See also http://www.irs.gov/instructions/i8854/ch01.html (877 taxation of former citizens and long-term residents)
But practically speaking are you saying that only they can afford the legal team to put such a thing together? I would think the IRS would be less interested in letting a decent sized corporation get any tax breaks by going off shore? It takes about 10,000 me's to make one of them after all...
No; there are a number of ways; operate a financial institution, structure the deal to avoid CFC and PFHC, set-up in the USVI, etc.. None are cheap or do it yourself projects ...
Hmmm...That makes me curious as to why the Congress/IRS ever allowed such "loop holes"?? How could such an animal ever have evolved??
On the above, the cost is probably the least of your problems. If you, as an individual, want to have control of the company, coming up with the above mentioned structures is nearly impossible. You might as well just set up a foundatin in Lechtenstein with a corporate structure in some tax haven country where you could trade via an "annonymous" account. But the question is why do you need this? I would think that anything you try to setup to avoid paying taxes ( not evade ) would stress you out so much that your trading will be impacted. I know so many people who have set up certain "expat" structures to get the lowest tax possible and not one of them are confidant in the structure. Come April - They are totally stressed. Not sure which country you want to have dual citizenship with but if you are in Europe - the tax consequences will most likely be of little benefit. Dual citizenship means having to abide by the laws of the country where you are currently residing, usually this will not be as favorable as the US. Offsetting the tax paid in one country only gives you a writeoff in the USA - thus you may have an accrued amount which you can deduct in the future - but it is not cash back. I have seriously thought about getting dual citizenship but just felt that it was not worth it given my current circumstances. If you are in Europe - one benefit is that you can apply for all those high paying EU government jobs in various countries. Another benefit is that you would not have to go through the legal hassle of getting a work permit, etc etc etc and all the other small hassles of living in a foreign country.
Most countries read everywhere expect the US tax you on a residency basis, if you live there they tax you on your worldwide income. So if you are a no-US citizen moving to Monaco, Switzerland or Bermuda and trading from there solves all your problems notice its not the dual citizenship that helps its the actual moving and living there normally for greater than 182 days a year.
you don't decide anything. If you are an individual with an employment contract you file taxes in both countries. ( assuming you are sticking around for over 183 days ). Again a generalization, but the point is you do not decide anything. If you are a corporation it gets a bit more complicated but the logic is still the same. As a very broad generalization no matter how you are structured you will have to file in the USA. Unless you got liquid assets over 10 million usd no one who knows this stuff is going to talk to you. Why?, because it is just not worth it if you are not loaded. offshorepress dot com is a nice place to start to get a general indication of how this is not so straightforward. Last thing, "using" your wife to avoid taxes in the USA is illegal and simply not bright. General things to consider is: getting the money into your account so that you can invest it in the USA, tax controls of european countries are a nightmare, trading account needs to be set up presumably in her name - and if she has a job and she has an audit - how will she explain trades made during the day while she is at work?
i agree but with monaco you have to buy not rent i believe at least a 70 sq meter apartment may not sound like much but try to find something for less than 500k euro, and i am pretty sure this will not solve his USA tax problem