1. law, govt and politics
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Prospectus
How to legally address the current Inter Governmental
Tax Treaties with compliance to those treaties via
Foreign Account Transaction Compliance Act
A discussion of the legal aspects related to the development
of proper account relationships for American Nationals
and the Foreign Financial Institutions without violation
of existing FATCA rules
www.grandcaystrategies.com
Understanding the Limited Scope of the
Foreign Account Transaction Compliance Act [FATCA]
How important is FATCA?
FATCA impacts the financial lives of every American in the 50 states of the Union [the
Constitutional Republic] who desire to bank internationally, for any number of reasons
including those Americans who have chosen to live in a foreign country. Living and
working internationally creates immediate needs for banking services in order to conduct
normal financial activities in their foreign domicile.
Over the last decade, the U.S. Government has created the impression in the international
community of nations that Americans with foreign bank accounts are all tax cheats or
tax evaders. Foreign Financial Institutions [FFI] such as International Banks have been
coerced with extra territorial legislation created by the US Congress to compel such
FFIs to comply with their wishes if those FFIs intend to remain a viable enterprise in
international commerce.
We will show that there is an intentional mislabeling of Americans, and their targeted
private banking activities, has now come to the forefront creating a need for clear
understanding of how to address this matter properly using federal tax laws that have
been obfuscated until now. Americans living internationally will be forced to deal with
this issue that has the potential if not dealt with properly to have a large negative impact
on their banking needs.
Why was FATCA created?
The answer goes back to the early 1970s when then POTUS Richard M. Nixon removed
the Gold Standard. Prior to the removal of the Gold Standard, the US Dollar was backed
fully in gold at the exchange rate of $35 US Dollars to equal one ounce of gold. This
served as a ‘regulation device’ against the US Government’s ability to print its paper
money in excess of the agreed exchange of $35 USD per ounce of gold. In effect, the
US Government’s ability to print more paper money was based on an increase in gold
reserves to back up the new issuance of paper money it desired to print and circulate.
Inflation was basically non-existent with the gold standard and prices were very stable
year to year.
Since that decision by Richard Nixon, the U.S. Government has printed paper currency,
not paper money as the paper is no longer backed by gold, and has with the "QE 1, QE 2"
exercise by the Federal Reserve created Trillions of dollars in debt. The US Government
today is in serious trouble and is going broke, if it is not there already. The politicians,
who have allowed this financial problem to exacerbate to the level that is faced today,
have created a method in the FATCA laws to round up as much of its currency [Federal
Reserve Notes] from the American People as possible. The U.S. Government shows no
interest in “living within its means” so it continues to seek new sources of revenue in order
to continue its socialistic lifestyle.
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What is FATCA’s purpose?
By living internationally, Americans are choosing to find an alternative to their personal
pursuit of happiness. Obviously, they take their capital with them in order to protect it
from the surging tide of continual devaluation of the dollar that was once backed by gold.
The real concern for the U.S. Government has been the fact that Americans have for
decades chosen to leave the geographical shores of the Constitutional Republic in
ever-increasing numbers. In 2013, the estimate of annual departures was stated to be
approaching 400,000 Americans. Due to the large number of Americans leaving annually
and no longer close enough to impose the increased domestic taxation, the National
Government has moved to address the international American audience.
It is all about the currency it needs, pure and simple. The issues become personal for
Americans when they realize that it is their assets that the U.S. Government is now coming
after and making claims that those who operate internationally are tax cheats and tax
evaders. The methodology used by the U.S Government is based on statutory tax laws it
created and now seeks via FATCA to locate all statutory “U.S. Persons” who have assets
of a level that is attractive to the U.S. Government to tax.
Who are those targeted for application of FATCA legislation?
Senator Carl Levin (D—Michigan) has stated publicly: “Any U.S. person who has an
offshore bank account is ipso facto engaged in tax evasion.” His statement is based on
the needed government propaganda to maintain the perception that such Americans are
tax cheats.
Some technical terms are required to be addressed at this point. It is an imperative
necessity for the reader to pay attention to these specific terms if you are to understand
‘exactly who is being targeted’.
Politicians use words that have special meanings and if you do not realize what their
terms mean then you are lost from the start of the process called FATCA. Americans
would do well not to use their personal ‘interpretations’ of what they ‘think’ the politicians
are referring to. The words the politicians use are statutory in nature and have very
unique definitions, as you will learn.
