Sunday, September 03, 2017

Apartment in residential zone of Panama City with easy access

7400 - San Francisco, Panama City - The Location

San Francisco is truly the best area to live in Panama City. It is a peaceful area, surrounded by
beautiful houses of impressive architecture, an inimitable exclusive and residential zone, close to the ocean but in the center of the city, which allows you to enjoy an incredible view of the ocean or of the city. Everything you need you will find close by: restaurants, schools, supermarkets, video rental stores, pharmacies and just a few streets away, one of the biggest shopping malls of Central America boasting stores selling international brands, at terrific prices, movie theaters and more. San Francisco is also one of the most accessible zones of the city, so it will only take a few minutes to arrive at your destination.

Maintenance fee includes: Maintenance of common areas, 24/7 security, broadband internet, gas.

7400 - San Francisco, Panama City - Key Features
  •  Prime Panama City Location
  •  Close to airport, Panama Canal and Bay of Panama (Pacific Ocean) etc.
  •  Family-owned developer with 35 years experience
  •  20 year exoneration from property tax
  •  Prices from just $270,000 based upon current availability
  •  Anticipated rental yield of 7-8%
  •  15% capital gains tax rate
  •  70-80% borrowing available


LA EXPERIENCIA QUE BUSCABAS PARA VIVIR A TU ESTILO! UBICACION: San Francisco es realmente el mejor lugar para vivir en la Ciudad de Panamá un área tranquila rodeada de hermosas residencias con una impresionante arquitectura una zona exclusiva y residencial por excelencia muy cerca del mar pero en el centro de la ciudad lo que le permite disfrutar de una vista increíble al mar o a la ciudad. Con todo lo que usted necesita cerca del área encontrará: restaurantes escuelas supermercados video clubes farmacias y a pocas calles centros comerciales cines y más.

EL PROYECTO: Con un estilo fresco moderno y relajado 7400 San Francisco encuentras las imponentes East Tower y West Tower. Estarás cautivado por su impresionante fachada con un estilo totalmente original ambas con elegantes lobbies entradas individuales desde sus múltiples vías de acceso y un diseño arquitectónico vanguardista que te hará sentir la experiencia 7400 desde el primer instante.

AMENIDADES: 7400 San Francisco te permitirá disfrutar a diario sin que te cueste más y sin salir de tu entorno 2400mts2. de amenidades como media cancha de basketball cancha de raquetball y áreas verdes para practicar deportes al aire libre.para relajarte cada día te espera un delicioso spa con sauna duchas completas y para ejercitarte un moderno gimnasio completamente equipadoun lujo que tienes con solo tomar la decisión inteligente de vivir en 7400 San Francisco. Cada torre cuenta con su propia área de esparcimiento para chicos y grandes con piscina área de juegos para niños terraza techada terraza abierta y una completa área social con salón de fiestas con cocina área para barbacoa terrazas baños y más para que celebres con toda comodidad y sorprendas a tus invitados.

LOS APARTAMENTOS: WEST TOWER con apartamentos de 153m es ideal para tu estilo de vida porque cada elemento en tu apartamento ha sido seleccionado pensando en que sea único e individual para que cada rincón tenga su propia personalidad y a la vez puedas adaptarlo a tu gusto. Acabados modernos y de buen gusto materiales importados de España de excelente calidad y que siguen las últimas tendencias en decoración: una hermosa cocina con sobre de granito y modulares estilo italiano elegantes baños con sobres de mármol modernos y lustrosos pisos de porcelanato de 60cms azulejos importados ventanas de piso a techo detalles que hemos incorporado para tí porque son parte del concepto 7400 San Francisco.

For more information contact by Whatsapp +5076617321

Tuesday, August 08, 2017

Anguilla provides advantages for hedge funds


Anguilla provides advantages for Hedge Funds and IBCs

In 2004, Anguilla added legislation that provided for mutual funds, captive insurance and protected cell companies. The IBC (International Business Company) Act provides all the necessary features of this entity with enhanced shareholder protections.

INCORPORATION
Anguilla has an online company formation system, ACORN, which allows for the incorporation of IBCs, and other corporate entities, as well as the filing of annual returns and all other statutory documents over the internet. Only licensed practitioners i.e. holders of a company management (registered agent), trust or offshore banking license or their approved overseas agents, are allowed access to the system. At the end of the incorporation process, the incorporator receives a digital certificate of incorporation which can be used to open bank accounts. There is no need to take any documents to the Companies Registry for stamping. These are automatically generated by the ACORN system and service providers simply have to collect the hard copy of the articles of incorporation bylaws which will all bear the Registrar's stamp, from the Registry.

Shares and share capital
Shares may be issued as registered shares or bearer shares or both and may be issued to corporations or natural persons. IBCs can be formed with any authorized share capital and in any currency approved by the Registrar. The government fees do not increase based on share capital and shares may be issued with no par value. Shares may also be issued in fractions.

Share registers
IBCs must maintain registers of shareholders and directors. However, there is no requirement to file them with the Registrar.

