Offshore Business Planning

US company ABC is manufacturing in China and distributing and selling in various other countries, including the US. ABC would like to deferrer US taxes on foreign earned income, to permit reinvestment overseas, both in inventory and for operating expenses. ABC company conferred with Mr. Malley, who was able to advised them on creating a structure for its overseas activities which allowed ABC to take advantage of complex US tax rules to defer US tax on foreign-earned income.

Foreign National Estate and Business Tax Planning

A foreign individual, Mr. X from a wealthy family, intends to become a US resident and, ultimately, a US citizen. Mr. X’s immediate family members also intend to become US residents and, ultimately, US citizens. Mr. Malley was able to suggest and implement an offshore structure which would facilitate future distributions of principal and income which, although reportable to the IRS in the US, are not taxable under current US law.

Offshore Insurance Structure

US company XYZ has a workers’ compensation annual premium in excess of $1 million. XYZ would like to reduce its workers’ compensation premium and still remain in compliance with California State law. Mr. Malley was able to structure an offshore captive insurance arrangement which, given a typical annual loss history, reduced the annual premium to approximately $350,000.

US company, with its several subsidiaries, desires to reduce its liability insurance premium and to increase its liability insurance coverage. Mr. Malley was able to advise on a captive insurance structure which reduced the company’s current liability insurance premium by over 50%, and which provided greater coverage through the international insurance markets.

Private Placement Life Insurance:

U.S. client is married to a non-Citizen spouse, who is not entitled to the unlimited spousal martial exemption or to the current estate tax exemption. By sending funds overseas to a U.S. qualified "private placement" life insurance policy, (no commissions) owned by the clients life insurance Trust, the tax free insurance proceeds, cash value and earnings, were delivered to the non-Citizen surviving spouse free of both estate tax and the burdensome Qualified Domestic Trust.