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Transborder Solutions

Apeiron Academy's expert team helps provide the following solutions for our clients.

一、涉及海外资产规划常见问题

 

1. 加拿大一代移民回流,如何为移民后代规划海外资产?

 

王先生2005年移民加拿大,移民期间大约带了1000万加币进入加拿大作为生活费、安家以及投资的启动资金,另有其他部分资产留在海外账户和国内。在加拿大期间妻子孕育了一儿一女均为加拿大护照。近5年,由于中国经济的高速发展,王先生整合了许多国内资源在国内开展了许多投资生意,生活也慢慢地留在国内,未来王先生希望在国内养老。但孩子们非常适应加拿大的生活,并不希望回到中国发展,对其具体的投资生意也没有兴趣接手。一直到现在,王先生仍在向加拿大报税,对于加拿大高额的税率,王先生希望找到一个解决方案,并能够把这部分资产安全地传承给加拿大的孩子们,最好能够同时兼顾税务优化。

  • 方案规划思路:王先生申请非税务居民,加拿大资产中岸化,设计传承机制,实现海外资产安全免税增长,免税分配,隔离保护,安全传承。

 

2. 全家美国移民,资产由他人代持,如何为移民后代规划海外资产?

 

2003年全家移民美国,进入美国申报资产时只带了满足生活费的资产进入,其他资产都放在父母名下和其他代持人名下。近期年迈的母亲由于身体原因入住医院,这也提醒了王先生夫妇开始考虑其他资产安排,主要涉及到的是海外账户的现金及投资部分。美国是一个全球征税的国家,王先生夫妇既希望资产能够为自己和后代所应用,也希望能有合理的税务规划,不完全暴露在美国税收体系之下。

  • 方案规划思路:由父母设立美国税务居民为受益人的外国委托人信托,资产留在美国境外继续投资。通过信托的合理设计实现家人受益、税务优惠、资产隔离保护传承等功能。

 

3. 移民加拿大,如何合理规划身份及带入加拿大境内资产和海外其他资产?

 

2010年前后申请了加拿大枫叶卡想要办理加拿大移民,但是2015年之后,王先生一家由于生意原因就常在国内居住。但是一直到现在两人都在正常报税,王先生的枫叶卡在两年前已过期。两人在加拿大期间购买了两套房产,并带入了约1000万加币左右的现金投资资产。现在女儿在加拿大读研并持有枫叶卡,未来女儿希望留在加拿大获取身份并长期发展。两人现在也有心想要在10年之后回到加拿大养老并获取身份。但是对于加拿大的税务体系两人听闻很多,感觉是需要做些什么规划的,具体要如何操作也不确定,也不知道找谁咨询。现在的状态是否能够继续移民加拿大,该做哪些规划能够实现合理的税务规划?

  • 方案规划思路:综合解决方案(移民政策+身份规划+税务筹划)

 

4. 准备移民美国,如何合理规划带入美国境内资产和海外其他资产?

  • 方案规划思路:

1)不是人到哪里钱到哪里;

2)遵循持有在离岸、开户在中岸、发展在在案的原则;

3)合理规划美国境内资产持有,及境外资产持有。

 

5. 不涉及移民的海外资产如何规划?

 

CRS信息交换已经开始,而且有些被税局约谈的消息,夫妇二人在想如何解决海外这部分资产的规划和申报问题?

  • 方案规划思路:离岸信托小红帽,安全申报无烦恼。

 

6. 涉及多婚姻、复杂家庭情况的海外资产传承规划?

王先生夫妇是重组家庭,两方各有自己的孩子,现在二人婚姻重组之后过的还是比较幸福和顺利。二人经营着一家海外贸易公司,多年的积累也有了过亿美金的海外资产。如今孩子们已逐渐长大并面临成家,但是对于两方孩子之后的资产传承安排是一个敏感的话题。王太太希望能够妥善安排好几位孩子的资产传承,不至于因此产生更多的家庭矛盾。

  • 方案规划思路:

1)明确传承规划,到人,到钱,到权力,到金额;

2)做好家族内部沟通安排。

 

7. 希望寻找海外安全稳健投资方案?

