June 12, 2017 at 02:16 #4610
I am considering being the investment advisor for an IBC that’s managing investments for a foundation.
The IBC will need a bank account and a brokerage account. As the IBC’s investment advisor, I would open the accounts and state the IBC as the owner, but with myself listed as the business contact. In my interpretation of CRS guidance, this would not make me the account holder since I’m performing services to the benefit of the IBC, and ultimately the Foundation and it’s UBO (a charitable cause).
Who will the bank consider as the account holder according to CRS, and thus potentially trigger AEOI? The IBC director? The foundation and/or it’s councillors? Me as the investment advisor and account signatory? All of the above?
Do you have experiences with specific banks how they perform this assessment that you can share? Leupay, OCBC, Scotiabank etc
If I provide correct information in the CRS self-certification form, is that what will be used for the CRS/AEOI assessment? Or will the bank independently assess the situation and potentially report me as the account holder as well? I would obviously not want to end up being taxed for income that is not mine.June 13, 2017 at 08:29 #4619
First, note that reporting does not equal tax obligation. Whether accounts are reported as associated with you or not has nothing to do with whether you’ve got a tax liability and vice versa.
Second, depending on the institution they might in order to be safe report any number of persons.
This all being said depending on how you set up the account you could be a user without being the account holder it will all depend on the specifics of the situation especially where trusts and foundations are concerned as banks tend not to understand them.June 30, 2017 at 08:08 #4649
Thanks for the reply Michael! Do you have any example of such a setup you mention in your last paragraph? e.g. the bank reporting the company and it’s registered representative(s) as account holder(s), but still allowing a consultant/investment manager to be an unreported account manager.June 30, 2017 at 20:33 #4650
I applied for an account for my Seychelles IBC in Armenia. That their compliance policy is a lot looser than my local banks (Some of them even rejects companies wholly owned by a resident living nearby a branch of the bank).
It reminds me of the bank from Djibouti mentioned on Streber’s article. (If I remember it right.) However, they are asking questions to identify how I conduct my business. (How I market, types of service… etc)
The initial corporate document review takes 2 weeks, since I forgot to submit some of the documents that were required, it would take another while till my account is open.
The bank’s representative spoke English quite well but I don’t think she is fluent.
One of the form that bank provided me asks if the UBO exist or not.
When I had asked the bank to clarify this, they had given me a reply saying that I need to give them the correct answer which left me with a question mark.
For your information, their fee for brokerage account is just as much as the most of stock brokers in Hong Kong. Is this the type of bank you’re interested in?July 4, 2017 at 00:51 #4653
Cameroon, which bank in Armenia is opening account for your Seychelles IBC? Remotely?July 4, 2017 at 00:56 #4654
@Cameroon Yes, this is the type of bank I would be interested in. To be honest, I haven’t really looked at Armenia as a jurisdiction for banking so need to do a bit of homework 🙂 Would love to hear how your experience has been so far.
- This reply was modified 9 months, 3 weeks ago by Midas Gordiusson.
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