“The test of our progress is not whether we add more to the abundance of those who have much; it is whether we provide enough for those who have too little.” – Franklin D. Roosevelt
Well, this time in history will be remembered, in the times that the multi-national corporations have most of them fled their regional scenes and put their headquarters and main operations into tax havens. Therefore, with this in mind, the states and republics that actually is where they make the profits get less tax and get fewer monies to spend on public services. That does not make them poor, but smart someone might say. This is legal and the openness of the economies let them do it, but to be frank, we should question this big giant corporations for their fleeing fortunes abroad.
The corporations are not alone in all of this, the rich people themselves cannot sustained this, they cannot afford to pay reasonable taxes, and they need tax-relief so they can salvage their Monte Carlo and their Lamborghini’s. They have their massive mansions and stalls of cars, but cannot pay the percentages on the tax as ordinary working-class do. In addition, the working-class use decades on end to pay down the mortgage on the house and loan on their Ford Fiesta. If they can even afford a house and a car at his point.
The American enterprise and experience is really seeing it, as they plan to repeal and replace Obamacare, because the wealthy are too broke or to selfish to help the working-class who made them rich. That the working-class and industrial worker are falling behind as new schemes to outrun their possibilities. The corporations and the believers of free economies want more flexibility, but do not give equal wages or compensations. Therefore, the loser in the transactions are the workers and not the companies. Secondly, the states earn less without added productivity.
It is naive that the businesses care about other things than the bottom-line is vicious, like the wealthy have the capacity to share the spoils, which they have earned on the commoners and the citizens. Therefore, the spoils, which in some industries entails sweatshop workers and exports to the Western hemisphere with grand profits for the clothing and appeal giants. Something that the workers in Bangladesh or Pakistan doesn’t see anything delivered back, than a filthy industrial complex and possible health hazards for their hours work on end for a lousy T-shirts.
The others are the ones who are doing mining and extraction for the technology and IT businesses that has no issues with the illegal and militias taking controls over mining fields and black-market trading of rare earth minerals or cobalt for that matter. As long as the giant companies trading computers, smart-phones and whatnot get their profits. Certainly, the CEO and other leaders in the corporations should worry of the implications and the lives destroyed while their businesses are earning loads of monies. There should be some sort of certification of the weak trading points; if they knowingly paid, some of the monies on technology could fund militias and illegal armed conflicts.
This is real poverty, that we have systems, salary structures and imports that hurt local areas, while the businesses earn fortunes, that again is flying on the merry to a tax haven in the pacific through a shell-company set-up by lawyers in Panama. In addition, this is legal and just, by law and in society. That the same companies telling their workers that they cannot afford more wages, since they have to stack millions upon millions in the British Virgin Island. So that the shareholders and stakeholders can earn profits for the toils and sweat of fellow workers.
So when I hear that the workers cannot ask for bigger salaries, while the states and republics create tax-holidays and tax-breaks, incentives for “investments” while the big-men are doling away vast fortunes in the middle of the day. Like a legal heist, a theft of both tax and salary, the salaries that could be used more in the system to gain growth, and secondly the added tax that could build roads and infrastructure that the company could need. However, hey, we do not need proper roads and wages, as long as the rich can travel to Monaco and St. Tropez whenever they feel like it. We are foolish to think otherwise!
When you hear that the rich has to get tax-breaks and their taxes cut, know that they are poor in spirit and heart. They may have vast fortunes and riches, but their hearts are empty. They do not see the problems of the day-to-day basis of the ones creating their empires. They do not see the people who buys their labeled products and services. They only see the bottom-line, the empty shells companies’ accounts and the schemes to hide the monies. That is because these wealthy people are so poor; they cannot afford to be like the rest of us.
The wealthy are so poor, they are so poor that they have to avoid taxes or pay taxes, because if they were paying taxes they would be like us. They would have the same responsibilities and have the same understanding of welfare and public services. Therefore, since they do not need the public service, they can afford to travel abroad for health-care; they can afford to send their kids to private schools and can afford to import goods. Then they do not need the support and the base line of the republic or the state. Like you and I do. Therefore, with that in mind, which is why they are so poor. Their poverty is in the mind and in their spirit; they cannot be a part of us, because they want to shield themselves from us. Still, earning our monies and taking our cheap labor, no problem!
This poor people need help, they need guidance, their riches might fall out of their hands, might be lost in coup d’état or worse than they get bankrupt. Than they need the states to salvage their business or their bank, with our tax-monies, without any hesitation, but when it was booming. That was the time they had no need of paying taxes or paying amends to the state through the regulations. Like we do and pay for our right to live and use the needed services of the states.
In these interesting times of ours, we have the riches seeking to pay-less, while the working-class is footing the bills or trying too. While the republics and states make it harder for public service and make it more expensive to pay for the needed services. This are all made in the hands of the wealthy and the multi-national corporations, without considering the implications of the commoner, the working-class nor the middle-class that are all sinking on the behalf of the rich. Certainly, the belief that the trickle-down economy should be a project avoided, but to many still have faith in the paradigm. While very, few have any social mobility or have the capacity to go from one class to the next. Peace.
After reading a Forbes article on Illicit Financial Funds leaving Ethiopia, as they question the need for and the use of donor aid to Ethiopia. I had to read the reports that it partly was based and make my own assumptions. The difference is that I want to focus on the East African Nations and their Illicit Financial Funds that leaves the States. So that the values and the amounts show’s lack of governance and regulation of finance gives way for the African governments and corporations to get away with transferring funds without legal bounds. This is a way of misusing funds and also money laundering through lacking revenue service and authorities to keep up the upkeep of the states. Take a look!
“IFFs are illegal movements of money or capital from one country to another. GFI classifies such flows as illicit if the funds crossing borders are illegally earned, transferred, and/or utilized. If the flow breaks a law at any point, it is illicit” (GFI, 2015).