By learning the definitions of the terms politicians like Senator Carl Levin has used, you
might start to ask, “What is the definition of the statutory term ‘U.S Person’?”
The definition section of the Internal Revenue Code [Title 26] is section 7701. The
definition of the statutory word “U.S. Person” is found at 26 USC Section 7701 (a)(30).
“The term United States person means -- (A) a citizen or resident of the United States, (B)
a domestic partnership, (C) a domestic corporation, (D) any estate..., (E) any trust...”
At first glance, it might appear that the reference to “a citizen or resident of the United
States” is referencing Americans from within the Constitutional Republic.
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After all, there is the reference to “a citizen or resident of the United States”. You must
remember that you should not use your own definitions when hearing words that are
statutory in nature because politicians are skilled at semantics and obfuscation of the
facts. So the next question to ask is: “What is the statutory meaning of the term ‘citizen
of the United States’ or ‘U.S. citizen’?”
What you will find is that the statutory term “U.S. citizen” and the statutory meaning of
the term “U.S. Person” used by Senator Carl Levin, are not the same terms as expressed in
the Constitution.
Beginning the search for the statutory definition of the term “U.S. citizen” you will find this
term defined in Title 8 of the United States Code [8 USC] at section 1401(a). It is stated
to mean “A person born in the United States and subject to the exclusive jurisdiction
thereof.”
If you are really sharp, you probably noticed two new terms that need defining as well
which are ‘person’ and ‘United States’. We will get those in a moment. In the legal
encyclopedia, the American Jurisprudence 2d, you will find the best definition for the
statutory term “U.S. citizen”. Found in Section 2689, Who is born in the United States and
subject to the United States jurisdiction, is the following:
“A person is born subject to the jurisdiction of the United States, for purposes
of acquiring citizenship at birth, if his or her birth occurs in territory over
which the United States is sovereign, even though another country provides
all governmental services within the territory, and the territory is subsequently
ceded to the other country.”
Admittedly, this gets deep very quickly for the novice reader of legalese. Being
persistent, you see that a statutory U.S. citizen is: (1) one who is subject to the jurisdiction
of the United States. The American People are still determined to be sovereign via the
Constitution and by numerous Supreme Court determinations. The National Government
is a creation of those sovereigns. Thus, a statutory U.S. citizen is not the same as what is
expressed in the Constitution.
Secondly, you see in the American Jurisprudence expression referenced above that
a statutory U.S. citizen is: (2) one “born in territory over which the United States is
sovereign.” As stated above, the National Government is sovereign within its jurisdiction
but that jurisdiction does not include the 50 states of the Union [the Constitutional
Republic]. The National Government has a limited jurisdiction to the 10-mile square
known as the District of Columbia. This also includes the territories that it acquired and
controls following the Treaty of Peace, signed in Paris, with the King of Spain in 1898
formerly ending the Spanish-American War. Those US Territories are most commonly
known as the US Virgin Islands, Guam, Wake, American Samoa, Puerto Rico, et al.
Clearly, the term U.S. citizen when considered in light of the definitions published show
that there is no direct reference to Americans born in the 50 states which are also referred
to in common expression as U.S. citizens. To differentiate and eliminate the confusion,
the non-statutory term American National is a far better way to state those born in the 50
states who enjoy the Constitutional citizenship vis-a-vis the statutory meaning of a U.S.
citizen.
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Before we end this section, we need to consider the definitions of ‘person’ and ‘United
States’ as used in context to the FATCA and the multitudes of articles in the press on
referencing these terms without showing any definitions.
The statutory term ‘person’ is defined at 26 USC section 7701 (a)(1) to mean — “… an
individual, a trust, estate, partnership, association, company or corporation.” These
expressions allude to only legal fictions. Yet there is the curious word ‘individual’ and yet
again we need to look up this statutory word.
Upon doing so, you find at 5 USC section 552a(a)(2) that “the term individual means
a citizen of the United States or alien lawfully admitted for permanent residence.”
Reflecting back on the statutory definition for the statutory term U.S. citizen, you can see
that the term individual does not mean nor does it include any reference to an American
born in the Constitutional Republic. This term only addresses those born within the
territory which is under the dominion and control of the National Government arising from
its sovereignty over such territory.
