Reply by Devere Group

As the most regulated independent financial consultancy in the world, deVere Group strictly adhere to international regulatory laws. By partnering with some of the world’s most respected investment providers, deVere are able to provide clients with trusted financial products helping them to achieve their financial goals and aspirations. Working in financial services can be hard but very rewarding; we provide full training turning our advisers into fully qualified financial planners gaining CISI qualifications.

I hate to say i have encountered this company and been lied to. I trusted their advice and didn't check the history of the company ... they actually called themselves PIC which is also DeVere. I thought i signed into a plan that was for 14 years until I retired, unfortunately when the paperwork showed up some 4 months after the cooling off date i had been put on the maximum 25 years. I tried to call the agent and was told he left the company.

I saw another rep who advised me i wouldn't be able to cash in the plan until 11 after i had retired and would have to pay in until the end... he advised me to freeze the plan and set up a new one for the correct length of time and later he would transfer the money from the original plan but could only do that after 18months.

I thought it sounded good advice which I followed.

I set up another plan and stopped paying the first, after a year or so I tried to contact the new rep to find out when the money was going to get transferred from the original plan...I was told he had left and that the money was not able to be transferred and that it never has been. I lost the $8, 000 I had originally invested. The advice I was given was rubbish... I was scammed twice I wish i hadn't given in to there cold calling antics.

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I found Devere Group very reliable and they help me a lot in my financial problem I would really suggest my family and friends to contact with devere group in future financial services. I saved $2000 and get upto 20% credit really helpful for me.

to robertandy15 #622740

How much did deVere pay you to write that garbage? Just been recruited by them have you, went on the training course in Malta?

Get a life & wake up, smell the coffee. You will be thought how to lie to people face to face, give totally biast advice. Nigel has his own Life Co. on Malta called STM which deVere stick all their clients pensions in. More often than not you'll be charged 35% tax if the country you are retiring too doesn't have a DTA (double taxation agreement) & have to do an annual tax return. Who wants that?

Bad advice is number 1 @ deVere- be warned.

Just search YouTube- who stole my pension deVere! The BBC Panorama documentary about one of the many offshore/onshore companies Nigel Green is behind with his band of merry helpers.

to Ivan Milkytyre #622958

Devere didn’t pay anything. Folks bluff by the person who used devere group name, and now they all people blaming to devere group.

People don’t have sense why they are sending money to the person who don’t have real identity if anybody show you that he or she is related to this company and will give you better future so why you come in greediness everyone want money in return what they invest but don’t think or ensure where going to be invest and when they got bluffed then start blaming for the group who are not involved and start posting all rubbish things in forum and video channels and tell their friends to keep blaming even you are not involved just giving favor to your love once. :?


DeVere "financial advisors" usually lie to their clients to get business. I had a similar story.

Taner Kaplankiran, an advisor from DeVere convinced me to get into a saving plan with Generali for 20 years and promissed that I will be able to get money back after initial period if I don't like the results. The results were disappointing, so I wanted my money back. Then he told me that I can get back only $3000 out of $26000 because of "Administrative fee" that they charge UPFRONT for the whole period of 20 year on the full amount that I would have invested if I didn't stop! I did a monthly saving plan, so it's got as high as 86% of the principal.

If you are fullish enough to trust them a big sum, their cut would be more modest, like 40% (20 years*2%). But I don't think it's a good idea to trust your money to these *** artists.

I would like to assemble a group for a collective lawsuit against deVere and Generali. If you were burned in a similar way, write to me at

to Yuri Plainview, New York, United States #614209

International tax, transfer pricing, FBAR


April 24, 2012 By Lance Wallach, CLU, CHFC


International Tax, Transfer Pricing, FBAR problems

Transfer Pricing FBAR International Tax Problems

By Lance Wallach

The IRS dedicates enormous resources toward dealing with taxpayers who are involved with any form of transfer pricing. The transfer pricing provisions of IRC 482 address four general types of transactions between commonly owned or controlled parties.

1- Use or transfer of tangible property

2- Services

3- Loans

4- Use or transfer of intangible property (especially cost sharing arrangements)

Use of tangible property: When one member of a controlled group rents or leases property to another member of the group, the price paid for use of such property must be appropriate for an arm’s length amount. Per Treas. Reg. 1.482-2(c)(2)(i), the arm’s length amount is determined by reference to the amount that would have been charged between independent parties for use of the same or similar property under similar circumstances.

Determination of what is arm’s length for fair rental value transactions:

a) Period of use

b) Location of use

c) Owner’s investment in property or rent paid

d) Expenses of maintaining the property

e) Type of property

f) Condition of property

Transfer of tangible property: When sales or transfers of tangible property are made between related parties (sales of goods), the arm’s length price generally is the price that an unrelated party would pay for similar property under similar circumstances.

