Former Harvard Money Manager Is Launching a Digital-Currency Hedge Fund
bloomberg.com
bloomberg.com
Probably because of the beaches, pina coladas and what not, riteguise?
Of course, it should have been taxed when it was earned by investors. And it will be taxed again when investors receive and domesticate any dividends. That part is the dodgy tax dodging issue. Not the issue of where the fund is based.
> Capital is very mobile and not there's usually not a strong reason to keep it in high tax jurisdictions if it's possible to move it out.
They are exploiting a loop hole.
Google & Apple, etc play the same jurisdictional tricks, as do pretty much all multinational firms.
Why should it be the employees getting taxed and not the corporation? I might get taxed more than twice. Federal income tax, state income tax, sales tax, capital income tax, why should a corporation get a pass? I also don't think that it's getting taxed twice as they are different taxes.
> Google & Apple, etc play the same jurisdictional tricks, as do pretty much all multinational firms.
Why are you assuming that I condone that?
I think you are confusing the fund with the mangement company.
An asset manager is a company that manages assets for investors and charges fees. They have employees and offices and profits and pay taxes. Fidelity's parent for example is a US based LLC.
An asset manger like this runs many funds on behalf of investors. For each investment fund, they setup a fund to legally ring fence the assets for that particular fund, which they manage on behalf of the fund's investors. This protects the investors and maintains separations of the assets. If the management company went bankrupt, the funds themselves are unaffected (aside from needing a new manager).
The fund itself has no employees, it's just a method of legally separating out those assets.
I would also point out that this particular case has nothing to do with the US. The manager in question is not a US citizen or resident and I would be extremely surprised if the management company was being setup there.
The question is: why is the US entitled to these taxes, such that avoiding them becomes unethical?
False equivalence. You can deduce anything that's used to generate the profit. This makes sense.
> The question is: why is the US entitled to these taxes, such that avoiding them becomes unethical?
The answer to this question is the same as the answer to the question "why is the US entitled to taxes".
Pretty sure you wouldn't consider that one one that makes sense.
Plenty of deductions exist for a reason, and generating profits isn't always one of them.
Various reasons: 1) to segregate assets, 2) because certain regulators will apply restrictions on certain security actions (one example: it seems the Belgian regulator has barred investors from borrowing against their stock holdings for most purposes, but this is possible with a US broker, even for Belgians, without restriction), 3) to stop double taxation which would be bad for global investment (e.g. some pension funds are tax exempt under local law), and 4) because investor A living in country B doesn't want to pay taxes in country C, he wants to pay taxes in country B under the laws he knows and understands.
Imagine living in Greece, and then having to figure out the entire tax system of Spain. In a foreign language. It would probably be too complex to bother (and thus you wouldn't invest) or it would be an expensive undertaking (lawyers etc) eating into your returns.
Investing in a CaymanCo is generally easy -- you don't pay tax at the entity level, you pay tax in your personal entity. Clean, easy, and you can ride off on your boat into the sunset.
The investors in the fund are obliged to pay taxes on their income/gains in their relevant taxation jurisdiction, which will be the US for US investors and elsewhere for non-US investors.
I can also imagine that the fund has some US legal protection (don't quote me on that).
> The investors in the fund are obliged to pay taxes on their income/gains in their relevant taxation jurisdiction, which will be the US for US investors and elsewhere for non-US investors.
So why is the fund getting a pass?
Fine. When will you start paying taxes to Greece and Italy for essentially inventing the core civilizational structure the West is based on?
Haha, the EU is paying them more than enough already.
So, have you been paying your taxes to Germany, Canada, the UK, and the rest of the world?
You said the fund should pay taxes to the US because it "indirectly benefits from the US social structure".
By that logic, you should be paying taxes to all the countries whose "social structure" you indirectly benefit from.
Why? As far as I can see, two people who are neither US citizens nor US residents are setting up a Cayman fund. What exactly does this have to do with the US?
The recent SEC decision on Ethereum ICO's made it clear at least the legal part of the social structure still applies. The normal tax setup isn't really setup to do this though as the same also applies to all the other countries the fund would want to sell to. A tax on the fund transactions with citizens of each country would probably be a better way to pay for the SEC and other regulatory and legal services in each country.
