IRS Letter Ruling 9332006 shows how to legally avoid millions (even billions) of dollars in taxes.

Combine Letter Ruling 9332006 with Revenue Ruling 69-70 for the best U.S. taxpayer estate planning?

The investment banking firm of Warburg, Dillion Read (on Park Ave. N.Y.) have offices in 39 foreign countries - including the Bahamas, the tiny Cayman Islands, Hong Kong and the the Channel Islands. Makes you wonder why, doesn't it?

One good reason is.... foreign non-resident alien individuals, offshore companies, offshore trusts and offshore banks avoid all US capital gains taxes on their stock market trades because the U.S. has never taxed the capital gains of non-resident entities that do not have an office or are "doing business inside the United Stated". The other good reason is none of these tax haven countries tax the capital gains of companies and banks domiciled there.

But there are some still some great tax loopholes left for the American taxpayer venturing offshore. IRS letter ruling 9332006 and Revenue Ruling 69-70 are two important puzzle pieces to a smashing loophole for the American taxpayer. Check them out for yourself - below.

IRS -LTR 9332006 ™ Full Text

The use of an offshore testamentary trust to receive a U.S. persons assets only upon his death might afford some definite tax advantages, especially if the trusts assets are revocable by a nonresident alien individual or corporation. IRS LT. 9332006 confirms that upon his death, assets held in a foreign trust will no longer be subject to U.S. taxes, and not considered part of the U.S. person's U.S. estate, even if there are U.S. beneficiaries for the foreign trust.

LTR 9332006 -- ISSUE (4). UPON A SETTLOR'S DEATH, WILL THE PORTION OF THE TRUST TREATED AS OWNED BY THAT SETTLOR CEASE TO BE SO TREATED EVEN IF THEN TRUST BENEFICIARIES INCLUDE UNITED STATES PERSONS? Section 679(a)(2) (A) provides that the rules of section 679(a)(1) do not apply to "a transfer by reason of death of the transferor." While section 679(a)(2)(A) does not expressly address the tax consequences of the termination of foreign grantor trust status by reason of the grantor's death, the legislative history of the enactment of section 679 (H.R. Rep. No. 658, 94th Cong., 1st Sess. at 209 (1975); S. Rep. No. 938, 94th Cong., 2d Sess. at 218 (1976)) provides that "an inter vivos trust which is treated as owned by a U.S. person under [section 679] is not treated as owned by the estate of that person upon his death." Accordingly, any portion of the Trust that is treated as owned by a Settlor under the rules of section 679 shall cease to be so treated upon that Settlor's death.

In 1970, the IRS issued Revenue Ruling 69-70 (only part of the ruling is included here, but the IRS' entire Revenue Ruling 69-70 is in my book - Tax Havens of the World) to study... Revenue Ruling 69-70 has never been repealed!

Revenue Ruling 69-70 states: "An individual beneficiary who is resident of the United States is not taxable on a distribution from a foreign trust considered to be owned by a nonresident alien grantor under subpart E of subchapter J of the Code" - These are the exact words of the Internal Revenue Service tax writers - i.e., the tax lawyers working for the U.S. Treasury department writing your tax laws. They are people from Harvard, Stanford, and other big name institutions.


The author of Tax Havens of The World has formed over 950 of these foreign testamentary asset protection trusts for client already. But, if you don’t instruct someone (in your U.S. WILL) to transfer the U.S. assets offshore to the foreign trustee, you’ll be missing the boat to the tax heaven. You must include this information, and be very specific as to the amount you want transferred to the foreign trustee; and this information must be in your U.S. WILL (or domestic trust) – before you die!

Under current U.S. estate tax law. U.S. estates over $21,000,000 pay a flat 55% estate tax duty. What’s left over will be taxed every year, unless you implement a tax strategy before you die, and carry through on it. Smaller estates (under $21,000,000) can take advantage of this tax planning too.

In chapter 11 of my "Tax Havens of the World" you can review ALL of Rev.-Ruling 69-70. This IRS revenue ruling tell how U.S. beneficiaries can receive the income from the IRS's testamentary trust (above) TAX FREE. The Ruling was issued in 1970. Rev.-Ruling 69-70 has never been repealed by the IRS, and is still applicable today - in certain limited situations.

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ABOUT THE AUTHOR... My name is Tom Azzara.... It's a fact. Foreign, offshore companies and banks avoid all US capital gains taxes on their stock market trades. I live in the Bahamas. I know. I've incorporated over 990 International Business Companies here in Nassau. I work independent of/with a Bahamian bank owned by a $20 billion dollar parent bank from South Africa. Most of my companies end up with them. Contact me if you need something offshore.

I provide almost everything the client needs. Bank application forms from major Bahamian bank • VISA card from the top bank in Caribbean. • Debit card (ATM) issued within 24 hours • asset protection trusts with every company • offshore banking contacts in other major tax havens • low costs (see my web site below) • I work with several U.S. advisors for their clients • advice for U.S. taxpayers • offshore checking accounts Americans can use • Good brokers in the U.S. for opening up trading accounts.. ... Director and shareholder minutes for every company from Nassau in the Bahamas... much more..

DO YOU KNOW WHAT A REVENUE RULING IS?

A Revenue Ruling is not a law passed by Congress; it is a proclamation by the Internal Revenue Service explaining the facts as they relate to a particular set of laws. Revenue Rulings are the published conclusions of the IRS concerning the application of tax law to an entire set of facts.

Revenue procedures are official statements of procedures that either affect the rights or duties of taxpayers or other members of the public, or should be a matter of public knowledge. The purpose of these rulings is to promote a uniform application of the tax laws, and therefore IRS employees must follow the rulings. While taxpayers can rely on the rulings, they can also appeal adverse return examination decisions based on the rulings to the Tax court or other Federal courts.

The statement above was written by the IRS. It was taken (word for word) from one of their own publications.

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