“African governments have a political interest in IFFs because these flows impact their national development aspirations and encroach on state structures. They therefore have law enforcement and regulatory agencies whose duties include preventing IFFs. Among these are the police, financial intelligence units and anti-corruption agencies. Governments also have customs and revenue services and other agencies whose purposes are thwarted or hindered by IFFs” (IFF, P: 35, 2016).
“The widespread occurrence of IFFs in Africa also points to a governance problem in the sense of weak institutions and inadequate regulatory environments. IFFs accordingly contribute to undermining state capacity. To achieve their purposes, the people and corporations behind IFFs often compromise state officials and institutions. Left unchecked, these activities lead to entrenched impunity and the institutionalization of corruption” (IFF, P: 51, 2016)
“Most African countries do not have enough highly trained lawyers, accountants and tax experts to carry out the oversight functions to prevent or punish perpetrators of illicit financial outflows. The few that exist are often overworked and unable to prepare sufficiently to take on top-class representing large corporations” (IFF, P: 72, 2016).
Illicit Financial Funds ranking in the years of 2004 – 2013:
Nation
IFFs
Ranking
Burundi
$87m
124
Congo (DRC)
$225m
107
Djibouti
$375m
96
Ethiopia
$2,583m
46
Eritrea
$38m
133
Kenya
$83m
125
Rwanda
$359m
97
Somalia
$0m
147
Sudan
$1,311m
67
Tanzania
$482m
90
Uganda
$715m
78
*(in millions of U.S. dollars, nominal)
* Global Financial Integrity December Report 2015
Total IFFs in the years of 2004 – 2013 (GER+HMN)
Nation
Total IFFs
Burundi
$866m
Congo (DRC)
$2,254m
Djibouti
$3,745m
Ethiopia
$25,835m
Eritrea
$115m
Kenya
$829m
Rwanda
$3,589m
Somalia
$0m
Sudan
$13,115m
Tanzania
$4,820m
Uganda
$7,149m
*(in millions of U.S. dollars, nominal)
* Global Financial Integrity December Report 2015
* “Trade misinvoicing (GER) dominates measurable illicit outflows, averaging 83.4 percent of total illicit outflows during the years 2004 to 2013. However, there has been a noticeable growth in the hot money narrow (HMN) estimate of balance of payment leakages over those years as well. Though initially only accounting for 6.9 percent of illicit outflows in 2004, HMN rose to 19.4 percent of illicit flows by 2013” (GFI, P: 10, 2015).
If you look at the charts there are some monies that is missing and gone away on all sorts of schemes and tax exemptions, all sort of added invoicing or other types of financial instruments to make sure the monies doesn’t end where they are supposed to be. The East African states have misused giant amount of funds.
Ethiopia, Sudan and Uganda are topping the list. What is weird for me and the report it is not specifying the Sudan as the Khartoum republic or putting South Sudan alone! So the report and the values put on South Sudan, which was independent in 2011, there do not know what of part of Sudan who has illicit funds. Still, the values and the amount of million dollars Illicit Financial Funds (IFFs) from Ethiopia for instance. You can wonder how much of the government budget that is eaten by this sort of financial mismanagement and misuse of public funds. The reserves and state coffers have to be hit when it is these amounts of dollars that are lost. Uganda have also gotten rid of giant amount of funds, these is 10 higher than the revelation during the Oil Probe with the 2.4 Trillion shillings, which is about $640-700m dollars. That we’re oil revenue that has not been remitted to the state, just these values is ten-times of what was revealed in the Ugandan courts. So there is other revenue that the State House, Bank of Uganda and Uganda Revenue Authority not have complied to or have registered as there is a loss of $7,149 million dollars.
These is just two financial instruments as the HMN and the GER that is explained under the table, the other ways of misusing funds, I haven’t even covered. This is just how much that is miss-invoicing and Hot Money Narrow, the others can be shown at another time. The numbers shown here alone show the extent of misuse of funds in a decade. That is the public loss and the state coffers that been looted by the regime and their lack of will of following and regulating the financial markets. Therefore, the state and institutions does not have the will or capacity to follow the money. This shouldn’t be evident, but it is and not a good look. Peace.
Reference:
Illicit Financial Flows iff – ‘Report of the High Level Panel on Illicit Financial Flows from Africa’
Global Financial Integrity – ‘Illicit Financial Flows from Developing Countries: 2004-2013’ (December 2015)
Sometimes I wish I knew nothing, was clueless, and didn’t have the curiosity or learning ways of finding the information. Finding the sources and looking out for the ones that really said it and not hearsay.
In this world of constant dropping of instant news that are composed in a tabloid fashion suited to the political belief of either the sponsors, owners and the ones that get clicks. The reality and the true sources don’t matters. The Stories getting copied and bought; they don’t get written the newsagents drop them like a grocery-bag and it flees the hurdles before the shade of dark comes in.
The popularity and the spreading on social media makes the marginal papers, the marginal sources silenced as the big-media houses and conglomerates control the discussion and conversations. The minor ones might have a smidge of control and ones in while find a story or picture, even glimpse of reality that the world needed to know. But the houses are silent if there isn’t a buck in it or the righteous owner doesn’t approve it.
It has to be cleared and corrected made in a way that the population can accept it and the ad-revenue can come, either on TV, Online or in the Press. The grandest of them shows loyalty to the ruling regimes and dances with the Multi-National Companies without questions. Therefore the stories are fitted so the Colgate can be sold while the ruling regime can be smug on the front pages; there might not strict rules for censorship! Still the censorship can be made by company just to sell and the integrity doesn’t matter. The digging and questioning cannot happen as long as the journalist has to think about the owners and their wealth; not about generally praising the governments and the giant companies who subsidize their rule.