This is effectively how things already work. Sale of investment products is generally highly regulated in most countries by a domestic regulator and most of those also implement transaction taxes[1].
In effect, the taxation to fund regulation is done at the destination, not the source, which makes sense given that the regulator is typically protecting the investors located in the same jurisdiction.
In the US for example (since this discussion seems to be about the US despite the fact that fund being discussed appears to have nothing to do with the US):
Currently, the US imposes a $0.0042 round-trip transaction tax on security futures transactions and $21.80 per million dollars for securities transactions.[63] The tax, known as Section 31 fee, is used to support the operation costs of the Securities and Exchange Commission (SEC)"
You seem to have a very US-centered view of the world. To those of us who don't live in the US, it comes across as bizarre.
"Takes advantage of the US social structure" is so vague as to be practically meaningless, and could be extended to almost any developed economy.
Not all of us owe Uncle Sam, you know.
If the gains in lower taxes are done by playing states off each other (see Google in Ireland) or the regulatory gains are done by allowing dirtier production of the same goods elsewhere (usual China vs the West discussion) then for the vast majority of tax payers it is a loss. The taxes and regulations that apply to them individually don't change while their states have less tax revenue to provide services and the environment they live in is worse off.
>If there were a global territorial monopoly on the production of security and rule of law, you would likely find yourself with a lower quality of life.
I'd bet the opposite would be true. All those lawyers and accountants that Google employs to shift their tax burden between countries could be reallocated to doing something productive. The pressure to lower taxes is already high enough within a single state that the loss in pressure from lack of competition between states would probably be irrelevant.
Awesome I am Automatic made dead
I'm not advocating capital controls, but it doesn't make sense for us to allow people that by all means actually live and work in the US to set up a business elsewhere to avoid taxes. Because if tax havens were not allowed to exist, they would still set up in the US/UK/whatever, but would actually pay fair amounts of taxes.
Generally, if you want to bring that back, you will at least have to pay some sort of capital gains or dividend tax on that.
Second, pure tax havens (such as Jersey and the Cayman Islands) are one thing. But pretty much every developed nation has special tax incentives that exist in their tax code to attract investment. And it is obvious why they do it.
If we use Luxembourg as an example, which is generally a favourable holding and fund location, what can they offer? They are a small country with no natural resources. Smaller nations need to live off of intellectual capacity, meaning: outsmarting others.
There are various approaches (Singapore, Channel Islands, Luxembourg) to that, but ultimately, if you want to attract investment and tax revenue, offering an attracting tax system seems like a great way to do it.
I don't see the world introducing a globalised 20% corporate tax rate any time soon, for example.
Putting the fund in the islands just avoids having to deal with all of the work of getting exemptions for the money going to the foreign investors.
I suggest that you spend some time actually researching why these things are done before commenting based on a preconceived notion learned from popular media.
The fund being in the Cayman islands in it's own isn't a tax loophole.
He already wrote that (that's why the sarcasm).
Can't be dealing with all those pesky "laws"!
Every hedge fund is registered in some obscure offshore location. Don't confuse that with where it's managed from.
The reason is tax related. The investors don't want a tax bill dependent on some complicated local regime, and you want investors from different countries. That doesn't mean there's never any tax paid, it the company that "advises" or manages the fund will still be based in a well known financial centre like NYC or London, and will pay all the same corporate and employment related taxes that any other firm pays. The 2/20 fee goes to this management firm. And when the investors bring their money back into their jurisdiction, they pay according to whatever the capital gains regime that's relevant.
The fund vehicle is in the Caymans / Bermuda / IoM etc.
https://www.quora.com/How-are-hedge-funds-structured-so-that...
https://panamapapers.icij.org/
http://www.alternet.org/story/150904/7_ways_hedge_funds_lie%...
There's nothing in your links that contributes to this discussion.
I recall a few years ago how people talked about Harvard fund mgmt in reverent tones as if they somehow were simply smarter and better than everyone else. That caused some dissonance with me because a former boss's boss was someone who Harvard Endowment hired, and in my experience he was definitely not smarter and better trader than everyone else.
So I guess over time they find it as difficult to make returns as the rest of us do.