As to the statutory term “United States”, this is perhaps most clearly defined at 26 USC
section 7408(d). This subsection addresses citizens and residents outside the United
States. “If any citizen or resident of the United States does not reside in, and does not
have his principal place of business in, any United States judicial district, such citizen
or resident shall be treated for purposes of this section as residing in the District of
Columbia.”
The exclusive or sovereign jurisdiction of the National Government is the District of
Columbia. In Congressional legislation, the District of Columbia is well known as the
“United States”. Semantically, this has led to confusion for most Americans as they never
thought to determine what was being said by politicians like Senator Carl Levin when
using the statutory words for the expression “United States”. Thus, the above definition
at 7408(d) shows that those who are the property of the National Government [also
referred to as the United States] meaning statutory US citizens and resident aliens are
viewed and taxed as domiciliaries of the District of Columbia [the United States] by
statute law even when they have no physical presence in the District of Columbia.
As such, the statutory term “United States” does not mean the Constitutional Republic.
The establishment of National Government authority to tax “U.S. Persons” worldwide
Former POTUS William H. Taft was a lifetime proponent of generating ideas to provide
the National Government with the power and authority to tax its property, statutory “U.S.
persons”, worldwide. After leaving the White House, he became a US Supreme Court
Justice and quickly rose to Chief Justice. The landmark court case on providing the
National Government what it wanted — the ability to gain taxation claims on a subset of
“U.S. Persons”, those known as statutory “U.S. citizens” — was achieved via Cook v. Tait,
265 U.S. 47 (1924).
There still remains discussions among Constitutional scholars today about the origination
of this case. There are those who purport that this case was created by the government
as a fabricated stratagem to bring about the desired outcome. Others simply state
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that Mr. Cook was not cognizant of the subtleties of legal definitions and the statutory
laws created by the National Government for statutory terms like “U.S. citizen”. Either
way, the taxation zeitgeist of those in government service was greatly enhanced by the
decision of the US Supreme Court in Cook v. Tait.
Mr. Cook was an American who lived in Mexico and built yachts in there. Mr. Tait was
a government official with the title of Collector of Internal Revenue. Mr. Cook declared
himself to the Court to be a ‘citizen of the United States’. Basically, Mr. Cook argued that
the National Government did not have the constitutional right to levy income taxes on
U.S. citizens living outside the United States and on income earned outside the United
States. With that admission statement, the National Government viewed him as their
property.
The flaws that Mr. Cook created for himself, or those created by his defense in this case
before the Supreme Court, are numerous from that last sentence. The Legislative Intent
of the 16th Amendment levied the federal income tax only upon the National Government.
POTUS Taft in his June 16, 1909 letter to the US Congress stated:
1) “… in the case of Pollock v. Farmers’ Loan and Trust Company, 157 U.S. 429
(1895) was held by the Supreme Court to be a direct tax and therefore not
within the power of the Federal Government to impose unless apportioned
among the several States according to population.”
2) “The decision of the Supreme Court in the income tax cases deprived the
National Government of a power...it was generally supposed that Government
had. It is undoubtedly a power the National Government ought to have.”
3) “I therefore recommend to the Congress that both Houses, by a two-thirds
vote, shall propose an amendment to the Constitution conferring the power
to levy an income tax upon the National Government without apportionment
among the States in proportion to population.”
In the first statement above, POTUS Taft showed that the National Government could not
bring about such a direct tax upon the American People without the use of the Rule of
Apportionment — based on the Census — as required of the National Government via the
Constitution. This is a very important distinction as you begin to understand the Cook v.
Tait case.
The second statement illustrated, shows that the National Government never had the
power to levy a direct tax (without the consideration of the first statement listed). POTUS
Taft went so far as to state that the National Government was deprived of this kind of
power if it did not use the Rule of Apportionment. He showed his displeasure with the
Supreme Court decision by his reference to “it is undoubtedly a power the National
Government ought to have.”
Responding to his agenda to create the federal income tax, one reads in the third
statement by POTUS Taft that he instructed the US Congress to do exactly what the US
Supreme Court had told the National Government it could not do, or so it appears! Many
readers miss the directive in his Legislative Intent for the 16th Amendment insofar as the
income tax was ONLY levied upon the National Government and not upon those in the
Constitutional Republic.