The Advertisements and Owners control it, instead of the thought of giving the public the intelligence or the follow-up of stories; unless the leaks nearly have to be addressed. I am so tired of these notices and little margins of stories. The PanamaPapers and others are truly remarkable events that made certain papers look into the conspiracies and into the darker sides of the world. Where even the trails of papers found world-leaders, NGOs and Companies that wouldn’t’ like to be associated with fraud, Tax Evasions and other economic forgery. Still, the Apple Company and Amazon don’t care if they rig their LLC in ways in Europe to systematically not pay what they have due on their profits.
Still, the little smidge of barren, the little smidge of proper work or shown as the microwaved cases and the questions for a quick “BREAKING NEWS” as the Senator or MP calls the Network to come to the steps of Court or Parliament to discuss the plenary session on the “Bushwick” Tax; that are for the regulation of growth amongst the bushes. The Bushes that are a problem in the nation; this happens while the media doesn’t question the tenders, the payments and deals made for Oil Drilling and why the Petroleum Commission doesn’t show any signs of transparency towards the companies getting the contracts, the tax they pay on the dollar and the Crude Oil rate for developing the Pipeline. Still, it’s easier just to get a grand quote from the Senator or MP than asking the hard questions towards the Central Government.
The tricks and notion that the Government and Multi-Nationals doesn’t have anything is a lie. They just don’t want us to know as their knowledge and their mechanisms wouldn’t be controlling if we knew. The certain estimate if the Norwegian people for instance the grades that the food-producing companies paid the three great conglomerates (NorgesGruppen, Reitan Gruppen and COOP) for space on the aisles or placements fees directly to the Supermarket Company. Well, this will be kept secret and the agreements are happening in the shadow as the laws and regulations are not steep towards the conglomerates as they are supporting the campaigns of politicians and they doesn’t want to lose their Party funds. They might not say it, but why hasn’t anybody had the clue of curving the power of these companies and their near monopoly on food in the nation?
Well, the media doesn’t care and doesn’t question the powers enough. There certainly exemptions that some tries and somebody does ask questions. But they are wild roses and not common flowers in the gardens as they should be.
Where is these reports and these seldom good ones get lost in the trail of the tabloid and hearsay stories as the click-bait are more commonly shared. The dumbing down and the simplistic words portrayed for the masses. We have to get the media to be more responsible to the viewership, to ask the questions as the dumbing down are happening. As he the journalistic integrity is dying and the media-houses are making easier pieces. Lastly we have to pay for men and woman to dig deep it takes time and doesn’t come for free. The hardcover reports doesn’t come over night, it takes work and persistence. The persistence to find and correct the powers and follow the money takes time. It is a reason if you follow the trail of money, you will find the heart of them. That is because we spend money where our heart is or where our heart desire. The ones that claim otherwise think about how you spend your own monies and cater to your needs. There you have it right?
Just think about it and the words I am writing. It is just a wild approach into darkness. Because their beacons of hope, but very few. I am just a man who writes what I like and discuss what I see fit and digs into the stories I see needed be or find questionable. If not like with Dr. Kizza Besigye and his campaign where I am a hopeful man who wishes for regime change, and for governments that are accountable and transparent. Therefore I support the man and his cause. The same I does with Pastor Evan Mawarire and others who deserves be credited for their cause of freedom, liberation and justice for their citizens. The Citizens that needs and deserves government that represents their will and their institutions to deliver needed services to the people.
We need them to ask questions; we need them to dig deep and not just what the government want to publicise to make them look good. We need the dirty laundry out… and without a doubt without fear and without being censored for the will of profit, but for the will of common good. I know it is a lot to ask in corporate multi-national media-houses and the governments who do what they can to be embedded with them. This says what state we’re in and what we can do about it. Therefore I poke, to question. Not because I have answers, because I don’t; but because I have the will to question and seek for answers. Peace.
We live in a day and age where the content of information is accessible at any time of the day on all kind of formats. It isn’t only pamphlets, posters, newspapers and books. But there are blogs like this; it is digital videos, cable-TV, social-media and all the other ways of gaining information with or without membership pay-walls for the content. In that world of constant ability to gain this, it can either feed the hunger for knowledge or become tiring for the people as the constant newsflashes and breaking news can make your mind boggle and wonder what is really important. Therefore before I continue let see a main definitions of Indifference!
Definitions of the Word:
“lack of interest in or concern about something: an indifferent attitude or feeling” (…)” 1: the quality, state, or fact of being indifferent
2aarchaic: lack of difference or distinction between two or more things b: absence of compulsion to or toward one thing or another” (Meriam Webster Dictionary).
As I tried to explain brief in this time and day, we’re all access to information and ability to download reports, getting brief headlines and watching reports on TV or tablets the clarity of what is important can sometimes not sink in. As we check the normal suspects for the commentary or the capability to get news and become reasonable updated on the matters at hand. Though there are stories lost and we can’t know what happens at every corner of the world, than we are stuck between all screens and behind every tweet dropped every hour of the day. We’ll live in a forever groundhog day and wish that we had comic talent of Bill Murray instead of trying to get up to date with current news.
The fear is with the level of information, the different formats and the ability of entertainment and tabloid news. The simplistic and breaking is taking over for the hardcore policy discussions as the direct terror threats and artists dismissals seems more important than the issues of trading and health care policies. The indifference towards the reasons behind the migrations and the reasons for the crisis in Syria for instance are lost in the battle against terror. The devastating idea for why Tunisia, Libya and other states who was has been under fire since the Arab spring have been lost in tales of Clinton and British death, instead of the iconic and important support to build state institutions for the citizens. In countries that before this we’re built around grand dictators like Ben Ali and Gaddafi. Therefore the indifference to the solutions and the real deal behind the fragile state is worrying.
