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Alex Jones, a U . S . citizen, moved to Bermuda 1 0 years ago and he has resided there ever since and has no

Alex Jones, a U.S. citizen, moved to Bermuda 10 years ago and he has resided there ever since and has no intention of returning to the United States. Alex enjoys his Bermuda residence status but continues to maintain his U.S. citizenship for safety purposes and peace of mind. A few years ago, when Alex started his travel agency business in Bermuda, Alex borrowed $1,000,000 from his college friend, Vincente, who is a U.S. income tax nonresident alien and Alex pays Vicente 6% interest annually or $60,000 a year. Vicente will not be subject to a flat or gross 30% U.S. income tax on his interest income and Alex will not have to withhold that tax and timely pay it to the Internal Revenue Service with the appropriate form.

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