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QUESTION: Do UNALLOCATED metal assets held under the Perth Mint Certificate Program need to be reported on the IRS TDF90-22.1? I recently purchased your book "Reporting Foreign Financial Accounts" as well as the 2010 Update and searched both of them for an answer on this point, and have also searched your online Q&A looking for an answer, but I have not found one.

You have covered the ALLOCATED aspect of the Perth Mint Certificate Program and also the Perth Mint DEPOSITORY SERVICES (a completely different service, which operates like a private client bank account or stockbroking account, except with balances of precious metals in troy ounces---and IS reportable); however, the UNALLOCATED aspect of the Mint's Certificate Program appears to have not been addressed.

With the UNallocated Bullion program, one has title to precious metal deposited in an UNsegregated storage account, and is issued a Perth Mint Certificate. This is not a "managed fund"; it is simply a pool of unsegregated precious metal in which one purchases an interest.

The following description of the Certificate Program appears on the Perth Mint's website:

"With unallocated storage, also known as a metal account, clients purchase an interest in a pool of precious metal held by The Perth Mint. The Mint purchases an ounce of precious metal from the spot market for every unallocated ounce it sells to clients. Accordingly every unallocated ounce is 100% backed.

"The precious metal purchased by the Mint is recorded on its balance sheet as an asset and the unallocated amounts sold to clients are recorded as a liability.

"At purchase, clients only pay for the precious metal. There are no fabrication charges or storage fees, until clients elect to convert their unallocated into a specific coin or bar, which they can do at any time."

Since this question has not previously been specifically addressed or answered, I would really appreciate your view on the UNALLOCATED aspect of the Certificate Program in relation to the FBAR disclosure requirements.

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Gold Hits Sterling Record

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April saw the price of gold hit a Sterling and Euro record. While the GBP754 (or 865 Euros) per troy ounce stat still remains 5% below the all time US dollar record, this was nonetheless excellent news for the British investors.

Compare the GBP754/ounce price tag with the price of GBP562 per ounce, as gold stood back in August 2009 and it means that holders of the previous metal have seen the value of their gold soar 34% in value in less than a year.

It's widely thought that the fact that gold is maintaining such a high price per ounce, despite the fact that the US dollar is making a notable recovery, indicates a growing number of people viewing gold as a 'safe investment,' in light of inconsistent currencies and the still prevalent economic uncertainty globally.

Gold is also proving a popular investment for those who, in times of US dollar instability, might have invested in Euros, Pounds Sterling or even Yen. As these currencies also continue to perform inconsistently, following the recent global recession, investors are increasingly turning to gold bullion, which has proven a more sound investment in recent years.

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National Bank of Abu Dhabi Added to Sponsor Roster for Next Week's Latin America Mid-East Investors Forum in Abu Dhabi

ABU DHABI, United Arab Emirates, April 21, 2010 - The National Bank of Abu Dhabi is the newest sponsor of next week's Latin America Mid-East Investors Forum, a move that reinforces the growing bond between Latin America and the Middle East in a number of areas including agribusiness, real estate, infrastructure, oil, renewables and more.

The Forum takes place this coming Monday and Tuesday, April 26th and 27th, at the Fairmont Bab Al Bahr in Abu Dhabi, and features senior-level executives from Latin America's corporate and investment community, as well as public sector leaders such as the Brazilian Development Bank (BNDES) and the head of Public Credit for the Republic of Mexico.

Registration to the forum is nearly full, with a few seats left for qualified institutional investors representing SWFs, family offices, asset managers, private equity and direct investors, and high-net worth retail investors. Registration for these delegates is free of charge and must be confirmed before the event starts.

Press is also invited to attend and cover the event at no cost. Visit www.latinfinance.com/la-meif or contact Alex Rubin on
arubin@latinfinance.com, +1-305-357-4216, to register.