The worrying indifference to the abysmal understanding of the financial structure of Greece and Italy, as the banks of Italy are in limbo; while the state sales and economic liberation while drowning a debt-burden Greece in more greasy debt as they trying to cope with the level of migrations. We should ask ourselves if the European Union forgot counting people or building swimming-pools for the new rich investor elites that got ability to buy state-resources and key installations like Piraeus port harbor for few cents on the dollar. Therefore the indifference for the swallowing the pride and the reactions this might have for the Greek state.
The indifference for rigging elections and supporting peacekeeping armies on the African continent, while the UN Peacekeepers in C.A.R. are using their power to rape and destroy, not only generate peace, as the UN Mission in Western Sahara is more a luxurious club for diplomates than generating mediation and justice for the people under siege from Morocco. But the world is silent. That the DRC are planning to exile more opposition or even detain them before the General Election for a third term for President Kabila and nobody flick their eyes. While the opposition is under siege in Rwanda, but President Kagame is hailed for the economic recovery as the totalitarian leader are oppressive and using forces in the Kivu’s to still steal resources from the Congo. The world doesn’t care or tries to forget. While the Burundi are still in crisis as the third term of President Nkurunziza is bloody, friends and foes of the President vanish and assassinated, while the Inclusive Dialogue by EAC and AU under former Tanzanian President Mpaka are at a standstill. So the state of affairs is far from beautiful. The indifference to matters is staggering as the knowledge of these actions shouldn’t be forgotten.
I wonder if I feel alone on it, like so many didn’t notice the skirmishes and the recent battles from the militias in Beni, in Democratic Republic of Congo. If it was just the Congolese diaspora who wore the yellow color clothes on Sunday’s to remember the dead and spread awareness of the continuing warfare in the region. As the world have forgotten the violence and want to be rest assure that the cobalt and other resources need in the smartphones are exported to factories far away.
The ignorance and indifference are so big as the cable-news and grand media-houses focus on the click-bait and easy journalism instead of digging deep and having questions to the matters. Only following the money, the money always says how the ethical principles a man or woman has; as a person will only spend money on the things and people that they care about. That is a forgotten one, at one point of time with the PanamaPapers, the big media-houses followed it, but when the leaks when silent the interest dwindled as quickly as the importance of Blackburn in British football, which division are they now in?
We can question if the world really want to care, as the violence, the single handily gun-men going on shooting spree and the endless bloodshed is sad to read about and would make your hard. The continuation of news on the freedom fighters or guerrilla of Niger Delta Avengers would be less interesting as long as they’re a giant force in Boko Haram that are steadily doing abductions, kidnaps and killings in Cameroon and Nigeria.
We can’t be able to be refreshed and know about all issues worldwide, but at least not care more about Pokemon Go, Donald Trump’s latest racist tweet or a Stephen Colbert skit. They might a moment of joy and laugh, but with the possible knowledge of destruction, lose forces and able information, we as people shouldn’t let this just go on without questioning the powers to be.
Because as long as the public is kept in the shadow and not knowing, the people will not be able to see what the government or civil society is doing. That gives leeway to do whatever. So with this in mind the people should be interested and question, wonder and check the resources and ability to gain information on the matters. Either if it by Youtube, library or on the newsstand; the government have it easier with ignorant public sphere and indifference to matters both domestic and international, as they don’t have to take a stand and change policy as long as the people doesn’t act upon the issue. Therefore the knowledge and questioning the businesses, government and NGO’s happens when the citizen’s acts upon what we know. Indifference is only earning the government and the ones that already are in power, the danger for them is if we already knows and can anticipate their moves. Because if so, then they can’t away with thieving, lying and deceit of public will. Indifference of this gives way and is a gift to political sphere. Peace.
The Company in Scandinavia famous for getting George Clooney to be parts of their commercials and being synonymous with the Norwegian National Team of biathlon, making Ole Einar Bjørndalen wearing a Vital hat to the races and competition as a display of one of the main sponsors of the National Team. That is ordinary in sports, and is ordinary in the time we live in. So that a big bank is supporting a National Team is everyday event, but that is not what I will write about and discuss. As I got to read one of the papers in the Panama Papers leak. Here it is and hope you can see how DNB Nor ASA used the opportunities for meager taxation and higher earning for their subsidiary.
Before you continue her is a classy ad from the company:
Now we will see how the Norwegian Company can also be a little greedy and trying to avoid taxes in Norway, but still earning the profits and having accounts, but using the PriceWaterCoopers (PWC) offer for a Shell Company in Luxemburg to save taxes and still keep the funds in safety in Luxemburg. That is the grand DNB Nor who is the largest bank group in Norway.
Here is how they do it, and it is epic ways of using the shell-companies to avoid Norwegian tax regime and use a Corporate Fund that is a S.A. “Societe Anonyme” as financial company in Luxemburg to simply benefit from the specific tax status for a company in Luxemburg instead of the Norwegian one. Let me take you for a ride!
What is the Carlson Fund Management Company S.A.:
“Carlson is a Luxembourg resident company incorporated on August 14, 1990 as a limited company (“Societe Anonyme”) in order to develop the German and other European markets” (…) “Carlson is a company of DnB Nor group (hereafter the “Group”). The Group is Norway’s largest financial services group with total combined assets of NOK 1,834 billion. It includes strong brands such as DnB NOR, Vital, Nordlandsbanken, Cresco, Postbank.en, DnB NORD and Carlson” (…)”Carlson is part of the life and asset management branch of activities of the Group, DnB NOR Asset Management. It is Norway’s largest fund manager and has a leading position within discretionary asset management for institutional clients in Norway and Sweden” (…)”Until July 28, 2006, the purpose of Carlson was the creation, management and administration of a unique fund, Carlson Fund, created in Luxembourg on August 31, 1990. In this respect, based on the Luxembourg law on UCis, Carlson benefited from a specific tax status exempting the company from Luxembourg corporate income tax, municipal business tax and net wealth tax”.
You think that is saga in the making just see what more they did to secure lesser tax in Norway and close to none in Luxemburg, because corporate greed is what makes the world run like Ussain Bolt!
