Law Offices - Kenneth D. Sisco, Attorney - Personal Information

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Action Asset Protection Services

Kenneth D. Sisco, Attorney at Law

11421 Orange Park Boulevard

Orange, California 92869

714 538-6800

4555 East Sahara Avenue, Ste. 179

Las Vegas, Nevada 89104

702 430-7728

 

ALL FOREIGN TRUSTS ARE NOT CREATED EQUAL

Effective January 1, 1997, the "Small Business Job Protection Act of 1996", attempts to discourage the use of foreign trusts, especially those grantor trusts, referred to as "Asset Protection Trusts". Generally speaking, the Act has little effect on the strategy described in my article, "The Ultimate Estate Planning Tool."

I am writing a new article dealing with the Act in depth, but for the time being it seems prudent to try and clear up some of the confusion. To do that I will share with you, my reply to a particularly astute reader that sent me the following E-Mail.

Question: Are you aware that in a 1996 Cook Islands court decision opened the books of trust companies there to publish details of how some wealthy California investors sought to protect their assets? Also the Cayman Court of Appeals held that the Cayman bank secrecy statute could be lifted if virtually any criminal conduct was alleged, either in the Caymans or in the USA, with which the Caymans had signed a Mutual Legal Assistance Treaty. I am assuming that as long as a country such as Belize does not sign such a treaty, that this country is maintaining its sovereignty by not signing such a treaty. Is this assumption correct?

Reply: I believe your assumption is correct, although a jurisdiction can always change its policy in the future. That is why it is so important to select a jurisdiction with a long history of independence and respect for privacy. Liechtenstein is such a jurisdiction. Not only has Liechtenstein repeatedly refused to enter into such a treaty, but under its law there is a six month prison term for any bank or other employee that discloses client information.

Question: I also have a report that changes enacted in the Small Business Protection Act of 1996 enhance the ability of the IRS to tax the income of foreign trusts and increase disclosure requirements for such instruments.

Reply: Foreign trusts, even under the new law are not taxed per se. The trusts that the new law is primarily aimed at are the Grantor Asset Protection Trusts. A grantor trust is one over which the grantor or creator, retains significant control over the trust. If it is a grantor asset protection trust, then the grantor is taxed on the income of the trust as though it were his own. Moreover, the new law sets forth very stringent reporting requirements for grantor trusts.

The strategy I describe does not utilize a grantor trust, and therefore not only is the income of the trust not taxed to either the creator of the trust or the trust itself, but the reporting requirements do not apply.

Queston: Effective Jan. 1, 1997, to qualify as a domestic trust, a court within the USA must be able to exercise primary supervision over the administration of the trust and one or more U.S. fiduciaries must have authority to control all substantial decisions of the trust. This places authority over the trust squarely within the U.S. jurisdiciton, making the trust much less attractive for asset protection. Assets in trusts that fail to meet this definition are subject to a 35 percent excise tax on "unrealized appreciation." What is the implecations of this matter?

Reply: Again, a "domestic" trust is one that is domiciled within the United States; that is not an issue in the strategies I describe. The 35% excise tax comes into play when a domestic trust that holds appreciated assets, converts to a foreign trust.

The new law is very complex and gives new meaning to the word pollution. I am sure that the reply above raises as many questions as it answers, so if you have further questions, please let me know.

Copyright ©1997

 

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·         Foreign Asset Protection and Estate Planning

·         Personal Information on Ken Sisco

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