the wiggly tail of Blairmore Holdings

Ages ago I downloaded the prospectus for Blairmore Holdings. I stashed a part written post about it in my notes. Patience has its rewards because it is now in the mainstream news.

There are a couple of points that don't stack up with the chorus of secondary politicians defending their leader right now in the saga about who held what.

Firstly, the reported £30,000 holding cashed in? A minimum holding stipulated with the fund is USD100,000. This would imply that the total holding by a single entity would need to be at least USD100,000. Either this condition was waived, or there was a joint holding, which would then be closer to $100,000 - split 2 ways? Could it be that Sam and Dave each cashed in £30k? Not what Dave implied. Someone should really ask...

Then the statements about this being a regular trust mechanism and not one particularly designed to avoid UK tax. That's quietly contradicted in the original prospectus, which made s specific point of saying it is designed to avoid UK taxation.

As a clue, the banking arrangements were via Nassau, Bahamas. Payment into the fund was via Société Généralé in New York.

Intriguingly, the investment managers are Smith and Williamson, 25 Moorgate, London. That's really the working part of the Fund, having to decide what it invests in. One could say that the financial factory was based in London. I wonder if any of the beneficial holders of the trust had links with that firm (wink)?

Then there was an English legal firm, Simmonds and Simmonds from Ropemaker Street EC1, as well as the Mossack Fonseca in Panama. Add some Deloitte and Touche auditors from Nassau, a few more advisors and banks and it makes a complete structure.

But that was then.

The trust has since relocated to Ireland, which also claims that funds are not subject to any taxes on their income (profits) or gains arising on their underlying investments. Furthermore, with Irish regulations, the treatment of foreign investments can reduce or eliminate withholding taxes under Ireland’s network of tax treaties.

I notice that the current Blairmore fund is currently rated at around USD30 million. Some of its top ten holdings are also well-known tax optimisers. Top holding is Google (Alphabet), 2nd is Walt Disney (tax via Luxembourg) and 8th holding is Amazon.

There's probably another story in that?


And here's those Prospectus extracts (SEOs rev your engines)...

Blairmore Holdings

Minimum Investment
The Directors are entitled (in their sole and absolute discretion) to determine the minimum initial investment amount and the minimum amount for subsequent subscriptions from time to time. As at the date of this Prospectus, the minimum initial investment per subscriber is US$100,000. Shareholders must maintain this minimum level of subscription in the Fund...

Taxation, United Kingdom

(a) The Fund
The Directors intend that the affairs of the Fund should be managed and conducted so that it does not become resident in the United Kingdom for United Kingdom taxation purposes.

Accordingly, and provided that the Fund is not trading in the United Kingdom through a fixed place of business or agent situated in the United Kingdom that constitutes a “permanent establishment” for United Kingdom taxation purposes and that all their trading transactions in the United Kingdom are carried out through a broker or investment manager acting as an agent of independent status in the ordinary course of business, the Fund will not be subject to United Kingdom corporation tax or income tax on its profits... "

produkt review

Sometimes it is the simplest things.

Take this product called Produkt, from that well known purveyor of Billy bookcase.

Plonk it into warm milk and switch it on to make frothy milk for latte coffee.

The bulky mains powered fancy machine I'd used previously took 2 minutes, required a teflon interior coating and a complete overhaul after every use. This takes about 10 seconds and then a quick dunk in some water.

And all for £1.

Oh yes. Even if the instructions were in Norwegian.

my iPhone secret experiment

I decided to carry out a secret experiment when the recent iPhone SE was announced.

I decided to take a leaf from all of these tax-free people and see how long it would take to use Apple shares to create a tax free gain sufficient to buy a new Apple iPhone 'for free'.

So I set up a watchlist on a W8-Ben compliant share trading platform. I added an amount of money equivalent to the maximum level of the current UK ISA, which for 2015/16 is GBP 15,240. In other words I put the virtual money into a virtual tax-free wrapper.

Then I set the watchlist to buy Apple shares at the announcement prevailing USD106.51 rate.

The I let it run until Apple's share price got over USD109.27, which would be the equivalent of a 2.59% gain, or expressed in GBP, a gain of £395 - i.e. the price of the phone.

The number was broken today and ran on to around USD109.93, briefly going over USD110. That shift moved the gain to be sufficient to buy the larger 64Gb iPhone.

Now, I did this as an experiment only, and I can say that it took 8 days to see the gain, based on what I perceived as Apple's comparatively low share price before the recent announcements.

Just an experiment and just for fun, of course.

the allure of the Panama hat

I once had a proper Sheplers stetson hat, acquired when I was in Texas, but it was 'lost' at some point after I returned to Blighty. I've had a secret hankering to replace it alongside maybe adding a proper panama hat to the collection.