“By resolution of the Extraordinary General Meeting (“EGM”) held on July 28, 2006, Carlson has amended its by-laws in order to comply with the law of December 20, 2002 transposing the UCITS III Directive 85/611/EEC into Luxembourg law. Since the EGM, Carlson has been responsible for the management and administration of several investment funds. Carlson currently manages a portfolio of funds under 3 fund umbrellas: Carlson Fund, DnB NOR Fund and more recently DnB NOR Part II Fund since February l, 2008 (hereafter the “Funds”)” (…) “As from the date of the EGM (i.e. July 28, 2006), Carlson became subject to an unlimited tax liability and is considered as a newly incorporated entity for tax purposes”.
You think that is bad and telling how the Carlson entity of Luxemburg, which funds and fueling money from the DNB Nor and their subsidies and banks in Norway. As he Tax is high here for any profitable business, this kind of transaction and order clears lots of funds from the Company and banks, which gives higher profits, because of less tax as they follows through consultation to follow the exemptions laws in the tax-haven. Here we go!
How do they secure the tax-exemption with the laws in Luxemburg?
“Based on article 35 (4) of the Luxembourg Income Tax Law (“LITL”), when a company becomes taxable, all its assets and liabilities have to be valuated, at the time of the conversion, at their fair market value The assets and liabilities concerned are those “contributed” to the fully taxable entity, including intangible assets (article 59 (2) LITL)” (…)”the tax balance sheet has to take into account all the assets and liabilities of Carlson (i.e. the whole assets and liabilities whose, by nature, intend to serve the activity of the company2) including the valuation of the management contract. The administrative doctrine precises that is assimilated as an asset all the potential assets that can be exploited in the context of the activity of the company and with an individual economic value” (…)”Carlson has to revalue its capital in its opening tax balance sheet. The revalued capital includes the share capital of the formerly tax exempt company, the reserves accumulated by Carlson until the moment of the conversion, as well as the revaluation reserves resulting from the step-up at the moment of the conversion. The revalued capital is treated as “fiscal capital” in the hands of Carlson from a tax point of view. Any repayment (of part) of this “capital” to Carlson’s shareholders will therefore not be subject to withholding tax in line with the provisions of article 97 (3) b LITL”.
Now we have seen how the DNB Nord have put a S.A. Society Anonyme with the Carlson Funds to drop money into the Tax-Haven of Luxemburg as the DNB thinks the suits of Luxemburg to perfection and wondered if Barney Stinson bought suits made for Luxemburg.
DNB set up the Society Anonyme is set up with a new “EMG” to get unlimited tax-liability in Luxemburg. So the advice made the funds from the company under the Carlson from the time of the board-meeting by law of the 28. July 2006. The continued thing they did was to take their assets and monies fueled into the Carlson Funds, so the liabilities together with all of contracted value and management in the tax-balance sheet. So there fueling of moneys into the Fund is also fiscal capital and because of the status of the S.A. hide more in the secret company there.
Then the control of Carlson Funds is by all means controlled by DNB Nord as written here:
“As an example, a major part of the support activities (e.g. accounting) is done in close collaboration with the members of the Group located in Sweden/Norway. Moreover, the members of the team managing Carlson in Luxembourg are all senior officers originated from the Group. Consequently, the distribution of the Funds in Luxembourg is mainly performed thanks to the support of the Group”.
Here is what the group is supposed to pay in tax:
“Taking into account the total 2006 and 2007 value of the business compared to the total 2006 and 2007 annual profit before tax, Carlson will pay an annual and arm’s length remuneration in accordance with articles 56 and 164 (3) LITL to the Group for its support representing 65,92% of its annual profit before tax” (…) “Carlson will benefit from such retrocession of fees over a period of 10 years. As the taxable activity of the Company started in 2006, we propose to recognize such retrocession as from August I, 2006 until the financial year 2016” (…)”The computation of the percentage of notional retrocession of fees will be subject to a supervision period of 4 years (2006-2010). In case of significant/major changes in the business in Luxembourg, Carlson commits itself to inform the Luxembourg tax authorities of any significant changes that would modify its business and/or its tax position in order to agree on the more appropriate tax treatment”.
If you wonder what retrocession means that is planned underwritings of the earnings of the company. Underwritings or retrocession is usually a volunteer act of a company to return property or ceding property, though usually by request and not by forced transaction. Also the underwriting is also done to diversifying assets by consolidating them amongst the stakeholders. That means the last one the percentage of the company which is 65 % of the profits of DNB NORD’s Carlson Funds will dived 65% of the funds to the stakeholders of the company. Initially meaning that the Stakeholders or the Owners of the DNB NORD and that before any tax in Luxemburg, which is beautiful business model for the Stakeholders and for the ones owning DNB, and by literal controlling Carlos Funds.
The Company found another way to dodge a little more tax:
“Net Wealth Tax:As no intangible asset is recognized in the tax balance sheet of the Company, there is no increase of the unitary value of Carlson for net wealth tax purposes”.
This is initially saying that since they have not written any assets of value when they started to operate, therefore they does not have assets or monies worth to be classified for the Wealth Tax Purposes in Luxemburg. Here was yet another way of using the loopholes in Luxemburg to get even less taxation and a favorable way of using the tax-system there.
This article in the middle of the charter of Carlson Funds says the truth of the company:
“The purpose of the corporation is the creation, administration and management of one or several Luxembourg and/or foreign collective investment funds in transferable securities authorized according to the Directive 85/611/EEC, as amended (”UCITS”) and of other Luxembourg and foreign collective investment funds not covered by trus Directive (“UCI”) (all together the “Funds”) on behalf of their unitholders or shareholders in accordance with the provisions of chapter 13 of the Luxembow-g law of December 20, 2002 on undertakings for collective investment, as it may be amended from time to time (the “2002 Law”) , and the issue of certificates or statements of confirmation evidencing undivided co-ownership interests in such Funds. The corporation shall manage any activities connected with the management, administration and promotion of the Funds. It may on behalf of the Funds, enter into any contracts, proceed to any registrations and transfers in its nam~ or jn third parties’ names in the register of shares or debentures of any Luxembourg or foreign companies, and exercise on behalf of the Funds and the holders of certificates of the Funds, all rights and privileges, especially all voting rights attached to the securities constituting assets of the Funds. The foregoing powers shall not be considered as exhaustive, but only as declaratory”.
