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Collective Investment Scheme is the legal denomination.
>I have to confess I do not understand what you mean when you say 'a
collective
>investment scheme (in the Channel Islands, for example)'.
>
>Who is making the 'investment' decision for the scheme, and, more
importantly,
>where is he located? If the decision maker is in the US, I would think it
hard
>to claim the 'scheme' is in the Channel Islands, but not in the US, for tax
>purposes.
>
There are several ways around this. You (Dan), for example, could be engaged
on a contract basis to make decisions, or to give advice which would be
little more than taking advice from a newsletter. The board of Directors
would then act (or not) on your recommendations. You would be paid a fee for
this which would be taxable under US law. However, the profits earned by the
investment remain those of the company until granted as dividends.
Just a quick thought in answer to your question. As I said before each case
has to be studied on its merits, and demerits.
Regards,
Gram.
>Regards
>DanG
>
>Gram wrote:
>
>>
>> >In other worlds, it is hard to cheat the taxman in the US, even when you
>> >go abroad.
>>
>> Also not so straightforward. It is not a question of cheating, not a
>> question of evasion, but a question of planning - organizing your affairs
>> (fiscal and none) in a suitable to you and the taxman.
>>
>> A collective investment scheme (in the Channel Islands, for example)
could
>> manage money from there trading in most exchanges (futures, options,
forex,
>> etc.) The problem arises when the members take their share of the
profits.
>> How much they can keep personally depends on where they physically reside
>> (and oone or two other factors).
>> Of course, this is summary, as each case needs to evaluated on its own
>> merits.
>> What is erroneous is the notion that the IRS (or anyone else) can stick
its
>> nose, willy nilly, into the running of a company based in another
country,
>> especially if it is run in line with that country's laws.
>>
>> Double tax laws are of course to be taken into account where
approporiate.
>> >Regards
>> Gram,
>>
>> >DanG
>> >
>> >
>> >
>
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