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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.

addressed to Vern Jacobs (from the Jacobs Report): I was given your e-mail address in the hopes of learning more about how to become sovereign. I would like to know the process and what steps to take in order to do this as well as information regarding any offices or people here locally who could help me in attaining this status.

REPLY: Based on the theory in "The Sovereign Individual" and in the Judeo/Christian bible you don't need to become a sovereign person because that is an inherent element of being human. In the Bible, humans are given free will by God. As for the secular aspects of free will, that is limited by the government where you live and where you consent to be governed. (Your consent is presumed as long you choose to live in that country.) Therefore, you are already a sovereign person, but your freedom is limited by the laws of the country where you live.

The U.S. government structure was designed to permit every citizen to be a sovereign person to the maximum possible extent. However, in the course of two centuries the system has been subverted to the point where the U.S. is essentially a near socialist state. So that begs the question of whether there are any countries in the world today that provide maximum personal freedom. Switzerland is the only country that comes to mind but I admit to having a limited awareness of the lifestyles available in other countries. The Sovereign Society seems to favor Panama. If you have substantial financial resources, there are other countries that give you a tax incentive to live there.

Freedom House (www.freedomhouse.org ) has a public web site that provides a lot of interesting information about the extent of civil, political and economic freedom in countries around the world.

Safe Swiss Passage

Swiss reporter Myret Zaki, who sacrificed three months' salary to probe the UBS financial scandal, was both prophetic and cryptic. "India will never get to know the names of those having accounts in banks across Switzerland. New Delhi has neither the will, nor the clout," Zaki told TEHELKA. "You have to be very rich to investigate," she said in her presentation. On the German Swiss side, Lukas Haessig also investigated UBS as a freelance reporter. But after several months of looking for a book deal, he ended up writing for a publisher on the global financial crisis -- not the actual UBS mess. "Banks love secrecy," says Haessig.

http://www.tehelka.com/story_main44.asp?filename=Bu080510Safe_Swiss.asp

Americans Seeking Reward Money Inform IRS on Others

Americans seeking reward money are turning in neighbors, clients and employers they suspect of cheating on taxes to the IRS at a rate of nearly eight per day, the director of the agency's whistleblower program said. "Right after we got the new law" containing the minimum award, "the fax machine was running the next day," Whitlock told the Offshore Alert Financial Due Diligence Conference. The rate of submissions is on pace to eclipse the 476 applications filed in 2008, a number that was four times the previous year. Whitlock said the submissions have "stabilized."

http://www.businessweek.com/news/2010-05-04/americans-seeking-reward-money-inform-irs-on-others-update2-.html

I-T asks IPL franchisees to reveal details of offshore stakeholders

The I-T authorities, probing the ownership details of the Indian Premier League (IPL) teams, have asked the owners of the teams to disclose details of offshore companies who have a stake in these teams. Though the team owners claim these offshore companies are legitimate, the I-T authorities suspect that atleast some of them had been set up just a year ago or less. "Some of them may be table companies, with just a table and a chair duplicating as offices," said a senior I-T officer.

http://economictimes.indiatimes.com/news/politics/nation/I-T-asks-IPL-franchisees-to-reveal-details-of-offshore-stakeholders/articleshow/5878680.cms

Eighty-Two Percent of Executives Willing to Move Out of Region, Country or State

LOS ANGELES, May 3, 2010 - A wide majority of global executives are willing to relocate for the right career opportunity, according to Korn/Ferry's latest Executive Quiz. The Executive Quiz, commissioned by The Korn/Ferry Institute, surveyed executives from 65 countries about their motivations to relocate.

Overall, a staggering 82 percent of global executives said they are willing to relocate to a different region, state or country. In the April survey, 47 percent of the respondents expressed an "extreme willingness" to relocate to a different region, state or country, and 35 percent said they are "somewhat willing."

Career acceleration is the primary reason to move, according to 78 percent of the surveyed executives. However, compensation is not necessarily the No. 1 motivating factor that is driving relocation. Nearly half of the global executives - 42 percent - say the "quality of life" in a new location would most motivate them, while only 20 percent chose "job title and promotion" or "salary" as the top motivator. Eighteen percent of executives cite "the reputation of the company" as the primary motivating factor.

"It is a major life decision to move away from family and friends for the sake of one's career and there are two significant factors which are driving this phenomenon," said Michael Distefano, Korn/Ferry chief marketing officer. "First, there is no doubt that the global recession has taken its toll. Today's talented professionals realize that it's a buyer's market, which is forcing them to relocate to where the action is. Additionally, the speed of globalization is tearing down boundaries at an unimaginable pace. Although the global business community is operating seamlessly around the world, there are still hubs of economic activity which attract the best and brightest."