This here says enough of the practices of the Norwegian Banking group of DNB Nor or DNB Nord ASA had a subsidiary for recess their tax-operation and use the lucrative opportunities for keeping the profit without having issues with the Tax-regime in Norway. As the Norwegian rules and tax-regulation without studying them is stricter and has to be stricter than this. Because the end of the Tax contract with Luxemburg disclose the information where they are planning not to pay for their “Net Wealth Tax Due”. So even if the funds grow massively and the monies invested in the Carlson Funds, the opportunity to underwrite 65 % before the tax on its profit and that is possible with the “underwriting” method. In that sense the taxation of the will always is 10% on very little part of the funds, as the stakeholders can theatrically take 65 Euros on the 100 euros. Leave behind 35 Euros of it profit and pay 3, 5 Euro on the 100 Euros of Profit, that is a beautiful operations. If it wasn’t for the underwriting of the revenue then the company would have by the standard tax of Luxemburg paid 10 Euros of tax. 10 Euros is not much of a profit of 100 Euros, but still vastly more than 3, 5 Euros, the difference by quick calculation is 6, 5 euros. That is nearly a price of a Big-Mac Combo-menu that cost around 8 Euros in Luxemburg.
That is because of the technic of underwriting and sharing that with the shareholders and stakeholders of the Carlos Funds S.A. in Luxemburg which is their subsidiary. As written so nicely to the Luxemburg Department of Tax Collection in 2nd July 2008:
“on behalf of our client Carlson Fund Management Company S.A. (hereafter also referred to as “Carlson”), we respectfully request you to confirm, in writing, the content of this letter as to the Luxembourg tax treatment applicable to the situation described herein”.
That the Carlson was supposed to get the reasonable Tax Treatment for the company so there was a hashed plan from the get-go together with the Company of PriceWaterCooper. The plan was made an acted upon. This would not been possible if the DNB Nor did not use the guidance and setting up the charter after the laws there and follow the guidelines of the company setting it up for making sure of having less tax.
As explained with the 100 Euros scenario. The certainty is not any excuse from the DNB Nor can tell away. As they explained in 2016 to the Norwegian Press:
“No, DNB Luxemburg does not help the costumers to avoid tax. The Advisors function as discussion and talking-partners when it comes to financial questions, which offers legal and legitimate tax-plan for the costumers who live abroad. It could for example be about advice about financial-solution, cross-border transactions, complicated inheritance-regulation and other taxing environment that would be different from the ones who are living in Norway” (…)”DNB does not operate in Luxemburg because of taxation (Foss, 2016).
Well, I have already explained there operation and how they get to pay as little tax as possible through their operation. So DNB Nor had or still have the Carlson Fund Management Company S.A. in Luxemburg to save taxes and earn more monies in their operation and company there. Something they would be able to do in Norway or under Norwegian taxing regulation. Peace.
Reference:
MF I/ECCi/ AEGN/C21108001 M-PEWR – “Carlson Fund Management Company S.A. – Identification tax number: 2006 2240 378- Recognition of a license fee for tax purposes” (02.07.2008) – PriceWaterCooper (PWC)
For those who have been surprised by the recent allegation and findings in the #Panama Papers that incites lots of politicians, the general elites and businessmen connected close to the governments. The money always talks, the money always moves and by any means possible.
For the wealthy and close connected they have the ability to forge networks and find businesses that earns coins on helping to move that money. But that is not for the ordinary people, as we pay a fortune to use RIA or Western Union to move between usually loved ones. But the Panama Papers are for whole other ordeal.
This here is for Tax Aviation’s and getting rid of extra burdens on the solid amount money they have gained. The persons and companies are set-up Shell-Companies to stack up money in British Virgin Island (BVI), Panama or Luxemburg. As this places doesn’t have that many inhabitance or sheep to earn money on, they earn tiny percentage on being “big-banks” for all kind of operations, while securing that the companies and persons involved can keep it discreet and silence. Until cover-ups like the recent ones shows the true color of the amount of money, that are dished away. The money that are stashed-away is millions upon millions of American Dollars; dipped away in a treasury chests that most economies would dream of having in circulation!
That should not be surprising as all of well-known government leaders are setting up and making it possible to have sophisticated economic systems that cross-borders for the benefit of trade; while these are used to ship the money from the places that have initially no taxes and programs that made up to build societies. This is also the places where they can have it without any concern, except some extra sunshine and a family resort at the beach, though I would not consider that in Luxemburg, unless suits and gas-stations are your thing.
The business-men and government officials, even relatives usually walks around with that without problems for decades as the banks, and the legal advocates set-up this fixed businesses to secure the fueling of their money. The worst thing is the loopholes and the ways that this decisive methods to undermine the local public to create and secure more funds for already wealthy clients. Where the bank as HSBC and lawyers of Mossack Fonseca divided fees to pocket the money that the client needed to send away from the shores and country-sides; where the money was raised and earned. While getting away from local agony of having fortunes and paying taxes on the high-incomes earned to the local communities.
