Dick Adams wrote:
- quote -

But the folks are real nice.

--
Frederick E. Jorden http://Tax-Accounting-Payroll.com
7825 Midlothian Tpk - 207 Richmond, VA 23235-5247
EMAIL knowtax[at]bigfoot.com
(804) 320-6210 FAX (804) 320-6211

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C. Nelson wrote:

- quote -

It should be noted that land is a scarce resource in
Bermuda and the cost of living is outrageous.

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C. Nelson wrote:

- quote -

Not much unless you have real international business
operations. UPS is headquarters in Bermuda but has real
worldwide operations. If you are in this category you should
seek advice in face to face meetings with tax and legal
experts.

--
Frederick E. Jorden http://Tax-Accounting-Payroll.com
7825 Midlothian Tpk - 207 Richmond, VA 23235-5247
EMAIL knowtax[at]bigfoot.com
(804) 320-6210 FAX (804) 320-6211

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->

- quote -

Are you an individual, a partnership, or a corporation?
Assuming that you are a corporation, are you just moving the
headquarters or are you reincorporating there? Is the stock
publicly traded? What is the form of the reincorporation?
(merger, 351, etc.). Are more than 50% of the shareholders
from outside the U.S.? Are you a greater than 5%
shareholder? . . .

The potential costs of "reincorporating" a U.S. corporation
to Bermuda include: shareholder level tax, corporate level
tax, and public shame (and the concern that Congress may
soon add more costs and/or eliminate some of the perceived
benefits). The benefits might include: creating more
deductible interest expense in the U.S., reducing the cost
of moving cash between related non-U.S. entities, and
potentially shifting profits outside the U.S. via transfer
pricing. There may be others too, but these were off the
top of my head.

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What are the tax implications of moving headquarters to the
Bermudas?

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