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It's not as easy as it used to be because of all the new AML/KYC regulations, but doing something like this through bitcoin and using the bitcoin mixing services available to block-off the flow of the funds from prying eyes looking at the transaction history (blockchain) would be an interesting...

Interesting technique, basically John Paulson created a bermudan reinsurer shell corp (PaCRe) which outsources actual reinsurance to a legit reinsurance company, used the shell to invest in the main fund, and then cashed out after a year by selling shares in the company, and thereby paying the...

That's for long-term capital gains, P.E guys/long-term hedge funds pay the 20% carried interest rate, which is now going to be 23.8% after obamacare. For short-term capital gains/trading, the carried interest is still going to be 39.6% for an individual+3.8%, making it 43.4% now. On the...

If it works for foreign investors, then why wouldn't it work for US investors? It's the same basic concept, and it's well-established that accountants do use these techniques for foreign investors, perhaps the incentive (35% upper rate vs 43.4% now) simply didn't exist to apply these techniques...

You haven't provided reasons for why this method wouldn't be possible, but otherwise the option would be #3 to renounce us citizenship and leave the country. Even 8.4% can add-up in the long-run.

Even at 39.6% you can make the argument that it is an incidental increase, but when it becomes 43.4%, the story changes. 43.4% is almost half your income, vs 35%, which is closer to 1/3rd. It should be possible to do it, why wouldn't it? If it isn't (for which no one has yet provided an...

If they aren't already doing it, then they need to realize that foreign investors get a better deal on us investments than they do. Foreign Investors using blocker corporations are capped at 35% tax liability. Even in Canada, the capital gains tax rate is 22%. Even in France, which has the...

International Investors in the U.S already have similar corporate shell arrangements to what I have described: http://en.wikipedia.org/wiki/Blocker_corporation Are you saying that the system should be set-up whereby foreign investors pay less in capital gains taxes on US investments than...

Do you realize that non-us citizens who use blocker corporations to make investments in the US pay the corporate rate of 35% capital gains tax on their earnings? Why should a US-based trader have to pay 4.6-8.4% more in income for no reason other than being 'blessed' to live in the US...

Your largest expenses, such as automobile (company car), housing expenses (home office), etc. will be through the corp, not personal expenses.

The top corporate tax rate was the same as the top income tax/short-term capital gains rate for the past decade, now income tax rates are higher, and the incoming obamacare tax is only going to increase the margin of difference.

Because the corporate tax rate is 35% while the new individual capital gains rate is at 39.6% + an additional 3.8% Obamacare tax. This would have the short term capital gains rate 43.4%, as occam has pointed out. So, you would have incentive to keep your assets in the corporation and save the...

It's outrageous when you think about it. The Canadian Capital Gains Tax Rate in comparison is 22% for both short-term and long-term capital gains. Meanwhile, with obamacare the us long-term capital gains rate for individuals will be higher than even the short-term canadian capital gains rate at...

Obamacare doesn't apply to businesses with less than 50 employees. http://obamacarefacts.com/obamacare-smallbusiness.php

Well, for 300k per annum, for example, it may not work, but for even another application such as carried interest with higher numbers, you can still pass it through to a personal shell corp and save the 4.6%.

But how often would you need to get it out when most of your net worth will be tied up in assets anyway?

Of course, but the point is that you won't generally need to pull the money out, as the bulk of your assets will be held and managed inside the corp, thus saving most of the 4.6%.

But you wouldn't necessarily need to take that much out in the first place.

That's why I said a certain portion would be allotted to personal expenses in the form of your individual income (which would be taxed again), like 20k or something like that, but the bulk of your assets could be in the corp. The corp would reinvest the profits for future trading without going...

So you can keep your major assets in the shell corp, while paying less in income tax (35% vs 39.6%) on those assets.