Only 8 percent of executives reported turning down an international work assignment. More than half of the global executives have accepted an international work assignment; 41 percent have never been asked to relocate internationally. Additionally, 81 percent of surveyed executives have relocated to a different region, state or country during their careers.

Global executives say the top four most desirable regions to work in are North America, Europe, Asia Pacific and South America.

Offshore Savings Accounts Can Offer Valuable Tax Savings

ST PETER PORT, Guernsey, April 30, 2010 - Each year, according to the Institute of Public Policy Research (IPPR), around 400,000 UK nationals move abroad to work or retire. Opening an offshore savings account could bring significant tax benefits once they cease being UK residents for tax purposes.

Firstly, let's get rid of the age old myth that offshore banking is just for the super-rich or super-sophisticated. As Jim Coupe, commercial director, for Skipton International (www.skiptoninternational.com/) in Guernsey comments, "This is just not the case in today's offshore financial environment where choice of product, competitive rates and tight regulations in offshore centres such as Guernsey make it an attractive marketplace for all types of expatriates. With many familiar names in the offshore financial environment such as Skipton International (www.skiptoninternational.com/) Limited, and of course all the main UK high street clearing banks, there is a wide range of products to choose from to suit every facet of expatriate life - from easy access deposit accounts, sterling higher interest notice products and euro or US dollar savings accounts. With minimum opening balances starting at GBP10,000 in many cases, this is not a market the ordinary saver needs to feel excluded from"

For many expatriates the type of banking relationship they are going to need during their time abroad is often not available or not appropriate from the UK high street. Expat customers tend to be retiring with capital, on short-term placements for career development or perhaps on a more attractive salary package (but possibly not the lavish salaries of previous years). Their needs are therefore different and require a different approach. Working expats will firstly be looking for a safe home for sterling or a safe place to deposit foreign earnings. International expatriates will be looking for flexibility and accessibility to match their global lifestyle, while others will be looking for tax planning advantages. Those who are retired will be looking for ways to generate a greater return on their savings, perhaps with a notice account or a fixed term bond.

One of the problems most investors come across once they have moved offshore is how to repatriate their offshore funds.

Sending wires directly back to your home bank account could involve dangerous invasions of privacy, whereas physically going to your offshore bank and withdrawing cash may also breach customs restrictions and invite the risk of theft.

For larger payments, you could ask your offshore bank to wire funds directly to the vendor, but the time and effort this involves would not be appropriate for smaller sums. In this article we look at using offshore credit cards to repatriate funds.

It is widely recognized that the easiest way of spending your offshore money is with an offshore credit or debit card. An offshore Visa or Mastercard will allow you access to your offshore funds from pretty much anywhere in the world. Here are some typical features of offshore cards: -

Offshore Credit Card - almost all good offshore credit cards are secured. This means that along with the offshore credit card application you will have to deposit a certain amount, (usually 100-150% of the credit line), to use one. For a credit line of 10,000USD at 150%, you would need to deposit 15,000 USD for example. Although this means that they are not strictly credit cards, it does mean that credit checks are not required as with most onshore credit cards.

Furthermore, you can expect from an offshore credit card the same privileges as for any major credit card such as cash advances, car rental benefits, insurance, and travel freebies.

Unsecured Offshore Credit Cards - are not issued by offshore banks except to well-known clients. Due to the global nature of offshore banking, credit checks would be too complicated and the risk of non-payment too great.

The vast majority of 'unsecured' offshore credit cards are scams, because such credit lines would simply not be offered without extensive KYC (know your client due diligence). Most unsuspecting investors who are lured into unsecured credit card schemes end up paying an initial card registration fee and then never hearing from the 'bank' or 'offshore service provider' again.

Offshore Debit Card - offshore debit cards function in almost the same way as secured credit cards, the difference being you can only spend what is actually funded on the card. The advantage is that they will offer the same privileges, benefits and worldwide acceptance as a major international credit card.

Calling Expats Everywhere - Make Sure You Have Your Say!

LONDON, April 27, 2010 - This week marks the official launch of Expat Explorer - the largest global survey of expats - where expats from all over the world can have their say about life as an expat and the challenges and opportunities they face living and working abroad.

2010 is the third year of the highly insightful survey, which in 2009 saw over 3,100 expats participate from more than 50 countries across the globe, making it the largest independent survey of expats, worldwide.

