Tag Archive for offshore reporting

Licensing Companies And Intangibles

A Licensing Company is a type of offshore company that involves intangible property and the licensing of its use. It involves a variety of issues relating to country disparity. This use of the offshore situs usually is a result of a particular foreign situs imposing withholding tax upon royalty income and is not treaty accommodating. Also, one may find peculiar foreign situs rules that effect the disposition of industrial property rights.

Licensing Companies seek International Financial Centers that provide more reliable substantive judicial systems to protect intangible and substantive rights, as compared to a country situs of licensing use. Licensing Companies also provide flexibility. The flexibility lies in the contracting for rights to use in different foreign locations. The issues of Subpart F Income, source of income concepts, and arm’s length pricing of related parties are the focus of structural planning. Read More

Written by | Posted in Corporate • International

Whistle Blower Leaks Offshore Financial Records of 550 Canadians!

whistle blowAs we posted on May 6, 2013 Whistle blower Exposes Massive Offshore Corruption! discussing the release this of an investigation by the International Consortium of Investigative Journalists into off-shore holdings of people and companies in more than 170 countries and territories hiding trillions of dollars in income and assets.

Now we come to discover that the names of 550 Canadians have been found in these 2.5 million recently leaked records from offshore financial centers. The files include personal and financial details relating to those linked to companies and trusts in the South Pacific and Caribbean.

One of the most infamous names is Toronto-based Peter Sabourin, whose name appeared 1,449 times in the files. Found liable for fraud at several Ontario Superior Court trials in 2007, Sabourin now owes more than CAD32 million to his investment victims and is still being investigated by Ontario Provincial Police.

There is going to be some civil and criminal exposure for some of those Canadians named in this list “EY.”

In accordance with Circular 230 Disclosure

Written by | Posted in International