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This was a skillful use of legal semantics on the part of POTUS Taft. He stated openly that
the tax was levied upon the National Government and by that admission the income tax
became a municipal tax upon the District of Columbia — Washington, DC — and was never
directed to the Constitutional Republic. He furthermore stated that the US Congress
should create the 16th Amendment to the Constitution “without apportionment among the
States in proportion to population”.
What most American Nationals have overlooked here is the second reference to the
federal income tax only being levied upon the National Government’s exclusive sovereign
jurisdiction which is the District of Columbia. Washington, DC is believed by many to be
the “Nation’s Capital” but in reality it is a foreign jurisdiction to that of the states of the
Union. In this limited jurisdiction of the National Government, the Constitution is null and
void! The 16th Amendment illustrates this fact clearly.
The facts stand for themselves. The National Government was denied and deprived of
any power or authority to levy the Federal Income Tax directly upon American Nationals
without the use of the Rule of Apportionment, which is a Constitutional requirement
imposed upon the National Government to adhere to. Yet today, we know the 16th
Amendment is “on the books” as it were.
Politicians knew very well what POTUS Taft was doing and saying. Sadly, American
Nationals did not.
Returning to Cook v. Tait, the National Government argued that it did have the
constitutional right to levy income taxes on its citizens living outside the [statutory]
“United States” and that it could levy those taxes on the [statutory] “U.S. citizens”
worldwide income.
Justice McKenna wrote the decision for the Supreme Court and stated the following:
“The contention was rejected that a citizen’s property without the limits of the
United States derives no benefit from the United States. The contention, it was
said, came from the confusion of thought in ‘mistaking the scope and extent
of the sovereign power of the United States as a nation and its relations to its
citizens and their relations to it.’
And that power in its scope and extent, it was decided, is based on the
presumption that government by its very nature benefits the citizen and his
property wherever found, and that opposition to it holds on to citizenship
while it ‘belittles and destroys its advantages and blessings by denying the
possession by government of an essential power required to make citizenship completely beneficial.’
In other words, the principle was declared that the government, by its very
nature, benefits the citizen and his property wherever found and, therefore,
has the power to make the benefit complete.
Or to express it another way, the basis of the power to tax was not and cannot
be made dependent upon the situs of the property in all cases, it being in or
out of the United States, and was not and cannot be made dependent upon
the domicile of the citizen, that being in or out of the United States, but upon
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his relation as citizen to the United States and the relation of the latter to him
as citizen.
The consequence of the relations is that the native citizen who is taxed may
have domicile, and the property from which his income is derived may have
situs, in a foreign country and the tax be legal — the government having
power to impose the tax.
What you have just read can be simplified by understanding the definition of the statutory
terms and the Legislative Intent of the 16th Amendment. The National Government’s
position was only concerned about the relation of the National Government to its
statutory “U.S. citizens”. As the US Congress created the legal definition it also identifies
statutory “U.S. citizens” as its property.
This is similar to someone owning two homes in different countries. While the
homeowner cannot be at both homes simultaneously, he still remains the owner of his
property wherever that property is located even if he is not physically present. It is after
all, his property.
This is the foundation for the premise that FATCA is valid worldwide and can be enforced
worldwide even extra jurisdictionally for those who are its property. If one claims, as did
Mr. Cook, to be a statutory “U.S. citizen” then you must realize that you have a Tax Home
in the District of Columbia per 26 USC §911 (d)(3) and by doing so you are proclaiming to
be a statutory “U.S. Person” which is a type of U.S. Taxpayer. Under that structure, the
FATCA rules do apply toward you and the FFIs must utilize the tax treaty established with
the FFI home country to be compliant or disallow you as an account holder.
As a result of the Cook v. Tait decision, the National Government can tax its statutory
“U.S. citizens” wherever that statutory citizen might live based upon the presumption
that the National Government benefits the statutory “U.S. citizen” wherever the statutory
citizen lives.
When one does not distinguish the difference between those terms that are statutory
in nature vis-a-vis those terms that are non-statutory, it is easy to see how the National
Government comes out on top and becomes the sovereign who has dominion and control
over its property, those who are identified as statutory U.S. citizens.
American Nationals were never imposed with the Federal Income Tax according to
POTUS Taft and he stated so in the Legislative Intent of the 16th Amendment.