>>If you will invest in a hedge fund, or require maximum transparency and regulatory agencies, I usually recommend Cayman Islands or Luxembourg.<<
edit: the point of the post, is more or less answer to my own question. Why cayman instead of Panama or some other place. May be I am not clear about it in the post.
[0] https://twitter.com/aridavidpaul?lang=en
Edit:
Here are 15 more hedge funds for the klutz. Please old media: keep up! Would quite like NEWs.
https://www.forbes.com/sites/laurashin/2017/07/12/crypto-boo...
Edit2: dpflan, I think I'm being throttled b/c of my VPN. Here's how I see it;
Personally, I think bitcoins will still increase, but the bet is more symmetrical. There are other crypto assets which are asymmetrical bets (lose 1x, gain 100x). I focus on the latter.
What do others think about Bitcoin's value changes and BTC as an investment? (Or the missed opportunity of investing in fidget spinners :)!)
I would consider it a gamble and not an investment. Some call it a new asset class that isn't correlated to other assets, which is valued by portfolio managers. Its high risk high reward, if you understand why it has value and want exposure to the risk, put in enough that you are fine losing. This is still a grand social experiment and still could plummet in price at ANY time.The government regulatory clarification we have seen over the past few years has lessened the risk of a government crackdown at least.
This is not financial advice.
Such as? Eth isn't going to increase 100x in any meaningful amount of time at it's current price.
As it's private it could get banned -- which could set in back in the short-term. In the long-term, I think it's going to be money (or something like it). It could be a rocky ride!
Edit: A rocky ride with consequences (It's not a fairground ride). I want to point that out.
Edit2: You could sell your investment, obviously. I talking about if you're in for the duration.
https://blockchain.works-hub.com/blog/XRP-We-Will-Persuade-t...
Oh, no he seems to be buying crypto assets; which have value because they're decentralised. Silly me. I was confused by the author being confused.
Edit: if you're downvoting me for this comment then you don't know what you're talking about. Happy to debate!
Edit2: seriously, there's a distinction to be made. One is a censorship resist asset (which is why the trade-off of greater resources is made) & the other isn't.
Edit3: explain to me why that isn't true & I'll change my position!
For any given use case I believe the solution could be done more efficiently with traditional tech. What traditional tech doesn't do is provide resistance to censorship. Governments can take them down. Currencies, social networks, whatever. The raison d'être of crypto is to provide this resilience. That's what the extra resources go to. Crypto is valuable because it's a more resilience-whatever. E.g., Bitcoin is a more resilient money (Monero is better b/c it's private). Assets which can be taken have less value. Platforms which require permission have less innovation. That's the quick answer.
Well, it's just that it's fairly obvious what is meant by the headline given the events of the past couple of years and your comment doesn't add anything.
Edit: & it makes a difference b/c one implies government control & the other control by the individual. Individual freedom. Privacy. Saftey from persecution. Allowing freedom of speech -- without the risk of being defunded by the government.
Edit2: Thank you for your comment.
Also, Paypal is not a currency at all, it's just a bank and payments provider.
I believe that's correct. Is the fund investing in non-crypto assets? 'Digital' implies the category 'digital' rather than 'crypto'. It's a subtle difference, but important for when government/gov agencies frame the tech.
My 'Edit2' of the root comment is incorrect.
> Also, Paypal is not a currency at all, it's just a bank and payments provider.
I believe PayPal is seen as having an electronic currency:
https://en.wikipedia.org/wiki/Digital_currency#Centralized_s...
Edit: I'll amend further. The headline is definitionally correct. It's not as precise as I would like since it doesn't convey exactly what the fund is investing in. I think being precise in this matter is important b/c the word use is used to frame the tech as yet-another-digital-thing vs a censorship resistance technology (allowing privacy in an age of increased surveillance & free speech where centralised companies have become the censors). The word 'crypto' has a certain connotation -- which is why I think the SEC won't use it. Or other gov agencies refer to it as 'so-called' crypto currency.
It's also why Coinbase says 'digital currency', I think. There are ppl who try & force the matter when they're being interviewed. Well, I'm forcing the matter back.
