Yes, the US is much stricter. I'm not a US citizen so those rules are not applicable to me personally.
You said above "you won't be subject to taxes in the US on those earnings"... so I'm confused. Anyways, that's not correct.
!00% correct. Unless you are really a broker/dealer and it is an operating entity the CFC rules will have you taxed whether you repatriate or not
What interest are you earning through these HSBC Sweep Accounts? I've was shown a scheme about 2 years ago to move FDIC insured funds from their Prospect Heights, IL Branch to their Mumbai, India branch overnight earning 9% than to their Sao Paulo, Brazil branch for the AM open for another 9% than back to the US by noon for FDIC insurance. The HSBC banker allegedly would only charge a flat 2% service fee to administer the sweeps. This was done under a Trust Agreement through a non interest bearing US business account and foreign interest bearing business accounts. I was skeptical of this scheme cause if it worked as presented every corp would borrow as much cash as possibly and just sweep for interest. The other concern was it seemed to be a leveraging scheme allowing the bank to record my deposit 3 times on their books in different branches allowing them to leverage the same $ from 30/1 here in the US to 90/1 or whatever the foreign branches are allowed.
Whatever standard local rates are. I also have access to fixed-tem deposits, and structured finance products... I have no ideas about the complicated scheme you describe, but in my experience nothing comes for free...
Swan and FT are basically correct if you are a US citizen - there is no tax advantage to having an offshore account unless you are interested in purposeful tax evasion. Seriously. And there is no way you are going to be able to move it into the US without paying taxes and interest/penalities and risking possible fines and jail time. International Tax Lawyers registered to represent US clients in Federal Court are very expensive as well - top tier billable hourly rates.
OP if you have to ask you can't afford it... Bottom line - take post-tax dollars, dump them offshore into a holding or shell company. make profits and don't pay any taxes on them... break the law and have your lawyer, accountant, mom, friends, etc. bring cash/goods back into the US for you small amounts at a time. Between the cost of the travel expenses + the cost of converting cash >>> goods you can sneak into the USA >>> Dollars... You'll realize its just about an even wash and you should have paid taxes... that is unless you are rich enough to buy a mega-yacht based out of the Caymans or something...
I would add that both the financial and criminal risks are present whether you move the money back to the US or not. The law here is clear. If you do not disclose the accounts -- and pay appropriate taxes as due -- you have committed a felony. It has nothing to do with what you do or do not do with the funds.