Determination of what is arm’s length for inter-company sales: The regulations specify six methods used to determine whether an arm’s length amount has been charged between members of a controlled group. Treas. Reg.1.482-3(a), states that the “best method" should be used to determine arm’s length price. The IRS views the “best method" as the method that produces the most reliable results based on facts and circumstances. The IRS is well aware of the fact that many transfer-pricing studies are prepared with the intention to validate year-end inter-company cost of sales regardless of whether they are arm’s length just to avoid the IRC 6662 penalties taxpayers would be best served if transfer-pricing studies were prepared by knowledgeable experts in the field.

Inter-company Services: When one member performs services for another member of a controlled group, an arm’s length price is necessary. This includes services such as marketing, management, technical services, or any other type of service. Such services can be provided by one party for the joint benefit of all members, or can be provided between two members of the controlled group.

Determination of what is arm’s length for inter-company services: The arm’s length standard for services between related parties is found in Treas. Reg. 1.482-2(b)(3) which states, “ an arm’s length charge for services rendered shall be the amount which was charged or would have been charged for the same or similar services in independent transactions with or between unrelated parties under similar circumstances considering all relevant facts." The arm’s length charge for services between related parties will depend upon the facts related to the services provided. The pricing rules fall within three categories:

1) An arm’s length charge will be based on the amount that would have been charged by an unrelated party. This generally means that the price should be based on reimbursement of cost, plus a mark-up for profit.

2) An arm’s length charge may be based on only the costs incurred, provided that certain criteria are met.

3) No charge is necessary, if certain criteria are met.

The area that concerns the IRS most with these types of transactions is technical services with regard provided by larger U.S corporations to their foreign CPC’s, which are not charged for these services. In regards to smaller cases, the IRS typically examines management fees in detail to ensure they are arm’s length.

Inter-company Loans: In the context of IRC 482, most of the areas of conflict in this area revolve around interest. When loans are made between members of a controlled group, interest rates charged do not always meet the required arm’s length standard.

Determination of what is arm’s length for inter-company loans: The arm’s length standard for loans between related parties is found in Treas. Reg. 1.482-2(a)(2) which states that “ an arm’s length rate of interest shall be a rate of interest which was charged, or would have been charged, at the time the indebtedness arose, in independent transactions with or between unrelated parties under similar circumstances."

Factors that are listed in Treas. Reg. 1.482-2(a)(2) that should be considered in determining arm’s length interest are:

a) The principle amount and duration of the loan.

b) The security involved

c) The credit standing of the borrower

d) The prevailing interest rate where the loan was made

The regulations provide further guidance in the following areas:

a) Safe harbor rules

b) Ordering rules

c) Determination of bona fide indebtedness

d) Period for which interest is charged

Transfers of intangible properties: When transfers of intangible property are made between controlled parties, the arm’s length price is often difficult to determine, in part because the property’s value derives from intellectual capital such as ideas, the outcome of research and development or creation of software.

Determination of what is arm’s length for transfer of intangible property: The regulations specify four methods to determine whether an arm’s length amount has been charged between the members of a controlled group with respect to the transfer or use of intangible property. Treas.Reg.1.482-4 (a) states that the “best method" should be used to determine the arm’s length price between related parties. Controlled parties may enter into a qualified cost sharing arrangements to share costs related to developing intangibles. They may also contribute existing intangibles for use in further development or for use in developing new and distinct intangibles.

The following general rules of Treas.Reg.1.482-7 (a) and (b) apply to qualified cost sharing arrangements:

a) Two or more controlled participants agree to share the costs of developing intangibles.

b) Costs are shared based on each participant’s share of reasonably anticipated benefits from the intangibles to be developed.

c) A “buy-in" must be paid to the participant that contributes pre-existing intangible property to the qualified cost sharing arrangement.

As with transfer pricing reports, cost-sharing agreements should be prepared by qualified experts who are knowledgeable in this area. The ideal candidate would probably be someone with decades of experience preferably with the IRS in the international taxation area. Said ideal candidate should also of course be a CPA. If examined by the IRS, the cost sharing agreement will be reviewed in detail. For further guidance refer to the Coordinated Issue Paper utilized as a guideline for the IRS personnel dated June 5th 2009.

Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio’s “All Things Considered” and others. Lance has written numerous books including “Protecting Clients from Fraud, Incompetence and Scams,” published by John Wiley and Sons, Bisk Education’s “CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation,” as well as the AICPA best-selling books, including “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.” He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, or visit

The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.


Devere are being investigated by FSA for all their scams, both on and offshore. They have cost customers millions.

Left a trail of devastation in their wake.

By comments on here they have not only treated their customers bad but also their staff. Thats what you get when you dance with the devil.


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