If you we’re shocked of the values and the persons that was involved in the scandal of late, I wasn’t as the government officials, presidents sons and daughters; kin and other close connections have always gained extra through the cronyism or nepotism have been a thing since the Roman Empire, and does not stop any time soon. That the President Museveni of Uganda owns businesses and would have dashed a fortune for his grandchildren in an tax-haven through multiplied shell-companies. The same would not also be surprising on the Kenyan President Kenyatta who recently brought Sameer Diary and Livestock Limited who sells ‘Fresh Diary’ in Uganda through his company Brookeside. Surely his kins and family have some money abroad to secure in dire times might come. The same is certainly with President Kagame, who even been seen during the scandal that RPF-Elite men have been insiders in the scandal, as President Kagame have control and ease over it; surely he would skim over the top and gain some extra funds as the Executive. Similar is it in Democratic Republic of Congo where President Kabila sister is central profile in the scandal and shows how the monies and funds appear in tax-havens as she owns businesses and also the centralized economy around nepotistic and cronyism. Something that should not be shocking for anyone.
What this scandal shows is the amounts and estimates, this is through to major companies who serves this clients that are close by this totalitarian and big-men leaders who have close connected with central industries as they have to be granted and get contracts with government to drill oil, mining or even gain markets in the countries. With that power comes also embezzlement, kick-backs and percentage of the top that get skimmed through the advanced economic products that the blue-collar lawyers and bankers offers; they do that legally, but in a moral grey area as this thieving of government controlled funds in the name of the beneficiary or the shell-company in discreet secrecy. It’s not only dictators and their wives who are into it, I am sure if it wasn’t for the failed ‘Wonga Coup’ Mark Thatcher would still be up to game as the son-fallen from grace and proud family tradition; as even David Cameroon have been put into the mix. There is no shortfall when it comes to greed, and corporate greed never stops.
As the world leaders tries the best to hide their businesses and ownership through shell-companies and strawmen, or getting a cousin to run the business kind of like what Trump does to his son, just a little more subtle.
The governments are taking the sides of happy uncles as they all tries to open trades with tax-havens to keep businesses in their countries. The Companies who in many countries are seen as“Legal Person”can own land, own other businesses and be sued. Certainly with that power as stakeholders and shareholders does not care about other things than the bottom-line, they want to sell or sell enough services so that their earning a profit, by any means. That is why big businesses have been taken for tax-evasion in the UK this was Amazon and other online-retailers as they we’re officially legal unit in a tax-haven and not in the United Kingdom, though the products bought on Amazon was sent from a warehouse in UK, and sent to UK houses. The transaction between costumer who got the book from Amazon payed to a British account, but before the cash kissed the taxation to the Government of UK, it was sent to multiply Amazon shell-companies before ending at a Tax-haven. So that the United Kingdom get only pennies in tax compared to the Pound Sterling the UK state was supposed to earn from the Amazon LLC. That is just an example, but still important as a precise maneuvers the companies and international companies do, so they does not pay full-taxes or truthfully through sophisticated economic programs and revisions get the monies through foreign banks and tax-havens with help of legal teams in companies similar to Mossack Fonseca.
How to set up shop:
The LLC and Shell Companies will be used in market strategies as ghost straw-men for the owners sending monies through networks of intricate syndicates and money-laundering operations; That make Uncle Scrooge or Scrooge McDuck wishing he was a real person and not a cartoon character made up by Carl Barks in 1952; instead he is owning a Oil Company drilling oil in either Kazakhstan, Nigeria or North Dakota. Where he got the proceedings through UBS AG or HBSC; where the profit gets through manufactured holding companies and sent to BVI or Guernsey; where the McDuck Oil Company has headquarter, by official paperwork. That paperwork is written and made by lawful actions through Mossack Fonseca; while most of the Blue-Collar men are working in the unofficial Headquarters in the heart in the City of London or New York. But their taxing is little or near none there, because of McDonald Oil is fixed in Guernsey; Where they only have a Post-Box at the island; which by my reckoning would forward the mail to London or New York as the employees would actually be there.
This is a way of getting the bottom-line and the more of the ends directly to the stakeholders and owners of these companies tries to advance with this opportunities, that we the ordinary citizen, commoner, person or fellow human being would not be offered, since we don’t have the money to fix this or hire these men to forward our money, as we need the cash we have to get a home rent or buy, get food on the plate, pay electricity, airtime, taxes and then trying to get a chocolate bar once in a while. There is where we are. The once who was surprised about these papers have had too much faith in their rich, the elites and the once who has fortunes. They do not want to share that fortune that they have earned on our governments and our consumption; while trying to avoid giving something back to society, and giving the government more funds to develop the society the rich are doing business in. Peace.
This here is prove the numbers, this here does not prove who have the major accounts; on the surface as he page shows numbers, but not the accounts or who’s name that is behind the coded accounts from the HSBC Swiss Bank leak. This here proves that standards and values of how much money that leaves the countries and get into secret accounts in Switzerland.
This proves the values and the estimated amount of money in the accounts. In this here that I found on the page is very little direct as I don’t have somebody on the insides, that gives the documents. Therefore here is the raw-numbers and estimated that have been sent from East Africa. In this article I just have some persons who are connected, but not many of the holders of the accounts from the leak.
Burundi:
“30 client accounts opened between 1988 and 2006 and linked to 32 bank accounts. 14 clients are associated with Burundi. 21% have a Burundian passport or nationality. The total estimated values in the accounts are $30.2M. The maximum amount of money associated with a client connected to Burundi was $8.3M” (ICIJ.com, 2016).
Burundi Country Profile – Aziza Kulsum Gulamali:
“Listed as living in Belgium, Kulsum was linked to three HSBC numbered client accounts opened between 1990 and 1997. One account –15208BAMA– linked to two bank accounts that together held as much as $3.26 million in 2006/2007, was later blocked for unspecified compliance reasons. She showed up as a joint account holder of that numbered client account. The other two accounts were closed in 1995 and 2000” (ICIJ.com, 2016).
