because of the AEOI. They signed up almost immediately after the Panama papers. If I remember correctly even before Panama itself. I had huge expectations from Lebanon as well. Taiwan is still playing though but they don't have any reputable international brokers.
I know, you're right. I've posted about the US previously. However the US is a tricky thing because they're not as secretive as you might think. The IGAs that they have signed with various countries are definitely not one way streets. Basically there are two types of IGA that they have signed for FATCA. 1) the other country reports to the US, the US doesn't report at all, this is the rarest 2) the other country reports to the US, the US reports about individual accounts holders So there are countries which falls into the first category and as you can see the bigger and wider loophole is the second category because they only report about individual accounts. Consequently if you're using a US LLC with a BofA account and a US brokerage account then you're good to go. It was all nice and shiny until FXCM decided to close their US unit and now there is not a single real fx broker in the US. IB is fine but FXCM Pro was far better. Gain Capital is a market maker according to their license so the US may work for share traders and futures traders but not for fx traders due to the lack of ECN/DMA/STP brokers. I haven an EU citizenship so thank God I don't have to worry about FATCA. Btw it's not just HK and Japan but Switzerland doesn't have a category 2 IGA with the US either. If there would be any real fx broker then it would be a nice loophole. However, be warned, the US has accepted a law in the last months of the Obama administration that the US is going to require banks in every single state to collect information on the companies' beneficial ownership data from 2018. So I think they'll either join the AEOI or will report on entities within the IGAs.
Hi @dw31583 Apologies if this has already been discussed (I'm still making it thru this very long thread, great commentary all around). Is living for parts of the year in more than one country (as a non-resident tourist) a possible solution? If one was to achieve non-resident status in his/her current country (rules on this vary by country of course), then proceed to not spend >183 days/year in any given country thereafter, what are the tax ramifications, if any? edit - ok just getting caught up, I see that's been covered in spades, though rather non-specifically.. I'm not following... A tourist, non-resident & unregistered in the country of visitation, remitting zero income into the country - what exactly makes it "really, really easy" for said country to tax them? It sounds like it would take a nearly impossible audit/investigation (internationally subpoenaing a foreign tourist's business/trading records?). And with no local assets to seize, it could easily result in a tremendous waste of govt resources in an absolutely-certain drawn out court battle. If unsuccessful, it could also pose potentially disastrous consequences to said country's tourism industry (why would any rich business owner ever risk visiting a country that lays claim to income earned while visiting)?
According to the link below from OECD and regarding CRS, previously posted, you are right, although HK separately signed several TIA over the years and banks there tend to check now that their customers are tax compliants and are keen on avoiding any scandal. Many of the signatories show 0 agreement to apply CRS btw in that list, including China, and there are voices hinting that China will use it mostly as an unilateral way to get information on funds its citizens keep abroad, starting with probably the most fragile territory in this power struggle and a long term favourite among mainlanders, namely Hong Kong. http://www.oecd.org/tax/automatic-e...framework-for-the-crs/exchange-relationships/
Sorry about the mess in the post above, didn't mean to get it all red, the active link is the bottom line. Besides if one thinks the many documented territorial taxation systems are not exploitable, Monaco is an issue because the tax free perks are for individuals, Bahamas is too remote, and in UAE it's not safe to stack one's ferrari with a whole herd of siliconed hookers than sure life gets complicated. If you drive too fast and a boob explode you might well cause a massive car crash. Driver beware.
(I would have made a 2nd edit but I just missed the one-hour edit window.) Tax residency, as defined by nearly every country on earth, is spending 183 days or more in a country during a tax year. You first mention 60 days in the quote above, then several pages later jump to 90 days. Where are you getting either of these numbers from?
on the subject of Monaco I have heard that it is now possible to get Monaco residency by depositing as little as 300k euros in a Monaco bank. You can rent a studio there for 2500 euros a month so 30k euros a year. You can then live in France or Italy as long as you are careful to stay non resident for tax purposes in those countries. This would be easy to do as an individual as you keep ties minimal, as a family much harder as schools, doctors create links. The coffee & pastries are sublime, easy access to hookers. http://m.webcam-hd.com/monte-carlo-....1400.societe-des-bains-de-mer_port-hercule/0
Tax residency is defined differently by each country. In many countries you can become a tax resident without spending there a single day if you own (incl. via a company) or rent a property. Germany is a great example to this rule but there are many others, mostly European and other developed countries. There is only a couple of countries where you can consistently spend 180 days without getting taxed. Most countries' rules says that if you visit the country year by year then you can spend less than 180 days there without becoming a resident. The rules varies heavily by country. You can remain in the safe zone if you: - spend max. 90 days in a country but there are countries where you become a resident in 30 days ie. Switzerland - do not own or rent a property in the country - do not have a company in the country - do not have a car in the country - do not have a mobile phone in the county - do not have an insurance from that country - do not have a family in the country - do not have a personal bank account in the country or if you have then make sure that you have far more bank accounts in other countries In other words, if you're clearly just a tourist then you're safe. If you have any of these then you may be deemed a resident if you spend too much time there. I heard cases when people in Germany and Australia became tax residents because of a bank account or a P.O. box. Obviously those people also spent significant time (90+ days) in the country. Furthermore, just because you're a non resident, it doesn't mean that your income is not taxable in the country you're visiting. For instance if you're trading from a country, let's say Singapore, then you could be taxed on your trading income. Only on those positions which were both opened and closed in Singapore. Needless to say, only if they find you, a tourist, interesting enough to ask many information about your financial and tax situation. It's highly unlikely just like LuisHK said. What I'm saying is just the law but it's highly unlikely to happen. Consequently if you remain a tax non resident and you visit countries as a tourist for let's say 30 days and you trade from your hotel room while you have your tax residency in Panama, then there is a 99.99% chance that you won't pay tax anywhere.
You're funny but real life is a bit different Luis. First of all, you should have read at least Streber's blog post. TIEAs are irrelevant when it comes to banking information. It only matters if the authorities are trying to get information from your company ownership. Banking information gets exchanged automatically within the CRS. Monaco is a great place, we all agree in that. It's quite boring though so it's up to you whether that kind of life suits you or not. Personally I wouldn't live in a shoebox for $15 million where there is nothing to do in in 60% of the year. Bahamas is far better because you can also use companies and any other structure to enjoy some financial privacy (I'm not talking about taxes) plus you can get a nice house for a few millions. Dubai is a different place. I have a strong feeling that you have intentionally skipped the article that I linked about the two Britons who get jailed because they greeted each other with a kiss on the cheek in a restaurant in Dubai. Well, if you're willing to live like that then Dubai is fine as well.