Why USD keeps going stronger over SGD?

aster1

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No, the approach you've described as you've described it won't work. It's probably possible to thread that needle, but it's more difficult and more expensive than you currently imagine.

Where is the problem if a Singaporean limited company is the shareholder and not an individual? I do get that this is the US we're talking about so all logic goes out the window and there is probably lots of small-print that deals with this scenario as you say...

But I did read on a Canadian legal/financial advice site that trusts of all sorts can be tricky, but that a Canadian corporation is the safest way to safeguard against estate tax as it is a legal entity... and legal entities don't die.
 

peipei1

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USD/SGD dropped from 1.38 to 1.368 within days because of US-China re negotiations? What gifs? :s13:
 

henrylbh

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Just curious but would it be a viable option to set up a limited company (wholly-owned by oneself) and then invest that way? I take it corporate tax on any profits would then be the only worry, but at least no estate tax issues?

2. Own shares of a legitimate foreign (non-U.S.) corporation engaged in real business activities that invests in U.S. stocks, with all the complexity and reporting requirements that a legitimate corporate structure entails. This is quite difficult and expensive to pull off.

Does it mean the non-US corporation must be in real business that invests in US stocks and must comply with GAAP to get past estate tax on US stocks? Can't it be just some investments besides its other core business?
 

BBCWatcher

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Does it mean the non-US corporation must be in real business that invests in US stocks and must comply with GAAP to get past estate tax on US stocks? [....]

Where is the problem if a Singaporean limited company is the shareholder and not an individual? [....]
If either/both of you are seriously interested in what is rather exotic estate planning, then you'll have to consult a qualified professional who specializes in this area of the tax code. Fundamentally you're asking whether you can go into direct battle and defeat, or at least blunt, U.S. estate tax provisions that have evolved and been refined over a century -- and how to do it. Maybe you can, but it's not easy, certainly won't be cheap, may not be rock solid, and usually won't be durable.

Just as an interesting aside, an estate tax case triggered the U.S. Supreme Court's landmark 2013 ruling in United States v. Windsor that required the U.S. federal government to recognize same sex marriages. Thea Spyer and Edith Windsor married in Toronto in 2007. Spyer died in 2009 and left her entire (and quite large) estate to her wife. There's an unlimited marital exemption between U.S. citizen spouses in the U.S. estate tax code, but the IRS cited Section 3 of the Defense of Marriage Act (DOMA) and refused to recognize their marriage. Since Spyer's estate was valued above the US$3.5 million exemption her estate was allowed in 2009, the IRS assessed estate tax at $363,053. (Looking at the tax rate tables for 2009 it appears to me that Spyer's estate was around US$4.6 million in 2009 dollars. The court records would probably give the exact amount.) Windsor took the case all the way to the Supreme Court and won, and thus she changed history profoundly, forever. So indeed, sometimes estate tax (and broader) victories are possible, even big victories, but not often.

Windsor -- or, more precisely, Spyer's estate, with Windsor as beneficiary -- received a full refund from the IRS. Windsor died in 2017, when the U.S. estate tax exemption was US$5.49 million (since she was a U.S. person). I'm not aware of any information on the tax her estate paid, if any, but my recollection is that Windsor was extremely charitable and donated a lot of money to civil rights causes during her lifetime. My best guess is that her estate fell below the exemption.
 
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henrylbh

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If either/both of you are seriously interested in what is rather exotic estate planning, then you'll have to consult a qualified professional who specializes in this area of the tax code. Fundamentally you're asking whether you can go into direct battle and defeat, or at least blunt, U.S. estate tax provisions that have evolved and been refined over a century -- and how to do it. Maybe you can, but it's not easy, certainly won't be cheap, may not be rock solid, and usually won't be durable.

Just as an interesting aside, an estate tax case triggered the U.S. Supreme Court's landmark 2013 ruling in United States v. Windsor that required the U.S. federal government to recognize same sex marriages. Thea Spyer and Edith Windsor married in Toronto in 2007. Spyer died in 2009 and left her entire (and quite large) estate to her wife. There's an unlimited marital exemption between U.S. citizen spouses in the U.S. estate tax code, but the IRS cited Section 3 of the Defense of Marriage Act (DOMA) and refused to recognize their marriage. Since Spyer's estate was valued above the US$3.5 million exemption her estate was allowed in 2009, the IRS assessed estate tax at $363,053. (Looking at the tax rate tables for 2009 it appears to me that Spyer's estate was around US$4.6 million in 2009 dollars. The court records would probably give the exact amount.) Windsor took the case all the way to the Supreme Court and won, and thus she changed history profoundly, forever. So indeed, sometimes estate tax (and broader) victories are possible, even big victories, but not often.

Windsor -- or, more precisely, Spyer's estate, with Windsor as beneficiary -- received a full refund from the IRS. Windsor died in 2017, when the U.S. estate tax exemption was US$5.49 million (since she was a U.S. person). I'm not aware of any information on the tax her estate paid, if any, but my recollection is that Windsor was extremely charitable and donated a lot of money to civil rights causes during her lifetime. My best guess is that her estate fell below the exemption.

What a strange distraction ..... Own shares of a legitimate foreign (non-U.S.) corporation engaged in real business activities that invests in U.S. stocks, with all the complexity and reporting requirements that a legitimate corporate structure entails. This is quite difficult and expensive to pull off ..... now need to consult lawyer to get pass estate tax?
 

BBCWatcher

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..... now need to consult lawyer to get pass estate tax?
Yes! And not just any lawyer. Assuming you're not satisfied with the approaches outlined upthread, e.g. the popular Irish domiciled funds.
 
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