This year, HSBC Bank International is calling for even more expats to take part to ensure that their adopted country makes it into the 2010 survey and features in the league tables published in the Expat Explorer reports.

"Expats from a huge range of countries took part in the survey last year but we couldn't feature some locations because there weren't enough respondents to meet our statistical criteria," said Lisa Wood, Head of Marketing and Communications at HSBC Bank International.

"We would love to have them involved in 2010 and that's why we are asking expats from all over the globe to not only fill in the survey themselves, but to also pass it around to any expat friends, family and colleagues in order to make sure that their country doesn't miss out again."

The 2010 survey will continue to take an in-depth look at expat life, examining how this unique group experience new cultures, new lifestyles and, importantly, how they have been dealing with a new financial landscape as the world continues to recover from the global economic crisis. Last year's survey found that a large percentage of expats had been strongly affected by the global downturn, with a higher number in the UK and US admitting that they were considering a move back to their home country.

Judge says Trio fraud

INVESTORS with $123 million in an offshore fund managed by Trio Capital have almost certainly been victims of a ''fraudulent scam'', a NSW Supreme Court judge ruled yesterday. Justice George Palmer detailed ''vices'' in Trio's business and ruled it was in the public interest to wind up five schemes that it managed, including the controversial fund Astarra Strategic. He was scathing about Astarra's use of tax havens in the British Virgin Islands, Anguilla, St Lucia, the Cayman Islands, Belize, the Cook Islands and Nevis. More than $400 million invested in Trio has been frozen since October, when fears were raised that the $123 million invested in Astarra was the subject of a Ponzi scheme.

http://www.smh.com.au/business/judge-says-trio-fraud-20100416-skin.html

Seven Ex-UBS Clients Accused by U.S. of Tax Crimes

Seven former UBS AG clients, including two who pleaded guilty, were accused of collectively hiding more than $100 million from the Internal Revenue Service as the U.S. extends its crackdown on offshore tax evasion. U.S. prosecutors in New York today released indictments against Shmuel Sternfeld, Sybil Nancy Upham, Ernest Vogliano and Richard Werdiger, as well as a criminal complaint against Kenneth Heller. Federico Hernandez, 44, and Jules Robbins pleaded guilty today in federal court in New York. Upham, 72, and Werdiger, 62, pleaded not guilty to their indictments.

http://www.businessweek.com/news/2010-04-15/u-s-announces-multiple-tax-prosecutions-in-manhattan-court.html

OECD crackdown on tax havens seen lacking teeth

Over the past year, the number of countries on an Organization for Economic Cooperation and Development "gray list" of tax havens that have not fully implemented internationally agreed upon tax standards has dropped to 17 from more than 40. But some say the havens are getting off lightly, and that it is more or less business as usual. For starters, they say the number of TIEAs a country needs to sign to get off the "gray list" list is far too low at 12. In addition, the countries tax havens sign with may have little money moving offshore. Take the example of the Bahamas, a balmy Atlantic archipelago and international financial center that is home to more than 250 licensed bank and trust companies. It moved off the OECD "gray list" in March after signing 18 TIEAs, surpassing the 12 required bilateral agreements. These included TIEAs with the "Nordic Seven," which include Sweden and Norway, but also Greenland and the Faroes Islands.

http://www.reuters.com/article/idUSTRE63H2BI20100418

Now we know the truth. The financial meltdown wasn't a mistake - it was a con

The global financial crisis, it is now clear, was caused not just by the bankers' colossal mismanagement. No, it was due also to the new financial complexity offering up the opportunity for widespread, systemic fraud. Friday's announcement that the world's most famous investment bank, Goldman Sachs, is to face civil charges for fraud brought by the American regulator is but the latest of a series of investigations that have been launched, arrests made and charges made against financial institutions around the world. Big Finance in the 21st century turns out to have been Big Fraud. Yet Britain, centre of the world financial system,

http://www.guardian.co.uk/business/2010/apr/18/goldman-sachs-regulators-civil-charges

Bloomberg's Offshore Millions

It was a dark time for the city. In 2008, and early into the next year, morale was low, Wall Street was sputtering and Mayor Michael Bloomberg was steeling New Yorkers for pain. Brace for service cuts and tax hikes, he warned--while also pledging to find a way to keep tax money, particularly from the city's richest citizens, from fleeing. "I've said this before, but the first rule of taxation is, you can't tax too much those that can move," Mr. Bloomberg intoned on a radio show late in the crisis. "You know, we're yelling and screaming about the rich. We want the rich from around this county to move here. We love the rich people."

http://www.observer.com/2010/politics/bloomberg%E2%80%99s-offshore-millions

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.

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