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IFC International Newslinks

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UBS Client Pleads Guilty to Tax Fraud

A wealthy client of the Swiss bank UBS pleaded guilty on Monday to tax fraud, the ninth American caught up in an investigation of the bank's offshore private banking services, The New York Times's Lynnley Browning reports. The bank client, Harry Abrahamsen, of Oradell, N.J., pleaded guilty in Federal District Court in Newark to one count of failing to file proper disclosures on his UBS offshore accounts with the Internal Revenue Service, according to court papers filed in the case.

According to court papers, Mr. Abrahamsen used a sham offshore corporation in Panama known as Primrose Properties S.A. to help hide his UBS accounts.

http://dealbook.blogs.nytimes.com/


BVI residents defrauded; Anguilla native charged for allegedly operating pyramid scheme

A former BVI resident has been charged in the United States for running fraudulent pyramid schemes which have defrauded several BVI and USVI residents of more than $3 million. Janice Dorette Rey, 48, a native of Anguilla, was arrested by U.S. Marshalls in February 2010, a press release from the Financial Investigation Agency (FIA) has stated. Rey is now in custody in the United States awaiting trial for various offences relating to fraud, in which she is accused of operating a pyramid scheme titled "Global Cohesive Economics (GCE)" which was used to defraud several BVI residents, the FIA states.

http://bvinews.com/?p=1989


Holders Of Swiss Bank Accounts Should Not Be Branded As Criminals

Julius Baer chairman Raymond Baer has hit out at criticism of Swiss private banking, saying clients of the banks in the Alpine state should not be treated as potential criminals, responding to mounting pressure on the country's bank secrecy laws. "In recent years, virtually no new untaxed European money has flowed into Switzerland," Baer says in a speech to shareholders, according to Dow Jones, citing the text of prepared remarks.

"Swiss bank-client confidentiality, as we have known it, does not exist any longer," Baer said. He also urges European Union member states to "not slam doors on those who are seeking a path to full tax compliance".

www.wealthbriefing.com


Online Specialist Discounter for Electrical and Electronic Appliances Opts for Payment Solutions From a Single Source

MUNICH and GRASBRUNN, Germany, April 11, 2010 - redcoon GmbH, headquartered in Aschaffenburg, has decided in favor of the payment services of Wirecard AG. The redcoon company has meanwhile become one of the leading European specialist discounters for entertainment electronics, white goods, computers, photography articles and sports equipment.

The agreement signed with Dutch subsidiary redcoon B.V. comprises the processing of credit card payments along with an additional risk management package as well as credit card acceptance (Acquiring) services via Wirecard
Bank AG. The redcoon online shops established in nine European countries at present will gradually be integrated one by one: Germany has already been integrated, to be followed soon by Denmark and, step by step, Belgium, Italy,
Spain, Poland, Portugal, Austria and, finally, the Netherlands.

In its online shops, redcoon sells entertainment electronics, white goods, photographic and computer products as well as sports equipment. In the process, not only does redcoon concentrate on a large selection of articles at favorable prices, but also on excellent service and speedy delivery.

"To maintain our low level of prices, short and efficient processes are a key prerequisite. In Wirecard AG, we have found a partner who can provide all solutions in the field of payment processing from a single source. High
service quality, flexibility and, in particular, availability are of primary importance to us," says Michaela Langpap, General Manager at redcoon GmbH in describing the benefits of this collaboration.

"In cross-border trading, not only is smooth, seamless processing and settlement of payment transactions of enormous importance; merchants like redcoon, operating on an international scale, assign increasing importance to professional risk management. This is where our expertise and experience really count," says Christian Reindl, Vice President E-Commerce & Consumer Goods at Wirecard AG.

Offshore Savings Plan

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New Fixed Rate 5 Year Account Offers 4.5%Gross/AER

ST HELIER, Jersey, April 9, 2010 - A new sterling 5-Year Fixed Rate Saver account offering 4.50% gross/AER has been launched by Jersey based Abbey International. The account is aimed exclusively at new and existing Premium Banking clients. Premium Banking from Abbey International is an enhanced service suitable for those clients requiring a more personalised service from their offshore bank, with preferential early access to selected products and services and preferential interest rates on qualifying products.

The Premium Banking service is built around the core of Abbey International's Gold account, a multi currency, internet enabled current account which offers a range of benefits including Visa Infinite deferred debit cards and Monthly Offshore Saver, a high interest regular savings account.