Rather a round-about way to get to that Cameron Blairmore Holdings thing. I last wrote about it in February 2015. The story just resurfacing has been around for years this time unfolding as part of the bigger Panama offshoring wheeze. (See, unfolding - a panama hat reference!)

Of course, the fund was entirely legally framed as Panama based, and even included something in its Memorandum about not ever wanting to be considered as under UK jurisdiction. So that's all right then.

Another UK person in the Panama list is my one-time MP, who is no stranger to investigations. These include windfalls from Dolphin Square property, controversial support for Asil Nadir during Nadir's £29m fraud conviction and even a curious example when the MP used a rented property in Winchester as his residential address for an election campaign. It must have all come good though, because when he retired from Parliament he stood as the Police Commissioner for Hampshire.

By comparison, the Osborne family's painting and decorating business Osborne and Little shows its corporation tax avoidance as a very straightforward matter.

It saved the tax because of 'timing differences' in cashflow, which has resulted from £34m turnover, £722,000 profit and -er- £0 corporation tax. Actually, there's a rebate from 2010 of £12k. All entirely within the law, of course. No wonder the main director (George's dad, Sir Peter) gets a salary of £680k per year and the company has paid no CT on its £200 million turnover across the last seven years.

But back to the more complicated world of Mossack Fonseca. The data exposure is interesting because of its scale. It looks as if an entire server disk has been intercepted and then Nuix used to create machine readable formats and indices for all of the documents.

Then it becomes easy to type in search terms like 'Putin', 'Cameron', 'Sergei Roldugin', 'Bank Rossiya', 'Dietrich, Baumgartner & Partner', 'FIFA ethics lawyer' ...

We shall see.

what Katy might do?

One of those days when the weather changes in minutes.

It's like we have already moved into April a few days early.

The cherry blossom is back on the tree, but I'm wondering whether Katy is about to change all that.

time for an iTunes reshuffle

Away for part of Easter and an ideal time to run some of those long duration batch jobs to tidy some of the rashbre file system. Aside from the ongoing routine backup, the main chore at the moment is cleaning up iTunes, which in my case contains both music and video.

I've done that thing where you select File/Library/Consolidate and iTunes speedily rebuilt its directories into a much tidier form. I think the prior mess was a consequence of various generations of iTunes having different spaghetti ideas about how to organise.

The tidy-up is one of those simple push-a-button things. However, it shouldn't be undertaken lightly because it does completely re-organise the iTunes structure.

Afterwards, I wanted to ensure iCloud hadn't hi-jacked various files. That's the part that takes the longest, because there were still around 1,000 files that were in a state of cloud confusion.

I've since clicked the little iTunes iCloud button to sort it all out, but it will take a day or so to process, even on quite a fast internet connection. The main reason I'm doing this is to get the best quality legitimate versions of all of the music and videos, based upon the index entries in my iTunes directory.

Then I must backup the newly recrafted iTunes directories, using Chronosync.

I've decided to move the prior backups out of the way and to create new fresh clean ones, in effect streamlining the whole file structure. I noticed the Master iTunes directory has crept up to just over 2TB of disk. That'll be the digital video content I suppose.

Anyway, by the time I get back, it should all have rearranged itself nicely.

wet motorway jams and the heavyside and lightside sectoral balance

A change of plan today, on the basis that the roads could be rather overloaded. It looks as if I was right to follow the advice to not travel.

That was even before the rain started.

But yippee, it's easter, so we can have a few days break.

Just like all the traders selling shares defensively against unexpected news during their time off.

Red = Down and Blue = Up. That redness of the FTSE100 looks fairly down to me?

Except for blue spots on betting shops this sporty weekend and, curiously enough, for the makers of motorway concrete.

I think I can see why there's enduring strength in motorway construction.

so the new iPhone looks like the old excellent industrially designed iPhone?

The announcements about the newest iPhone are more muted because it is, after all, a device that looks like one of their previous generation designs.

For me this is great news.

My existing phone still does great service, although I often use a battery pack to keep it working for a full day. I've had occasions when the phone has been at 45% by 10:00 in the morning, when I'm doing busy things around London. That's more about me than the phone though.

The svelte 5s design is still, for me, a winner and I'm pleased to see that Apple have figured a way to cram just about all of the electronics of the 6s series into the 5 (SE) shell. For once, if I update, then I won't need to change my car accessory holder again.

I'm probably not exactly the target market for the SE (I assume that's the 7), but the SE could well be a useful way to get better battery life, near-field Pay and improved camera capabilities for what amounts to about 55% the price of my original device - And still be able to use the old accessories with it.

As Apple sets its sights on China and India, these smaller form factor and less expensive units become their gateway devices.

I assume they will prefer to ship as many units as possible with the Pay facility, which they can also link to their wider plans in these markets.