Cook v. Tait decision confirmed this but in a more sub-silentio manner and has
successfully obfuscated the distinctions of the National Government’s statutory terms
for Americans to muddle around trying to understand exactly what happened. Mr. Cook
made a gross error by not asking the Supreme Court to require the National Government
to define what it meant by the term “U.S. citizen”.
Hosea 4:6 states God’s warning most clearly. “My people are destroyed for a lack of
knowledge.”
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What are the key elements of the FATCA agreement for FFI compliance?
Deloitte has created a very detailed explanation of the concepts that FFIs are to adhere to
in order to be in compliance with FATCA rules arising from treaties between the various
international governments and the US Government.
The goal of FATCA is to secure the Identification, Withholding, and Reporting of any
account held by any statutory “U.S. person”.
Deloitte states the following key facts contained in the FATCA rules:
1) Whether you are impacted by the FATCA rules is not driven by whether
you have a business in the United States. It is solely determined by whether
you receive any “withholdable payments”.
2) Only gross proceeds from the sale or disposal of U.S. property of a type
that can produce interest and dividends are subject to withholding under
FATCA rules. The requirement is that FFIs are required to report worldwide
income and proceeds received by “Specified U.S. persons”.
3) FATCA withholding only applies to withholdable payments and proceeds
or “income from sources within the United States.”
Income from sources within the United States are listed at 26 USC section 861 there are
nine key descriptions of the varieties of income from within the United States that FATCA
only addresses. There are several key sections here that clearly show that Americans
who do not work for the National Government [meaning those who derive income that
is effectively connected with the conduct of the performance of the functions of a Public
Office] are not impacted by the FATCA rules thus the FFIs are obligated to comply with
for personal FFI accounts.
FATCA Reporting Requirements by Specified Individuals
‘Specified Individuals’ are statutory in nature as they are creations of the US Congress and
as such are defined in the Instructions for Form 8938 to be the following:
1) A U. S. citizen
2) A resident alien of the United States
3) A nonresident alien who makes an election to be treated [meaning taxed]
as a resident alien for purposes of filling a joint [or singular] income tax
return.
4) A nonresident alien who is a bona fide resident of American Samoa or
Puerto Rico.
Worthy of note in this discussion is the statutory term ‘Nonresident alien’. This statutory
term is defined at 26 USC section 7701 (b)(1)(B) to mean: “A nonresident alien is an
individual who is neither a U.S. citizen nor a resident of the United States”. Having already
learned the definitions of ‘individual’, ‘U.S. citizen’ and ‘United States’ make this expression
much clearer in spite of the fact that this subsection is not really a definition as it only
states what a nonresident alien is not rather than what it really is.
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There is really only one group that this initially obtuse term illustrates and that group
includes those who are American Nationals. The fact that the National Government can
only levy its tax upon those who work for it or those who derive “income from sources
from within the United States” should be very clear at this point.
This is validated even further by the Legislative Intent of the 16th Amendment. This
foundational document published in the Congressional Record of the United States
Senate on June 16, 1909, proves beyond doubt that the federal income tax was only levied
upon the National Government by the direct statement of then POTUS William H. Taft.
It is further established by the omission of the constitutional requirement for the
National Government to adhere to the Rule of Apportionment which it is clearly shown
to have ignored. This is only possible for laws that are applicable only within the District
of Columbia where the Constitution has no force and effect of law in that federal
municipality.
Therefore, all FFIs are only required to identify, withhold, and to report on those who are
statutory U.S. persons (statutory legal fictions and those born in territory belonging to the
National Government sovereign) of that limited jurisdiction. Those who are referred to
as Specified Individuals, meaning statutory U.S. persons are the proper parties for FATCA
rules and their income is determined to be withholdable due to it being derived from
sources within the United States (the District of Columbia).
American Nationals are those expressly stated as ‘Nonresident aliens’. American Nationals
are not statutory US persons.
There are no FATCA rules requiring any FFI to report on non-US person accounts.
There is further no income tax return requirement for any American National unless they
have made an ‘election’ in the past to allow the National Government to tax them as if
they were Resident Aliens. Then and only then can the income of such American Nationals
be considered as taxable and thus fall under the FATCA compliance rules of identification,
withholding, and reporting of assets in any FFI.
