International Financial Services
If you do not require a banking license, there are a number of less costly and
less regulated options available. Please note that these entities may not
provide the exception to the US Passive Foreign Investment Income regulations
available to licensed and operating international banks. In most cases, these
financial services companies are combined with a
Swiss Trust Company to move back office and
investment services to Switzerland.
Danish Bankers Trust Company
A Danish Bankers Trust Company is a financial services licensed entity in
Denmark. It may offer financial, investment, bank and trust services. With paid
in capital ranging from zero to US$90,000, depending on your structure, the cost
and compliance requirements are far less than an international banking license.
The Bankers Trust may offer financial services only to its own members or within
its own controlled group of companies. This means that the Trust may act as an
in-house bank. It may not offer or market any services to the general public.
New Zealand Offshore Finance Company
A New Zealand Offshore Finance Company (NZOFC) can offer banking services to
both private individuals and corporations worldwide, with no limitations on
number of customers, amounts on deposit or number of currencies.
The NCOFC can offer most services a licensed offshore bank can provide, but the
word "bank" cannot be included in the name. Activities of an NZOFC can include
but are not limited to deposit taking & lending, debit and credit card services,
issuing of financial guarantees and instruments, cash management services, current accounts,
checking accounts, savings accounts, term deposits, issuing of CDs, wire transfer services,
payment processing, fund management, and marketing of investments
The company is not subject to capital reserve
requirements and there are no regulations regarding nationality or residency of
directors and shareholders.
A NZOFC is not subject to Central Bank supervision and regulation, but its
activities are regulated by a number of acts and laws in New Zealand. It is
common to compare this entity to licensed banks in the Cook Islands (closely
tied to New Zealand) and Samoa.
Swedish Credit Union
A Swedish Credit Union is a registered Economic Association and can offer
financial services to up to 1,000 members and requires no paid in capital from
its founders. Services are generally restricted to accepting deposits and the
making of loans.
"Members" should be high net worth entrepreneurs and the Credit Union's business
plan should include common goals for its members. The entity may not use the
name bank, but "Credit Union," "Savings," or "Savings & Loan" are acceptable.
The Swedish Credit union is a very cost effective deposit taking entity. Most
bank licenses, especially those with low paid in capital, do not allow basic
deposit taking services. So, what's the catch? The Swedish tax rate is 30%. One
might reduce this by providing some services in a low tax jurisdiction, thereby
transferring a reasonable amount of profits out of Sweden based on the value
added in the low tax country. Also, each depositor is considered a shareholder
of the bank...because of this complex reporting issue, Chris Rusch
does not provide US tax compliance or consulting for
these entities.
Panama Financial Services Company
A Panama Financial Services Company may provide financial services such as:
payment processing, factoring, leasing, precious metals trading, bill collecting
and related services, foreign currency trading, debit & credit cards, and
trading in precious metals.
This entity is most commonly used for payment processing. As an active business,
with offices and people in Panama, it is an excellent vehicle to retain earnings
in a low tax jurisdiction.
The PFSC is commonly combined with a Swiss Trust and/or offshore bank. It is tax
exempt and best used to process payments on behalf of an offshore bank located
in another jurisdiction.
There are a number of options, entities and jurisdictions available to the
international entrepreneur. Please
contact me for a free
consultation.