MEMORANDUM To: Barry Hart and Peter Hiebert From: William L. Blum and Robert Ladislaw cc: Jeffrey Epstein, Erika Kellerhals, Robert Solomon Date: September 29, 2016 Subject Structure for Avoidance of Repatriat

THE TAX FREE ENTITY UNDER THE U.S. FLAG: A UNITED STATES VIRGIN ISLANDS EXEMPT COMPANY By William L. Blum, Esq. It will come as a surprise to many practitioners that the Internal Revenue Code provides an international tax planning tool with one very unu