Bank finance articles and tips

In most cases, when an individual who creates and transfer assets to a Trust (the maker or "Settlor" of the Trust), is also a beneficiary of that Trust, the Trust provisions will not protect the Settlor/beneficiary's creditors from reaching the assets of the Trust. On the other hand, the law of many foreign jurisdictions provides that when a Settlor transfers assets to an Offshore Asset Protection Trust that Trust can protect the assets of the Trust even though the Trustor is a beneficiary of the Trust.....

Subpart F rules limit deferral of foreign income by owners of foreign corporations. Earnings of a foreign corporation owned by U.S. taxpayer(s) are generally not taxable in the U.S. until remitted. This general rule is subject to several anti-deferral regimes, including Subpart F. U.S. shareholders (generally U.S. persons owning 10% or more of the vote) of a controlled foreign corporation (CFC) must include in their income currently certain types of income earned by the CFC, under the provisions of Subpart F. These inclusions are accompanied by a deemed-paid credit for corporate shareholders that operates identically to the deemed-paid credit for dividends. A Subpart F inclusion, however, is not a qualified dividend eligible for the reduced 15% tax rate.