A second version of the 5-Year Fixed Rate Saver account paying an attractive 4.00% gross/AER is also available for clients who have not signed up for Premium Banking which is linked to an Abbey International Call account, again offering multi currency banking facilities and internet access.

In both cases, a minimum deposit of GBP50,000 is required to open the account, with no additional deposits or withdrawals permitted during the five year term, although additional accounts can be opened to accommodate further deposits, if the account is still available. Interest is paid annually on the anniversary date of the account opening and either transferred to a Gold or Call account, depending upon which option the client has selected.

Commenting on the new account, Head of Client Experience Jane Matthews said, "This new account offers our clients a known and stable rate of return for the next five years and complements our other shorter term fixed rate savings accounts, such as our 18 month account. As a part of our Premium Banking services, clients can expect a more personalised service, ideally suited to the demanding lifestyle many of our clients may have."

Anxious US Taxpayers Who Disclosed Foreign Bank Accounts and Await Their Call From the IRS Need to Decide Whether to Accept the "Offshore" Penalty or Withdraw From the Program, Says Marks Paneth & Shron Director and Former IRS Special Agent The Call From the IRS Will Come; Once It Does, US Taxpayers Must Make Tough Decisions About Whether to Accept the 20% Offshore Penalty or Dispute It by Showing "Non-Willful" Failure to File an FBAR via an Audit, Says David Gannaway.

US taxpayers who disclosed their foreign bank accounts under the government's Offshore Voluntary Disclosure Program are growing anxious as they wait to hear from tax authorities.

But instead of worrying about whether the call from the IRS will come, they should be more concerned with the decisions they'll have to make once they're contacted, says David Gannaway, a former IRS special agent with the Criminal Investigation Division who is now a Director in the Litigation and Corporate Financial Advisory Services Group at New York accounting firm Marks Paneth & Shron LL.

According to Mr. Gannaway, anxiety is mounting among the more than 15,000 US taxpayers who submitted applications before the October 15, 2009 deadline and who complied with the Information Document Request due on January 15, 2010. "The IRS is working through its backlog of cases," Mr. Gannaway says. "US taxpayers can rest assured that they will hear from the IRS in due course."

"What they need to be concerned about is the decision they'll have to make once the IRS does call -- should they accept the standardized penalty, or contest it by asking for an audit. An audit can be difficult and time consuming, but it could drastically lower the 20 percent 'offshore' penalty amount that taxpayers will have to pay," Mr. Gannaway says.

Offshore Funds and the IMA

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From today the Investment Management Association (IMA) is including offshore funds in its sector classification system. A total of 91* funds will be included in 17 different IMA sectors. This is up from the 71 funds announced on 23 March,* as since then the IMA has received outstanding data from more funds that now meet the requirements.

In total, the IMA received admission requests from 180 funds, and there are now 69 pending, awaiting the finalization of queries and data from the funds. Once they are complete, they will be added to the appropriate sectors.

To be included in IMA sectors, funds need to be domiciled in the EU, as well as authorized in their own country, comply with UCITS regulations and be registered for sale in the UK. To satisfy UK domiciled retail investors, transactions should be in sterling. Therefore, most funds offer a sterling share class or one that is hedged back to sterling. However those that don't will typically provide a currency dealing facility. Funds must also have either Distributor or Reporting Fund status for tax purposes.***

IMA will shortly be calling for submissions to the second phase of entry for offshore funds. A third phase is anticipated in the last quarter of 2010.

Commenting, Jane Lowe, Director of Markets at the IMA, said:

"Funds are being admitted to 17 different IMA sectors, with the largest number, 42, going into the Specialist sector. It's pleasing to see the number of offshore funds that will be included initially. We expect the number to grow during the course of this year.

"Setting out clear criteria means that investors can compare offshore funds on a like-for-like basis with UK domiciled funds. Advisers and investors need to be aware that there are some differences when purchasing offshore funds, so the IMA has produced a factsheet."