The share price hasn't moved much yet, but I'll guess there will be action as the implications of these relatively modest sounding announcements become apparent.

should i stay or should i go?

One of the things we covered when I studied economics was the role of government to encourage stability and reduce uncertainty.

Later, a European boss of mine used to refer to the need for things to be 'boringly predictable'; I knew what he meant. Kind of 'Say it, Do it.'

I can understand these sentiments for the big picture. If the future path of government policy is uncertain, it raises risk premiums and can lead businesses and individuals to delay spending and investment.

If there is uncertainty about the monetary or fiscal policy, the tax or regulatory regime, or even over voting outcomes then it all gets added into risk pricing.

Our leadership, here in the UK, seems to have just about all of these effects.

Government spending has swung around with inaccurate forecasts from no less than the Chancellor himself.

The current fiscal mandate is being challenged by many economists who think that (a) the target for 2019/20 is misguided and (b) it will be missed in any case.

Some politicised tax changes were announced in the budget and then rescinded within a couple of days.

This introduced a new gap on top of the unexplained prior gap and both are currently left hanging and unaccounted for.

There's stealth measures around tax credit cuts that no-one is yet spotting but probably the chancellor relies upon.

The GBP to USD is bouncing around about its five year low.

The main parties are themselves divided and at least two of them have rumours about new leaders, ranging from Boris Johnson for the Tories and Dan Jarvis for Labour.

In both cases the popular date for this further upheaval is just after the referendum.

With that still to decide, as The Clash might say, "Should I stay or should I go?"

fire up the fitbit

I've re-gobbledegooked my fitbit so that it is working properly again. It went through one of those phases where the device sulkily folded its arms and said it wouldn't re-sync with anything. It was a few days before I realised and noticed that my position in my family and friends league table had slid away to the very last position.

After I re-installed the sync software, a combination of recharging it, pressing the button for 10 seconds and then re-synchronising it eventually worked. Yay, hop, skip and jump (3 steps).

I still prefer the hidden type of fitbit device, not wanting to sport a plastic LED readout on my wrist.

Curiously most of the newer device types are not designed to be hidden, and if anything are becoming larger visible devices. Not just from fitbit, but all of the other manufacturers as well.

This summer it will be three years since I first walked fitbit along the beach in Santa Barbara. That's apparently 11,242,616 steps. Perhaps it just needed a break?

i finally see the martian movie

I finally got around to seeing Ridley Scott's 'The Martian', the space movie about a biologist (Matt Damon) getting trapped on Mars after a space mission goes awry.

The movie has been on my list to watch, along with my slight intrigue to compare this Matt Damon character with his Dr Mann in Interstellar, an astronaut stranded on a planet the other side of a wormhole.

The Martian becomes a classic space rescue movie, in the vein of Apollo 13 or Gravity, with maybe some Silent Running thrown in for good measure.

I quite enjoy this type of space film, closer to reality than Star Wars / Star Trek franchise movies.

Admittedly this one still glossed over the reduced gravity and -60 C temperatures on Mars. It also had the inevitable explanation of a science point with a couple of cups and a biro, but it still made for a good story. If thrillers have MacGuffins, then this type of space movie's alternative is to include slingshot gravitational effects.

I was intrigued to see the movie is classified as a comedy, but maybe that's on some kind of special Ridley Scott scale, where the cat scene from Alien is also comedic.

choreographed responses

The unravelling following the budget is already bringing out co-ordinated responses from a group of government MPs. The briefing appears to be along the lines that "we are all great friends with Mr. Duncan-Smith, but don't agree with him on this issue" (sometimes adding that it is part of a EU exit diversion).

I listened to the Iain Duncan-Smith interview with Andrew Marr at the weekend and it seemed clear that ID-S was mainly championing welfare reduction of inequality and that this had little to do with EU arguments. He has run his welfare positioning for at least the last eight years and it is not something hastily assembled as a back-story.

Rather, the situation seemed to reveal someone cornered by the political machinations of his party, a party determined to use the rule of spreadsheet to achieve its ends.

That's not to say that ID-S schemes have worked. He is no project manager. Among other things, Universal Credits delayed and overran, with Osborne now stealthily using them as a vehicle to re-introduce tax credit cuts. Universal Cuts, one might say.

By now the political landscape has all changed. IDS resigned from the Cabinet and already speedily replaced. Cameron has slammed the brakes onto Osborne's 'take from disabled' scheme and rank and file conservatives are being wheeled out to replay the party line version of events. Corbyn has hinted that Osborne should 'consider his position'. Politics as a twitch game.

Disruption coverage assures that the signal to noise over the next few days will be low, and I expect there is already a team looking out for a good diversionary story to overtake this in the news.

I'll go back to my jelly steering wheel viewpoint from a few weeks ago. Maybe with Ant and Dec driving.