---
Edit2 (reply to icebraining):
icebraining, I'm being throttled. Here's my reply,
> A random line in Wikipedia does not make for good evidence about how something is seen.
At least I supplied evidence, vs your naked claim.
> Bloomberg is writing for a general business audience, using a more generic term is normal
Good journalists use 'crypto'. Here's an example from Forbes (general business audience?),
https://www.forbes.com/sites/laurashin/2017/08/10/coinbase-b...
> doesn't imply anything.
I think it does. I've explained above in an edit. You seem to be making a lot of statements without backing anything up with reason.
It only implies that for people knowledgeable enough to clear know what "cryptocurrencies" are. Bloomberg is writing for a general business audience, using a more generic term is normal, and doesn't imply anything.
I believe PayPal is seen as having an electronic currency:
A random line in Wikipedia does not make for good evidence about how something is seen. Especially as the line says they "will sell" their currency, which is not something Paypal does currently.
Paypal is a bank, they hold money in existing currencies, they don't emit their own.
Digital currency is an all encompassing term for any money that solely exists electronically. Example: Money deposited into a bank account is digital currency. Investing into digital currency can mean a lot of different things. A few include, taking positions on exchange rates (such as the conversion of USD to EUR), taking a position on lending yields, or even simply a position on inflation. An economically-proficient reader might opine that these are all the same things, but there is a very fine line that distinguishes them all. Sort of like the line between digital currencies and crypto-currencies.
Crypto-currencies are a subset of digital currencies. One who "invests" in crypto invests into digital currency, but one who invests into digital currency does not always invest into crypto.
There is a distinction, even if we all instinctively knew what the authors were trying to get across.
If you call censorship resistance a 'fine line', I agree.
I explained why I made the distinction. You should probably learn to read a more carefully before making statements about all knowing this & that. Or fine lines.
What do you think the point of crypto is? Make me look silly, bro.
Edit: You see the information I've talked about? I created that. So if you've got more, I'd be impressed.
Edit2: If you've got any thoughts on the blockchain as a data-commons for AI, I'm all ears.
Edit3: Any thoughts on the future of the decentralised web? Tangles for the IoT? How evolution relates to hard forks? Anything like that? Or just some dictionary definitions?
>I explained why I made the distinction. You should probably learn to read a more carefully before making statements about all knowing this & that. Or fine lines.
This is true. I have a habit of skimming and assuming if something's unclear.
>What do you think the point of crypto is? Make me look silly, bro.
Damn. If I came off as combative, wasn't my intention. Crypto's got a lot of uses. Fighting censorship through decentralization is one of its most notable features. Speculation and decentralized asset manipulator is another.
>You see the information I've talked about? I created that. So if you've got more, I'd be impressed.
I don't understand.
>If you've got any thoughts on the blockchain as a data-commons for AI, I'm all ears.
I don't understand.
>Any thoughts on the future of the decentralised web? Tangles for the IoT? How evolution relates to hard forks? Anything like that? Or just some dictionary definitions?
Exploitation of networks will be easier to carryout and forensics will be easier to fudge on a decentralized network. Having everyone run through the same nodes and the ability to mask my traffic as a benign pass-thru will greatly enable cyber-crime, even more-so than our current clearnet. Censorship will lose its foothold on oppressing, but it will now enable the other type of independent criminal.
On tangles: I think, if I'm correct in assuming how directed acryllic graphs operate, this will be a boon for anti-censorship, but its still has the same pitfalls. I can catch a ride and spoof myself as a benign fellow network user. I don't know much about this, but I've put one of the whitepapers on my to-do list.
It's like the use of the term 'bcash' to discredit Bitcoin Cash.
If you -- not being stupid -- don't get it, it's probably not worth my time explaining it again.
Edit: it's past 1 here. Need to sleep. Sorry for the short reply. You should check out Monero. A look at what the privacy has to offer.
I assume most don't care. The dichotomy is unimportant to them.
>If you -- not being stupid -- don't get it, it's probably not worth my time explaining it again.
I get it.
>it's past 1 here. Need to sleep. Sorry for the short reply. .
Sleep tight.
>You should check out Monero. A look at what the privacy has to offer
Already a user. Got in before people realized how much of a game changer this is.