Chapter 21: Foreign COPEs
Chapter 21: Foreign COPEs
Exotic Entities
Synopsis: Discusses the use of non-traditional entities as it relates to debtor-creditor planning.
Definition: Hybrid Entity -- An entity that does not have a classic form, such as a corporation or partnership, but instead exists as a combination of entities, such as a combination of trust and corporation. Even as late as the early 1990s the LLC was considered to be a hybrid of a corporation and a partnership, for example, but it has since become a classic form of business entity.
Offshore LLCs
Synopsis: Discusses the predominant offshore jurisdictions that have limited liability company statutes.
Definition: Offshore Limited Liability Company (OLLC) -- A limited liability company formed pursuant to the laws of a foreign debtor haven jurisdiction, such as the Nevis LLC.
Use of Offshore LLCs as Asset Protection Tools
Synopsis: Describes basic strategies for using OLLCs for asset protection planning.
Utilizing an Offshore LLC
Synopsis: Discusses probably hurdles that creditors would face in attacking OLLC structures, and the use of OLLCs in conjunction with foreign trusts and domestic ocmpanies.
Taxation of Offshore LLCs
Synopsis: Discusses the probable U.S. tax treatment of OLLCs.
The U.K. Limited Liability Partnership
Synopsis: Discusses the basics and operations of a United Kingdom Limited Liability Partnership, and its potential asset protection advantages from the U.S. viewpoint.
Definition: U.K. Limited Partnership (UKLP) -- A limited partnership formed under the United Kingdom's Partnership Act of 1907.
Definition: U.K. Limited Liability Partnership (UKLLP) -- A limited liability partnership formed under the United Kingdom's Limited Liability Partnership Act of 2000.
Exotic Entities
Synopsis: Discusses the use of non-traditional entities as it relates to debtor-creditor planning.
Definition: Hybrid Entity -- An entity that does not have a classic form, such as a corporation or partnership, but instead exists as a combination of entities, such as a combination of trust and corporation. Even as late as the early 1990s the LLC was considered to be a hybrid of a corporation and a partnership, for example, but it has since become a classic form of business entity.
Offshore LLCs
Synopsis: Discusses the predominant offshore jurisdictions that have limited liability company statutes.
Definition: Offshore Limited Liability Company (OLLC) -- A limited liability company formed pursuant to the laws of a foreign debtor haven jurisdiction, such as the Nevis LLC.
Use of Offshore LLCs as Asset Protection Tools
Synopsis: Describes basic strategies for using OLLCs for asset protection planning.
Utilizing an Offshore LLC
Synopsis: Discusses probably hurdles that creditors would face in attacking OLLC structures, and the use of OLLCs in conjunction with foreign trusts and domestic ocmpanies.
Taxation of Offshore LLCs
Synopsis: Discusses the probable U.S. tax treatment of OLLCs.
The U.K. Limited Liability Partnership
Synopsis: Discusses the basics and operations of a United Kingdom Limited Liability Partnership, and its potential asset protection advantages from the U.S. viewpoint.
Definition: U.K. Limited Partnership (UKLP) -- A limited partnership formed under the United Kingdom's Partnership Act of 1907.
Definition: U.K. Limited Liability Partnership (UKLLP) -- A limited liability partnership formed under the United Kingdom's Limited Liability Partnership Act of 2000.
Labels: asset protection, charging order, cope, hybrid company, offshore llc
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