Quote from performancetrad:
The first person on this tread who accused me of not know what I was talking about quickly changed his tone.
1. You need to learn the difference between "tax planning" and "tax avoidance" the latter is illegal.
2. Why do you think corporate structures exist? accounting 101.
3. PFICs? PFICS refer primarily to investment companies and mutual funds. I own a proprietary trading francise that dose not manage third part assets. No clients. Call any one you like to check out the legitimacy of my company... you think that any authorities would care about a an american owning a franchise in another country? Are you felling alright today, are you running a high grade fever?
4. The HEART ACT??? the one refering to penion benefits? how is that relevant? Is ther another Heart act that I am unaware of that pertains to the conversation?
Patronize is right. with your tone..I will gladly keep it up. I am simply explaining how to use a corporation legally if you live overseas.
With combative blowhards like yourself on the site..I think I will go ahead and ignore these chat boards. I thought that maybe they consisted mostly of adult members. Apparently I was incorrect.
look, if you're an american, and you're setting corps up to run your prop firm as an american and you're not claiming that income, the irs will own you. might not happen today, or tomorrow, but when it bites you, you'll lose everything. only reason i'm even taking the time to respond, is because i dislike the irs more than i dislike your fantastic display of arrogance and ignorance. if you're not an american, then you don't have any business giving advice on this stuff.
again, to reiterate, you really really don't know what you're talking about. you truly do not. whoever your legal counsel is should be fired. if you're doing it yourself, you should hire someone who understands american taxation of foreign corporations because you just don't.
1) 2) irrelevant
3) you don't need to manage money to fall under pfic rules, you just need to have income from investments as a corporation (ie trading... last time i checked that's what prop firms do). however, this assumes you figured away around cfc rules, which you haven't with your american controlled prop, so you don't even get to pass go.... and no, i don't think, i KNOW the irs WILL care... you haven't been watching the news much lately have you?
4) yep, heart act, that's the one. why don't you actually read it and figure out for yourself how it's relevant... because congressional bills are only about one thing right?
the only thing you're explaining simply, is that you know very little about something you're about to venture into, and it's really not something you want to know very little about.
a combative blowhard is someone who doesn't know what they're talking about, but assumes they do. so go ahead and ignore me and these boards, but how much are you willing to risk, that that's not you?