Quote Originally Posted by GTM 3442 View Post
Thanks SBQ.

I quite like "structure", and these two "structures" look quite interesting. I shall have to revisit this stuff. . .

However I suspect that joint ownership could become more complex if such ownership starts to cross state, provincial, or national boundaries - the rules may differ between countries, or between states/provinces within countries. And as you've noted, not all tax authorities respect national borders.
Not that i'm aware of and i've done extensive homework over the years between NZ/Canada/& USA. The only province I know of where joint accounts are considered 'part of the person's estate upon death' is Quebec, Canada. Rest of Canada is like the US where any joint account follows the lines of "Joint with Right of Survivorship"

Throw a changed or changing citizenship/residency/tax residency status into the mix, and there's the potential for further complexity. What works well with a particular combination of citizenship, residency, and tax residency may not work so well if even one of those things changes
In this day of age, people move abroad and reside in many places over a lifetime. Any modern day broker should be able to handle the correct paperwork when a client change residency.

Add trusts, and the mix gets even murkier - does involvement with a trust in another country create enough of a "link" to that country to trigger a tax residency.

To be honest, I must admit that I'm not looking forward to the research. It was hard enough last time*, and I'd bet that it won't have gotten any simpler over the years.

* Once you start crossing borders, even the most knowlegeable-seeming professionals have an unfortunate tendency to slide quickly into a swamp of waffly bullsh*t
The problem with setting up a foreign trust is the operate no different in how you would incorportate a company. That is if you have a US broker and want to setup an trust or company account, you have must do so in the US ; which means that foreign trust or company will pay taxes to the IRS in the same fashion as any person that setups a company or trust in the US. This is different to a foreign individual that has an account in the US (ie like a bank account) where the tax is treated where the person resides in. I am not aware of a foreign corporation or trust being able to operate in the USA (and vice versa with a US company operating in NZ without being IRD registered as a separate entity).

As I mentioned before, i've done the homework on taxation between all 3 places (NZ/Canada & USA). It's a shame to believe that the average working class family in Canada will have a larger pension than the avg working class kiwi family in NZ that contributes to Kiwi Saver. The benefits of share investing is far greater for those that live in N. America PERIOD! all due differences in taxation.