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e exempt company provisions, their technical application and requirements, and their practical application as a tax planning mechanism for selected non-United States owners. I. Historical, Policy and Legislative Background Formulation of Territorial Policy and Territorial Tax Policy The United States has sovere
Guam, American Samoa and the Northern Marianas as foreign corporations, while individual U.S. citizens resident in those jurisdictions are taxed by the United States on their worldwide income except that income from territorial sources is exempt While not directly eliminating the mirror systems in these territori
hicle for establishing a foreign (non-U.S.) owned exempt Insurance Company in the U.S. Virgin Islands, an exempt insurer may also be established by a United States person using a standard U.S. Virgin Islands corporation. However, it should be noted that changes in federal tax law in the 1980's, and the impositi
rer. An exempt company which so qualifies may conduct business in the Virgin Islands if it obtains the appropriate license from the Commissioner of Banking and Insurance. The Exempt Company Law also prohibits Virgin Islands persons from both owning and controlling 10% or more of the stock of an exempt company; howeve
nald, Director, in pursuance of the authority vested in me, do hereby authorize the above-named entity to transact business in the Virgin Islands of the United States. This C'ettlficytte ofitoensure is valid from January 1,2015 to beeestilier 31, 2015. Renewal of this Certificate olLicensure trsequired annually u
authorizes the creation of these entities. Pursuant to Title 9, Chapter 25, Section 721,a copy of which is attached to this letter, the Director of Banking and Insurance is responsible for issuing the license to FSG to commence operations. FSG is not required to obtain a business license from the Department of Licens
tion of the majority of the ruling body is controlled by another person. (bb) "The United States" means the United States of America, any state of the United States, the District of Columbia, and every possession, territory, political subdivision, and agency thereof, excluding the Virgin Islands. (cc) "Trust"
tive conduct of the business for which this certificate was granted within five (5) years of the date this certificate is signed by the Director of Banking and Insurance of the Office of the Lieutenant Governor." SUBSECTION 748-1. TRANSFER OF BENEFITS (a) This subchapter shall not be applicable in cases where any
Entities connected to both United States and Banking and Insurance

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Michael Cohen
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Richard Kahn
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U.S. Virgin Islands
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