#21 Treasure Finance #21

  Form 8621 Compliance Tips for Passive Foreign Investment Companies (PFICs) Investing in international funds or foreign corporations? You might be holding a PFIC—and if so, the IRS expects you to report it using Form 8621. Failure to comply can result in steep taxes, interest charges, and audit risk. But with the right knowledge and filing strategy, you can stay compliant and minimize unnecessary tax burdens. 📌 Table of Contents What Is a PFIC? Why Form 8621 Matters QEF vs. MTM: Choosing a Filing Method Key Tips for Filing Form 8621 Correctly How to Avoid PFIC Status Altogether What Is a PFIC? A Passive Foreign Investment Company (PFIC) is a foreign corporation that meets one of the following tests: ✔️ 75% or more of its income is passive (e.g., interest, dividends) ✔️ 50% or more of its assets produce or are held to produce passive income This includes many foreign mutual funds, ETFs, or private offshore investment vehicles. Why Form 8621 I...

  Family Office Tax Structures for Cross-Border Investors Managing wealth across multiple countries presents complex challenges — from avoiding double taxation to complying with ever-changing regulations. For affluent families and entrepreneurs with global ties, a well-designed family office tax structure can streamline reporting, reduce exposure, and unlock multi-jurisdictional planning advantages. In this guide, we’ll explore how cross-border family offices are structured, the tools used to minimize global taxes, and how to align investments across tax treaties, jurisdictions, and currencies. 📌 Table of Contents Why Cross-Border Investors Need Structured Family Offices Core Legal and Tax Structures Used Globally Leveraging Bilateral Tax Treaties Trusts, Foundations, and Hybrid Tools Compliance and Reporting Risks to Avoid Further Resources 🌐 Why Cross-Border Investors Need Structured Family Offices As families accumulate wealth across bor...

  Private Placement Life Insurance (PPLI) in Offshore Trusts 📌 Table of Contents What Is Private Placement Life Insurance (PPLI)? How Offshore Trusts Enhance PPLI Key Benefits of PPLI in Offshore Structures U.S. Tax Compliance and Reporting Who Should Consider This Strategy? Conclusion What Is Private Placement Life Insurance (PPLI)? PPLI is a life insurance policy tailored for high-net-worth individuals that combines tax-efficient investing with estate planning benefits. Unlike retail insurance products, PPLI policies are customized and can hold hedge funds, private equity, real estate, and other alternative assets inside a tax-deferred wrapper. Policyholders can grow wealth without immediate tax consequences—as long as IRS rules are followed. How Offshore Trusts Enhance PPLI Pairing PPLI with an offshore irrevocable trust (like in Bermuda, Cayman Islands, or Jersey) adds another layer of asset protection and estate planning. The trust owns ...

  An Introduction to SPAC Warrants for Retail Investors SPACs (Special Purpose Acquisition Companies) surged in popularity over the past few years, offering a non-traditional route to IPOs. But while most people focus on the SPAC shares, savvy retail investors have also turned their attention to a powerful instrument: SPAC warrants. This post will walk you through what SPAC warrants are, how they function, and why they might be an attractive tool for retail investors seeking leveraged exposure to merger outcomes. Table of Contents What Are SPAC Warrants? How Do SPAC Warrants Work? Risks and Considerations How Retail Investors Can Use Them Conclusion What Are SPAC Warrants? A SPAC warrant is a financial derivative that gives the holder the right to buy a SPAC’s stock at a specific price (usually $11.50) after the SPAC completes its merger. Warrants are typically issued to incentivize early investment in SPACs and are often bundled with shares at IPO. They ca...

  The Rise of Interval Funds and How Retail Investors Can Participate In recent years, interval funds have surged in popularity, becoming an increasingly important part of the alternative investment landscape. These funds offer retail investors access to asset classes previously reserved for institutions—such as private credit, real estate, and infrastructure—while providing periodic liquidity and regulatory oversight. If you’re a retail investor seeking diversification beyond traditional stocks and bonds, understanding interval funds can open the door to new opportunities. In this post, we’ll cover what interval funds are, how they work, their benefits and risks, and how you can get started as an investor. Table of Contents What Are Interval Funds? How Interval Funds Work Benefits of Interval Funds Risks and Considerations How to Invest in Interval Funds What Are Interval Funds? Interval funds are closed-end funds that offer to buy back a portion of the...