王先生夫妇一家家庭幸福,之前准备办理投资移民的时候也在海外留存着过千万美金的投资资产。现在两人移民没有办理成功,对这部分资产希望有个妥善的安排。能够实现安全、稳健即可。因为之前投资海外房产遇到了开发商跑路,所以二人现在对海外房产投资非常抵触。另外对于其他的项目投资水太深,二人还是非常谨慎。对于这部分资产,什么样的投资方案比较合适?

  • 方案规划思路:低息时代,保费融资,放大投资收益;获得安全、稳健、简单、放心的投资收益。

 

8. 涉及多婚姻、复杂家庭情况的海外资产传承规划?

王先生夫妇是重组家庭,两方各有自己的孩子,现在二人婚姻重组之后过的还是比较幸福和顺利。二人经营着一家海外贸易公司,多年的积累也有了过亿美金的海外资产。如今孩子们已逐渐长大并面临成家,但是对于两方孩子之后的资产传承安排是一个敏感的话题。王太太希望能够妥善安排好几位孩子的资产传承,不至于因此产生更多的家庭矛盾。

  • 方案规划思路:

1)明确传承规划,到人,到钱,到权力,到金额;

2)做好家族内部沟通安排。

 

9. 早年间在美国、加拿大投资了各项地产和项目,如今该如何规划?

王先生夫妇一家并未移民,但是由于王先生是投资出身,早年间在北美有很多投资资源,所以二人在美、加购置了很多房产和股权项目投资。听说北美的遗产税很高,另外有两笔投资马上到期,二人想对这部分资产做个统一规划,部分该退出的退出,到期后的资金重新安排。由于家人都在中国发展,对于这部分资金,希望能够妥善地安排和部署。

  • 方案规划思路:

1)让遗产“不是遗产”,规避高额遗产税;

2)选择安全稳健的投资方案,并做好隔离保护、税务和传承安排。

2. Frequently Asked Questions Involving Asset Planning in China

 

1. The Canadian immigrant generation returns, how to plan domestic assets for immigrant descendants?

 

Mr. Wang immigrated to Canada in 2008. Mr. Wang travels between Canada and China as a "trapeze" to take care of domestic business. In the end, Mrs. Wang and her two children successfully obtained Canadian passports and lived in Canada for a long time. Mr. Wang did not immigrate and still has Chinese passports. The child has been living in Canada and does not want to return to the country to take over the family business. The company is now very large, Mr. Wang does not want to sell it, it has not reached the listing level, and no one has taken over the inheritance. How to deal with the equity of domestic enterprises and take care of the lives of overseas Canadian descendants is a headache for Mr. Wang now.

  • Scheme planning ideas: domestic enterprise equity domestic trust settlement, enterprise design professional manager incentive plan, Canadian beneficiaries enjoy dividends as trust beneficiaries. It not only ensures that the company has a sustainable development plan, but also ensures that the Canadian family benefits. In addition, it develops overseas business, builds a cross-border equity structure, and realizes dividends going abroad through equity paths, so that overseas families can enjoy dividends.

 

2. American immigrant, domestic asset holding agent, how to make inheritance planning for the next generation?

 

Mr. Wang started in the catering industry. In 2010, he studied for his children. Mrs. Wang immigrated to the United States with two children. Mr. Wang very much hopes that the eldest son can take over the domestic business and arrange for him to return to China after completing his studies to help him in the company, while the younger son will work smoothly in the United States. Both children and Mrs. Wang have American passports. Mr. Wang is worried about how to plan the equity of domestic companies. The eldest son gradually took over part of the work, but the identity of the United States did not want to give up. All of them were transferred to the son's name and faced double taxation. If they did not transfer, how should they be passed on? Although the youngest son does not participate in the operation and management of the enterprise, Mr. Wang also wants to leave enough funds for his future development and life.