The offshore funds will be fully integrated into the existing sector classification system, allowing comparisons between funds to be made on a like for like basis. However, the IMA will flag which funds are offshore so that investors and IFAs may search for this data if they so require.

China's Gold Market

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World Gold Council and ICBC Enter Into Strategic Partnership to Promote China's Gold Market

BEIJING, April 1, 2010 - World Gold Council ("WGC") and Industrial and Commercial Bank of China ("ICBC") have signed a memorandum of understanding (MOU) for strategic cooperation within China's gold market. This agreement will enhance the exchange of market information between WGC and ICBC to promote domestic demand for gold, encourage investment into China's gold market, as well as jointly develop and market new gold investment products within the country.

Under the terms of the MOU, WGC and ICBC will share their resources and international gold market data to provide personnel training, research, and product development, as well as trade analysis. ICBC will also offer integrated services in gold investment and trading through its investment channels and client resources.

Both parties will explore and jointly develop new gold investment products tailored to the Chinese market, and conduct surveys and studies on the domestic retail gold investment market, facilitating financial innovation and product diversity. In addition, WGC and ICBC Precious Metals Business Department(s) will set up an ICBC/WGC Gold Business Strategy Board to discuss and plan strategies for their cooperation, as well as an Action Team to oversee the implementation of the decisions and initiatives adopted by the Strategic Group.

Aram Shishmanian, CEO of World Gold Council, commented at the MOU signing ceremony in Beijing:

"WGC will continue to develop strategic partnerships in China, in order to provide a stable and sustainable service to Chinese gold investors, and therefore help them achieve wealth preservation."

ICBC is the largest commercial bank in China and also the largest bank by market value and the most profitable commercial bank in the world. By the end of 2009, ICBC had 16,224 offices both in China and abroad, offering a wide range of quality financial products and services to 212 million individual customers and 3.63 million corporate clients around the world. WGC is the gold industry's key market development body and, as such, works with multiple partners and to promote the use of gold in all its forms. As a leading country in gold production and gold consumption, China is one of the most important strategic markets for WGC. The alliance between two major players, WGC and ICBC, will not only enable ICBC to better integrate in the domestic and foreign precious metals market but also stimulate the development of the gold market in China.

ST HELIER, Jersey, March 31, 2010 - Abbey International is currently celebrating twice over having won the coveted Best International Bank award in this year's Investment International Finance Awards and this week secured a "Best Buy" listing for its popular 18 month fixed rate deposit currently paying 3.57% AER with Moneyfacts, the independent industry monitor (source: Moneyfacts.co.uk). The Investment International awards are amongst the oldest in the offshore banking industry, having been running for some 20 years. Awarded solely from reader votes, over 800 magazine subscribers and website users took took part in the voting which started at the end of November 2009 and ran up until 31st December.

Commenting on the award, Jane Matthews, Head of Client Experience at Abbey International said, "This is an important award for us - we realize that international banking is a fiercely competitive market, so to win an overall award like this, we have had to both offer consistently attractive products and back these up with excellent client service. Now ultimately part of Banco Santander, the largest bank in the euro zone by market capitalization and third in the world by profit, we believe our client offering based around strength, stability and service is a winning combination. Looking to the future in 2010, we are anticipating being able to offer clients an increasingly diverse range of products, reflecting the changing demands of the market, but all built with the same objectives of wealth preservation and wealth creation - supported by our relationship managed service".

In 2009, Abbey International became the first major offshore bank to launch its range of Visa Infinite and Visa Platinum deferred-debit cards which offer a range of lifestyle services and enhanced levels of cover. The bank's product range is evolving as it move towards offering a range of accounts and services which are designed to appeal to a more discerning high net worth client. The Abbey International 18 Month Limited Offer Fixed Rate Deposit Contract has a minimum opening balance of GBP100,000 and is available in sterling only to new and existing clients. Abbey International is part of the highly regarded Santander Group, which has more than 150 years experience in banking and clients all over the world. For further information on banking with Abbey International in Jersey call +44(0)1534-828-828 or log onto www.abbeyinternational.com For media use only and not to be relied on by consumers to make financial decisions.

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