FATCA rules do not apply to non-US persons and FFIs are free to establish accounts
Grand Cay Strategies has created the proper legal documents for select American
Nationals to provide to any FFI in order to address the full spectrum of legal issues central
to permitting any FFI to establish a banking relationship with such American Nationals.
It is up to the individual American National to provide such proof or evidence as to their
correct non-US person status in order to legally bypass the presumptions created by
the press and the less informed that all Americans are statutory US persons. Grand Cay
Strategies has this documentation.
In the event that any American National has in the past made an ‘election’, even without
realizing such, Grand Cay Strategies can provide a legal way, as provided by the US
Congress, for that election to be terminated for all time. Then under that new status, even
those American Nationals can be free to establish an account with any FFI that operates
under the FATCA rules.
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With the Affidavits and other legal documentation provided to select American National
clients, the FFI can afford to welcome such select Americans as clients and provide their
customary wealth management services without concern for the current tax treaties of
their home government previously established with the US Government.
Every aspect of the efforts provided by Grand Cay Strategies are founded on federal tax
laws [statutes and regulations] so that there is never any violation of those treaties in
place or the tax laws of the United States Government.
The FATCA rules do not apply to non-US persons as well as those who qualify for the
‘Exception’ as stated in the Form 8938 Instructions. The home country of the FFI is not
in conflict by any actions on the part of the FFI as they remain in full compliance to the
FATCA rules and international treaties on taxation with the US Government.
The laws of the US Government are being adhered to at all times, as they should be, and
all parties related to FFI accounts under these structures are without issue on the matter
of tax evasion or non compliance concerns.
Who we are
Grand Cay Strategies began as a service to help American Nationals clarify their true
status as it relates to the Federal Income Tax. We have assisted around 1,000 clients by
providing solutions regarding the Revocation of Election, as well as defeating IRS actions
such as a Notice of Deficiency, Notice of Federal Tax Lien and Notice of Intent to Levy.
Our solutions-oriented approach has netted a tremendous success rate in these areas.
That success is not based on legal opinion or argument, but on enacted federal laws.
In short, we have raised awareness about the government’s duplicity in its attempt at
undermining the personal sovereignty expressed in the Constitution and further validated
by US Supreme Court decisions.
We are not anti-government but rather pro-individual self determination and strong
advocates of personal privacy. We recognize that the Federal Income Tax is not
unconstitutional as it is written but is limited to its narrow jurisdiction to which it applies.
The choice of the National Government to tax its own property and those who derive
income that is effectively connected with the performance of the functions of a Public
Office is lawful within Washington DC. We do not interfere with those who, either by
birth in any federal territory or by choice, are lawful US Taxpayers to which the FATCA
legislation apply.
Our principal, Adele Weiss, has compiled over 20 years of research into this specialized
field. As he benefitted from his predecessors, we now stand on his shoulders to help see
the light of truth in the protection of our God-given status of sovereignty.
The Revocation of Election and FATCA Affidavits, based on enacted federal tax laws,
have proven to be a powerful combination to help select American Nationals correct their
misunderstanding and the government’s misapplication of their true status.
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A meeting with Grand Cay Strategies
For purposes of further clarification, we recommend a face-to-face meeting between
principals of the banking institution and Grand Cay Strategies, where further
documentation can be provided, and any questions can be answered in a private setting.
As we are based in continental Europe, we currently hold our meetings in Frankfurt,
Germany. With as little as a week’s notice, Grand Cay Strategies could arrange a
conference room and take care of other logistics per the bank’s request.
The fee for the meeting is all the banks will be obligated to pay. Once an agreement
is made, the prospective American National client will pay for his/her documentation
to present to the bank as a third-party Affidavit. This clears the non-US bank of any
responsibility to vet the client, and the bank can seek other American National clients
without the worry of employing extra staff to attend to Form 8938 and other tax
documents. This could save the bank millions of dollars over time in staff and legal costs.
The advantage for the American National is clear, and substantial. The cost for the
entire package brings with it a lifetime of benefits. The Payback Period for such an
investment is very reasonable, based on a modest $5 million USD balance. Remember,
the US Government will want to confiscate 30% of any income derived from investments
worldwide, so it is important to clarify one’s true status as quickly as possible.
Please send us an email at [email protected] if you wish to discuss the possibilities of
keeping your American clientele and attracting new capital from affluent American
Nationals.
More information can be found at www.grandcaystrategies.com.
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