The only way to play the offshore angle is tax planning, not tax evasion, it is playing by the rules, not playing against the rules, longterm if you evade taxes by planning you are off good, if you do it by playing against the IRS and their rules, you are mostly doomed. The reasons are manyfold, the best tools the IRS has are angry spouses, angry friends, jealous neighbors and time as well as simple good old fashioned stupidity. In the US the IRS pays you a certain percentage when you tell them about a tax cheater and they collect. Beside that they have a longtime to catch up with someone cheating. The plans here include the usual, the registratio of foreign accounts is an old hat. See the FBAR IRS guidance:

quote:
Report of Foreign Bank and Financial Accounts (FBAR)


Do You Have a Foreign Financial Account?

If you own or have authority over a foreign financial account, including a bank account, brokerage account, mutual fund, unit trust, or other types of financial accounts, then you may be required to report the account yearly to the Internal Revenue Service. Under the Bank Secrecy Act, each United States person must file a Report of Foreign Bank and Financial Accounts (FBAR), if

1.
The person has a financial interest in, or signature authority (or other authority that is comparable to signature authority) over one or more accounts in a foreign country, and
2.
The aggregate value of all foreign financial accounts exceeds $10,000 at any time during the calendar year.

A United States person is not prohibited from owning foreign accounts. The FBAR is required because foreign financial institutions may not be subject to the same reporting requirements as domestic financial institutions. The FBAR is a tool to help the United States government identify persons who may be using foreign financial accounts to circumvent United States law. Investigators use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.

Definition of Terms

A United States person includes a citizen or resident of the United States, or a person in and doing business in the United States. Whether a person is considered, for FBAR purposes, to be in, and doing business in the United States is determined based on an analysis of the facts and circumstances of each case. Generally, a person is not considered to be in, and doing business in the United States unless that person is conducting business within the United States on a regular and continuous basis. Persons who are merely visiting the United States or who sporadically conduct business in the United States, are not in, and doing business in, the United States for FBAR reporting purposes.

A foreign country includes all geographical areas outside the United States, the Commonwealth of Puerto Rico, the Commonwealth of the Northern Mariana Islands, and the territories and possessions of the United States (including Guam, American Samoa, and the United States Virgin Islands).

Reporting and Filing Information

A person who holds a foreign account may have a reporting obligation even though the account produces no taxable income. Checking the appropriate block on Form 1040 Schedule B, and filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, satisfies the account holders reporting obligation.

A foreign account holder must mail the Form TD F 90-22.1 on or before June 30 of the following year to:

U.S. Department of the Treasury
P.O. Box 32621
Detroit, MI 48232-0621.

The FBAR is not to be filed with the filers Federal income tax return.
The granting, by IRS, of an extension to file Federal income tax returns does not extend the due date for filing an FBAR. There is no extension available for filing the FBAR.

Account holders who do not comply with the FBAR reporting requirements may be subject to civil penalties, criminal penalties, or both.

Exceptions to the Reporting Requirement

There are exceptions to the reporting requirement. These exceptions include:

1.
Accounts in U.S. military banking facilities operated by a United States financial institution to serve U.S. Government installations abroad are not considered to be accounts in a foreign country for purposes of the reporting requirement.
2.
An officer or employee of a bank that is subject to the supervision of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Office of Thrift Supervision, or the Federal Deposit Insurance Corporation, is not required to report having signature or other authority over a foreign account if the officer or employee has no personal interest in the account.
3.
An officer or employee of a domestic corporation whose equity securities are listed on a national securities exchange or which has assets exceeding $10 million and 500 or more shareholders of record, is not required to report having signature or other authority over a foreign account if the person has no personal financial interest in the account, and the officer or employee has been advised in writing by the chief financial officer of the corporation that the corporation has filed a current report that includes the foreign account.

FBAR Assistance

Help in completing Form TD F 90-22.1 (PDF) is available at (800) 800-2877, option 2. The form is available online at IRS.gov and MSB or by telephone at (800) 829-3676. Questions regarding the FBAR can be sent to FBARquestions@irs.gov.

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Deductions are normal and mostly regulated in Double Taxation Agreements and the trust issue, I have to laugh, I hope they get them all, whoever is so stupid not to consider this when setting up is just asking for it.

Offshore structures will not go away, the real players know what they are doing, they have lawyers and accountants and specialists reading all the regulations all over the world, I have them and I have been one of them, its a chess game and only viable at a very high level with responsible players, consider it: when ever you spent any money you have to reflect how it is booked, how it is registered, what paperwork is there, what is the tax impact.... that needs a specific personality or someone who does it for you. Offshore is not a game for the beginner, everybody should avoid the shelf companies and readymade accounts etc, they are a waste of time and a call to the IRS criminal division in the longterm.

In addition there is one thing to say, US rules apply within US territory, the UBS sample shows how the US strongarms foreign players who have an attack point in the US, best to aoid doing business in the US if you cheat on taxes. Last not least, remember there are some very nice tools to avoid taxation in the US, you do not need offshore to minimize your taxes, play by the rules and you will be fine.

In my opinion the current rules are enough and all the postering now is just showing off to the electorate that they care for the things they said during election, I doubt any job which went offshore will come back just for tax reasons.