Comments by "Jeremy Barlow" (@jeremybarlow2291) on "Puerto Rico vs. Offshore Tax Havens" video.

  1. The fact that the ACT 20 company MUST provide services for EXPORT should not be lost in the HYPE. This is especially true in light of new Treasury Regulations which are beginning to source the income of digital sales at the point of consumption. AT LEAST for downloadable digital content, ie non-SaaS software and/or eBooks, or downloadable videos. This could dramatically hamper the potential tax benefits of the ACT 20 NOW ACT 60 loophole. Let's be honest it is a loophole and Congress is very good at plugging loopholes. What about this plug for the hole, they grant Puerto Rico statehood and it loses its tax advantaged status. Don't get me wrong, Puerto Rico looks good, in fact, today, with the rise of CRS and FATCA, the EU blacklist and the OECD forcing its economic substance requirements on the tax favorable jurisdictions of the past, there is a lot to be said for ACT 20 and ACT 22, now ACT 60 as I understand it, but it is likely to be a short term solution. In fact, by law, IT MUST BE A SHORT TERM SOLUTION, 30 years maximum if the 10 year renewal is granted at the 20 year mark. What good does ACT 20 do for the business person who wants to sell real physical products to actual human beings? Yes, you can convert a portion of the profits from such an enterprise to service based income by providing marketing services to your physical products company, but wouldn't you rather pay the 9% corporate tax rate on the profit from selling those goods in Montenegro and not have to worry about how the income is categorized by the IRS in a dispute, and maybe pay Zero Percent on the dividends you receive for those distributions as a citizen and tax resident of St. Kitts & Nevis, or a tax resident of Panama or Malaysia receiving those dividends at your home in one of those countries where you have the option of pulling up stakes and changing your tax residency if needed to minimize your taxes, or where you have the option to move the company from Montenegro for a better deal if you find one. I mean the piece of paper creating a corporation can sit in any drawer in any country. As long as that country gives you access to banks that let you move your money and use it freely, it doesn't matter what country the corporate articles are sitting in at the end of the day.
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  2.  @coocoocachooglin  I have got to be honest, in reviewing the new "economic substance requirements" the OECD has placed on entities based in most of the no tax jurisdictions, and the numerous other onerous requirements that are being imposed thanks to the FATCA and CRS threats to banking in those jurisdictions, a lot of business ideas in the digital space that would greatly benefit from being based in a low or no tax jurisdiction are getting tougher to do tax free. Not impossible, but you need staff on the ground in some very tiny countries with inadequate work forces for the kind of work that needs to be done. The nations where that wouldn't be the case like Vanuatu are on the EU blacklist for the most part and will be tough to get bank accounts to run your business through.
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