Creators and Custodians of Intergenerational wealth readily acknowledge that new statutes and regulations targeting their wealth ensures that Privacy and Compliance are top of mind. There are four states of Privacy including:
- Solitude ~ Establishing physical separation from other individuals;
- Intimacy ~ Inviting select individuals into trusted relationships;
- Anonymity ~ A desire to restrict information available in the public domain;
- Reserve ~ Protecting and Controlling access to your data and assets.
In 2010, as part of FATCA, US Congress enacted new disclosure requirements for specified foreign financial assets (“SFFAs”). The types of reportable assets include: direct holdings of stock in foreign entities, interests in foreign funds, depository accounts, custodial accounts, or interests in financial institutions.
In 2018, the CRS was adopted across the G20 requiring the name and identifying number of the reporting foreign financial institution (FFI) as well as the name and the account number, year end balance, address, tax identification number, date and place of birth of each reportable person.
Interestingly, Gold held in a custodial account maintained by an FFI (bank) would be considered reportable, however, Gold held in an independent vault or safety deposit box is exempt from declaration provided (i) the vault is not in an FFI (bank) or (ii) the storage arrangement is not a financial account.
ICON CAPITAL RESERVE SA is not an FFI.