Presumably, you have an interest in offshore financial matters or you
would not be a member of this Yahoo Group. And you have most likely
seen a lot of answers to questions about foreign corporations. But no
one has asked me WHY? Why would a U.S. citizen or corporation want to
own a corporation in another country? So here is a boiled down "Top
Five Reasons to Own a Foreign Corporation"

Reason # 1. A foreign corporation that is legally structured so that
it does not meet the definition of a controlled foreign corporation
does not subject the U.S. owners to U.S. taxes on the current income
of the foreign corporation – unless the foreign corporation is a
passive investment holding company.

Reason # 2. If you are interested in a foreign asset protection
trust, the trust will most likely need to use a foreign corporation
(or IBC) to own the assets in order to protect those assets from
foreign estate taxes.

Reason # 3. If you want to operate a business in a low tax
jurisdiction, a foreign limited liability company can provide asset
protection and can also provide tax deferral on profits from operating
a trade or business offshore -- because it will be taxed as a foreign
corporation unless the owners make an election to be taxed as a
partnership or as a disregarded entity (one owner).

Reason # 4. Many foreign banks won't open an investment or checking
account for a U.S. person, but they will open an account for a foreign
corporation even if it is owned by a U.S. person. To avoid U.S. tax
problems, owners of certain kinds of foreign corporations can elect to
be taxed as a foreign partnership or disregarded entity.

Reason # 5. A lot of U.S. companies are looking to expand with
operations in foreign countries. To minimize liability risks, they
usually form a foreign LLC or foreign corporation to own the foreign
based operation. Depending on a variety of factors, the U.S. company
may be better off with a disregarded entity election or as a taxable
corporation – which is the default treatment.

If you have any serious interest in venturing offshore, you need to
know about the advantages and the disadvantages of a foreign
corporation owned by U.S. persons and you need to have that
information before you sign any papers of any kind. The rules are
complex and often ambiguous but on December 7th, three top experts on
the tax rules for controlled foreign corporations will help me to
explain the rules in plain English. Our seminar is less than most
technical seminars and we are offering a 20% discount for the next 12
pre-paid registrations. But we aren't cutting corners on the venue
because the program is being held at the world renowned Caesars Palace
in Las Vegas.

For registration information see
http://www.offshorepress.com/cfcworkshop.htm

Looking forward to meeting you in Vegas on December 7th.

Vern