How Not to Hide Assets Offshore


If you ever thought that using an offshore corporation was a good way to hide assets offshore take a lesson from this IRS Chief Counsel Advice (CCA20114034).

The first test on disclosure of the ownership of a foreign corporation is the 50% test. This is not a test you want to fail. A U.S. taxpayer must report the ownership of a foreign corporation if the taxpayer owns more than 50% of the total value or total combined voting power of the corporation. This test is applied under the CCA to mean ownership in substance, not just form.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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