  • Scheme planning ideas: domestic enterprise equity is settled by domestic trust, the eldest son takes over the management of the enterprise as the manager, and the dividends and benefits can be arranged through the trust contract to arrange the interests of the whole family.

 

3. Chinese entrepreneurs, the whole family has not immigrated, and hope to make plans for the inheritance and dividend tax of domestic unlisted companies.

 

Mr. Wang and his wife started their own business from scratch. One of them is responsible for sales and the other is responsible for the management of the family business, but they have not done much research on financial planning and arrangements. There is an account in the family business. Before, the use of invoice offsets and other operations was used to avoid corporate income tax. However, as the domestic corporate tax system becomes more and more perfect, the two also realize that they need to sort out the corporate finances. However, how to do a good job in corporate tax planning under a reasonable premise and distribute dividends to individuals is an urgently needed solution for the two of them.

  • Scheme planning ideas: The domestic trust scheme solves the three major problems of family investment and financing, reasonable tax planning and equity inheritance.

 

4. Chinese entrepreneurs, the whole family has not immigrated, domestic companies are listed in China (or invest in domestic listed companies), and they hope to reduce their holdings, optimize tax, and do a good job in family wealth planning.

Shareholders A, B, and C started a business together and led a group of business pioneers to finally successfully list in China. The entire listing process consumed almost all of the cash flow of several entrepreneurs. The reduction of shareholders’ holdings after listing is not a business operation problem, but a family need. However, in addition to paying 20% income tax after each share reduction announcement, it will also affect the stock price. All three hope to find a suitable solution, which can not only enjoy the benefits of listing, but also have tax benefits without affecting the stock price.

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  • Scheme planning ideas: domestic trust scheme solution.

1) There is no need to announce the reduction of holdings;

2) The reduction of holdings is not subject to quota restrictions;

3) The value-added tax during the reduction of holdings is greatly reduced;

4) Assets in family trusts can isolate creditors;

5) The family trust can replace the will and avoid the trouble of notarization of the inheritance rights in the future, and realize the inheritance desire of the rich.

 

5. Chinese real estate entrepreneurs, whose assets involve the inheritance of real estate and properties.

 

Mr. and Mrs. Wang started as a typical real estate speculator. The two invested in more than 20 properties in first-tier cities in China. Recently, there have been constant voices about the introduction of the domestic property tax, and the next step of the inheritance tax has made the two of them think about how to deal with the arrangement of this part of the property. It can not only have tax benefits, but also allow future generations to enjoy the return on investment. It's not a good thing to leave more than 20 houses for future generations.

  • Scheme planning ideas: solve the problem through the rules of domestic family trusts and senior creditors.

 

6. High-net-worth family in China, the whole family has not immigrated, and hope to take 10 million yuan to the next generation to pass on.

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Mr. Wang and his wife's family are both in China, and through their years of hard work, they also have a family background of over 50 million. Now the business is not doing well, the two attach great importance to the safety of wealth and the income of wealth investment. They hope to divide a portion of the money out as a safe fund for the family that can be passed on to future generations.

  • Scheme planning ideas: domestic trusts and life insurance can achieve both steady growth and safe inheritance.

 

7. Middle-class family in China, the whole family has not immigrated, 400,000 RMB, hope to make inheritance planning for the next generation.

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Mr. Wang and his wife have a happy family. When they were preparing to apply for investment immigration, they also kept overseas investment assets of more than ten million US dollars. Now the immigration of the two people has not been successful, and they hope to have a proper arrangement for this part of the assets. Able to achieve safety and stability. Because the developer has run away when investing in overseas real estate before, the two are now very conflicted about overseas real estate investment. In addition, the investment in other projects is too deep, and the two are still very cautious. For this part of the asset, what kind of investment plan is more suitable?

  • Scheme planning ideas: Domestic small trusts and life insurance can achieve both steady growth and safe inheritance.

 

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