Democratic Republic of Congo:
“182 clients are associated with DR Congo. 2% have a Congolese (Kinshasa) passport or nationality. 245 client accounts opened between 1984 and 2006 and linked to 299 bank accounts. The total estimated values in the accounts are $179.8M. The maximum amount of money associated with a client connected to DR Congo was $60.3M” (ICIJ.com, 2016).
DRC Country Profile – Jaynet Désirée Kabila Kyungu:
“Jaynet Désirée Kabila Kyungu is the twin sister of Joseph Kabila, the president of the Democratic Republic of the Congo. Famed for secrecy and meticulousness, she was elected to parliament in November 2011 and took office in February 2012. Kabila is the president of the Laurent Desire Kabila Foundation, named after her father, and owner of Digital Congo, a television, Internet and radio conglomerate. In 2015, Jeune Afrique reported that Kabila had become “the most influential person in the president’s entourage.” (…)”Keratsu Holding Limited was incorporated in Niue on June 19, 2001, a few months after Kabila’s brother became president of the Democratic Republic of the Congo. Jaynet Désirée Kabila Kyungu appeared as co-director with Congolese businessman Kalume Nyembwe Feruzi. The DRC Company Keratsu Holding Ltd has owned stakes in one of the DRC’s major mobile phone operators” (Eagle.co.ug, 2016).
Ethiopia:
“29 clients are associated with Ethiopia. 24% have a Ethiopian passport or nationality. 31 client accounts opened between 1986 and 2004 and linked to 55 bank accounts. The total estimated values in the accounts are $10M. The maximum amount of money associated with a client connected to Ethiopia was $2M” (ICIJ.com, 2016).
Eritrea:
“32 clients are associated with Eritrea. 28% have a Eritrean passport or nationality. 24 client accounts opened between 1981 and 2006 and linked to 39 bank accounts. The total estimated values in the accounts are $699.6M. The maximum amount of money associated with a client connected to Eritrea was $695.2M” (ICIJ.com, 2016).
Kenya:
“The county or people of Kenyan nationality have 1,093 bank accounts, which with 463 client accounts opened between 1975 and 2006 and linked to 1,093 bank accounts. 742 clients are associated with Kenya. 32% have a Kenyan passport or nationality. The total estimated values in the accounts are $559.8M. The maximum amount of money associated with a client connected to Kenya was $35.8M” (ICIJ.com, 2016).
Kenyan Country Profile – Johnson Nduya Muthama:
“HSBC files recorded Muthama’s name in connection with the client account “ROCKLAND96”, which was set up in 1996 and closed in 2000. Muthama was also linked to the numbered client account “20443NM” over the same period. Bank files listed eight of his relatives – named Nduya Muthama – also linked to the numbered account. The leaked files do not specify the exact role that he had in relation to the accounts” (ICIJ.com, 2016).
Kenyan Country Profile No.2 – Lady Justice Rawal:
“She and her husband were listed as directors at Forrell Real Estate Inc from 2001 to 2007 and Rocklane Properties Ltd from 2001 to 2003, which were notably active after her appointment to the Judiciary in 2000. She was also a director and shareholder at Ubique Services Ltd in 1994 and shareholder at Highworth Management Services in 1995. All four firms were registered in the British Virgin Islands (BVI), a notorious tax haven” (…)”The Kenyan Constitution makes it illegal for judges, being state officers, to open and operate offshore bank accounts. Chapter Six, Article 76 (2) (a) states: “A State officer shall not maintain a bank account outside Kenya except in accordance with an Act of Parliament” (Kubania, 2016).
Rwanda Country Profile – Emmanuel Ndahiro:
“”Emmanuel Ndahiro became a director of British Virgin Islands company Debden Investments Limited in September 1998, the same year in which Ndahiro regularly appeared in international news as a spokesman of the Rwandan army. Debden reportedly owned a jet aircraft. At the time of his appointment, Ndahiro’s listed address was a building in a commercial section of a West London neighborhood. Hatari Sekoko, a former soldier with the Rwandan Patriotic Front and now a major business executive, was the company’s owner. The company was deactivated in 2010.” (ICIJ.com, 2016)
Somalia:
“7 clients are associated with Somalia. 29% have a Somali passport or nationality. 10 client accounts opened between 1990 and 2003 and linked to 22 bank accounts. The total estimated values in the accounts are $15.5M. The maximum amount of money associated with a client connected to Somalia was $12.2M” (ICIJ.com, 2016).
Tanzania:
“99 clients are associated with Tanzania. 20% have a Tanzanian passport or nationality. 91 client accounts opened between 1982 and 2006 and linked to 286 bank accounts. The total estimated values in the accounts are $114M. The maximum amount of money associated with a client connected to Tanzania was $20.8M” (ICIJ.com, 2016).
Uganda:
“83 client accounts opened between 1972 and 2006 and linked to 212 bank accounts. There is now as the leak where happening 57 clients with Ugandan Passports or Nationality. The total estimate to be in value in the accounts is $89,3M. The maximum amount of money associated with a client connected to Uganda was $8.8M” (ICIJ.com, 2016).
Afterthought:
The numbers speak for themselves and the amount of money is staggering, this is most likely through one of giant Swiss Banks of the HSBC where the money have gone through and filtered in secret accounts. This here proves the levels of accountability and how the rich and elites filters away money from the country where they are earning money to have less tax or not being taxed in the under the regime some of them works for or is close by.
There lacking of accountability and senseless stealing of funds in between the different countries, as the scandals are rocking often. As state house and other governmental institutions missing funds before the fiscal years over, or lacking the economy to pay the salaries to their civil servants. Secondly is the free-based economy that gives edges and corporate greed who can strive without beneficial taxation and gives way for the movement of funds from the country the business is in; into a country that are a Tax-Paradise where the ones with the account can be secret and not pay what they are expected. If not it can be away of embezzling the funds or white-wash the funds as shell-companies are holders for the monies, while the owners tries to find a great use for the funds. Peace.
MinBane 