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Freedom, Privacy and Prosperity in the Offshore World
Be Careful What You Wish For
October 4, 2006


Alettermock2
The
            Sovereign Society Offshore A-Letter


Wednesday, October 4, 2006
Vol. 8 No. 198
In Today's Letter: Comment: Be Careful What You Wish For
Offshore: Unintended Consequences 
Wealth: U.S. Debt Keeps Growing
Privacy: Are You a Resident or Not?
Be Careful What You Wish For

Today's comment is by Jack Crooks, Currency Director for The Sovereign Society and editor of The Money Trader.

Dear A-Letter Reader,

For years Stephen Roach, Chief Global Economist for Wall Street powerhouse Morgan Stanley has talked about "global imbalances," and "global healing." At the heart of this global "imbalance" is the massive U.S. current account deficit. But now, Mr. Roach seems pleased with the process of rebalancing that is now underway.

Mr. Roach should be more careful what he wishes for - it just may come true. Improvement in the current account deficit could be dangerous to a host of other investment assets, and boost the dollar in the process. 

According to Mr. Roach:

"Time has finally run out for an unbalanced world. Just like the demise of the equity bubble over six years ago, America's property bubble is now in the process of bursting. Moreover, a sharp resurgence of equity markets is unlikely as corporate profit margins now come under pressure. That means the days of asset-driven support to U.S. consumption are coming to an end. For American households, that spells a return to basics -- the need to draw support from income generation rather than wealth creation. That points to a likely increase in personal saving and, as a result, less of a need for foreign saving -- setting the stage for a reduction in America's gaping current account and trade deficits."

For years, many have suggested a falling dollar is the key to this global "healing" process. The logic being we can export more if the dollar is cheaper, and help close the current account gap. But in reality, because the composition of manufactured goods to services is much lower than it was in the past, a decline in the dollar won't really benefit the current account deficit. 

Thus, as Mr. Roach points out above, the major improvement to the current account will come from two sources: 1) fewer imports, and 2) more domestic savings. I would add a third - a stronger dollar. A stronger dollar would reduce the cost of imports, especially oil which is often a big component of the imbalance number. What's interesting is that these three items can become self-reinforcing, and lead to "improvement" faster than many expect. 

But as the current account improves, any so-called "improvement" effectively means there are fewer dollars spread around the globe. After all, countries around the world stockpile dollars so they can buy stuff like crude, gold, copper, silver, etc. An abrupt drop in dollar supply (global liquidity) through a U.S. current account improvement has led to financial accidents in the past. It makes sense, as liquidity is the mother's milk of financial speculation for all asset classes. 

Bottom line: Tightening liquidity in a system highly leveraged to "inevitable" global growth that doesn't materialize is an accident waiting to happen. If there is a major accident, we could see U.S. fund managers, with their trillions of dollars offshore leveraged for growth, rush back home to the U.S. for safe keeping. And that could be very beneficial to the dollar. Stay tuned.

JACK CROOKS, Currency Director
on behalf of The Sovereign Society

EDITOR'S NOTE: Over 200 of you dialed in yesterday for Jack's take on currency trading and his number one currency pick for October. If you missed it, the audio recordings of his commentary will be available later this week.


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Offshore

Unintended Consequences

In the face of a decade of anti-offshore pressures from the British Labour government, the European Union and the OECD blacklisters, one might have thought the Channel Island tax havens would have sunk under the waves. Quite to the contrary, Jersey and Guernsey, Her Majesty's Crown Dependencies, responded with innovative lower corporate tax laws, tightened regulatory supervision and a host of new, sophisticated offshore investment and asset protection programs. By all reports, the Channel Islands are booming. In 2006 to the end of June, Jersey's investment funds jumped by 42% to £160bn (US$301bn), while Guernsey scored a 37% gain to £115bn (US$217bn). The EU tax directive has brought new business to the Islands that do collect EU taxes but don't share tax information. Many predict that the financial instruments markets will deliver more business as mainland UK financial institutions continue to be tangled in yet more UK and EU red tape.

BOB BAUMAN, Editor


Wealth/Investments

The U.S. Debt Burden Escalates

Total U.S. foreign debt stood at $13.6 trillion dollars at the end of 2005, or approximately $119,000 per household. Rising interest rates since June 2004 are coming home to roost as America pays more to its foreign creditors than it receives from its investments overseas. Though this gap is still relatively small, it is growing.

Some experts compare America's voracious borrowing to a massive hedge fund, borrowing at low interest rates over the last several years while overseas assets generate greater returns. It's a great trade until the trend finally reverses. But alarmingly, foreign funding of America's consumption habits could turn around. This would force the nation to adopt a lower standard of living at some point. By purchasing U.S. Treasury bonds, foreign investors put up more than four-fifths of the $1.3 trillion dollars the federal government has borrowed since 2001. Tax cuts, the new Medicare prescription drug benefit and wars in Afghanistan and Iraq have saddled the United States with massive deficits.

Though long-term interest rates remain historically low, financing America's gargantuan deficits has resulted in a 10% rise in debt payments to foreign investors from April to June, or $36 billion dollars. The size of the country's debt matters because it represents a share of income that American consumers, companies and governments won't be able to spend or save. Ultimately, rising debt payments drain consumption, which reduce a country's living standards. U.S. foreign debt might be high at 20% of gross domestic product (GDP), but other regions and countries also sport high deficits, including the 12-member Euro-zone (15% of GDP), the United Kingdom (17%) and Mexico at 44%.

Debts are a disease. Every great economic power that has ruled this planet has ultimately succumbed to debauching the coin. Over the next decade, if not sooner, the U.S. dollar and other currencies will probably be revalued against gold, the only real money in circulation that isn't someone else's liability.

ERIC ROSEMAN, Investment Director


Privacy&Rights

You Can be "Resident" in Some Countries Even if You Don't Live There

The U.S. is the only major country that taxes its citizens no matter where they live.  However, other countries may consider you a resident-and thus subject to tax on your worldwide income-based on very tenuous connections.

For instance, under the Austrian "key rule," if you possess a key to a residence that you have the right to occupy anytime, the tax authorities may consider you resident in Austria even if you only spend a few days a year there, particularly if they consider Austria to be your "center of vital interests."

A recent case from Canada illustrates an even more extreme interpretation of being "resident." An Air Canada pilot relocated from Canada to The Bahamas, and met the Canadian requirements that he spend more than 183 days outside of Canada each year to be classified "non-resident." However, he continued working as a pilot, and made frequent trips to Pearson International Airport in Toronto, which Air Canada considered his "work base." 

On that basis, the Canadian tax authorities assessed tax on his worldwide income, and the assessment was upheld on appeal. The issue wasn't whether or not the pilot was a resident of The Bahamas (which he clearly was) but whether he was simultaneously a resident of Canada. Because he had not sufficiently "divorced himself" from Canada, according to the court, he remained taxable there even while meeting the 183-day rule.

The bottom line: before you assume that you're not resident in a country to which you have ties, however tenuous, be certain to obtain expert tax advice from an advisor in that country as to your status!

MARK NESTMANN, Privacy Expert & President of The Nestmann Group
www.nestmann.com


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