Registered office/registered agent
Each IBC must have a registered office and registered agent. Only licensed practitioners can provide this service.

Directors and company secretary
An IBC must have at least one director but there is no residency requirement. Directors have all powers provided for in the bylaws except those reserved to the shareholders by the Act. Directors may be corporations or natural persons. There is also no requirement for a company secretary.

Shareholders� meetings
Meetings may occur outside of Anguilla, wherever and in whatever manner determined by the shareholders. Meetings may occur by telephone or other electronic means.

In practice, all companies formed in Anguilla are ordinarily incorporated by a trust company. Because all companies are required to have a licensed registered agent, and only trust companies are so licensed, in practice they control the incorporation procedure.
Technically any person may incorporate an IBC or a CAC by subscribing and filing the Articles of Incorporation, but as all IBCs and CACs are required by law to maintain a registered agent at all times, in practice the registered agent will invariably deal with the incorporation procedure. Similarly any person may form an LLC by subscribing the Articles of Formation, but because all LLCs are required at all times to have a registered agent, this process is usually undertaken by that agent.

All IBCs must be incorporated as companies limited by shares. A CAC may be incorporated as either (1) a company limited by shares, (2) a company limited by guarantee, or (3) a company limited by shares and by guarantee.

 
The corporate constitution of an Anguillan company depends upon which statute it is incorporated under.


         For an International Business Company, they are the Articles of Incorporation and the by-laws. The Articles of Incorporation are publicly filed upon incorporation, but they are a relatively perfunctory document containing very little information beyond the name of the company, the registered office and registered agent, and particulars of the authorised share capital. The regulation of the company's affairs is primarily delegated to the by-laws which are a private document not accessible by the public which are maintained at the company's registered office.

         For a private company registered under the Companies Act, they also consist of the Articles of Incorporation and by-laws.

         For a limited liability company, they are the Articles of Formation and the LLC agreement. Similar to IBCs, the Articles of Formation are publicly filed upon registration, but they are a relatively perfunctory document containing very little information beyond the name of the company, the registered office and registered agent. The principal regulation of the company's affairs is primarily delegated to the LLC agreement which is a private document not accessible by the public which are maintained at the company's registered office.

 
The Articles of Incorporation (or Formation) of a company are filed with the Companies Registry but are not available for public inspection. However, the by-laws or LLC agreement are private, and not available to the public. In each case, the constitutional documents may be amended without a court application, but where the document is publicly filed, the amendment will normally need to also be publicly filed before it becomes effective.


For IBCs and CACs the Articles of incorporation and by-laws will bind the company and each member of the company as if they had been executed by them personally. There is no equivalent provision for LLCs.

In addition to raising capital from their members by way of equity, Anguillan companies may raise capital by way of debt, either in the form of loans or by issuing debt securities. Companies are not required to file financing statements in Anguilla when borrowing money.

Anguilla offers a low cost and efficient regulatory fund environment for private investment funds. 3 types of funds allowed, the two of interest to small offshore fund operators being Private and Professional Funds. A fund may be in the form of Anguillan company, Intl business company, LLC, limited partnership, partnership, unit trust or protected cell company, protected cell accounts, segregated portfolio company, or segregated portfolio accounts. This allows for the issuance of series or classes of shares with different rights, thus allowing for the creation of umbrella funds and master/feeder structures.

Private Funds
This refers to a mutual fund whose constitutional documents specify that it will have no more than 99 members. Private funds are recognised under the Act. The documents must also specify that the making of an invitation to subscribe for or purchase shares issued by the mutual fund are not offered to the public. Exemption from recognition is given to a family trust fund as defined in the Act.
There is no restriction on the amount of investment by individuals who may constitute a private fund.

Professional Funds
This refers to a mutual fund whose shares are made available only to professional investors and the initial investment in which, in respect of each of the persons constituting a majority of such investors, is not less than US$100,000 or its equivalent in any other currency. Professional funds are recognised under the Act. Professional investors are required to state in writing that they consent to being treated as a professional investor.

There is no restriction on the number of investors who may constitute a professional fund.

A mutual fund may also be recognised as a professional fund if it was carrying on business or engaged in an activity as a mutual fund on the date of the coming into force of the Act; the initial investments in respect of the majority of each of the investors in the mutual fund have been not less than US$100,000 or its equivalent in any other currency. Furthermore, the shares of the mutual fund are, after the date of the coming into force of the Act, made available only to professional investors.

Wednesday, March 01, 2017

Are you a client of SMH / Swiss Metal Assets?

For those asking about a company called Swiss Metals claiming to operate in Panama, an article in PanamaGuide.com reads :
Swiss Metal Assets S.A. (SMA), the Panamanian branch of Schweizerische Metallhandels AG, with offices in Switzerland and the Republic of Panama now offers you solutions for the protection of your wealth. Protection of your wealth can be achieved through purchasing physical ownership of rare industrial metals and industrial silver granulates. SMA products allows you to convert your currency into High Demand Rare Industrial Metals, TAX FREE.
Swiss Metal Assets, S.A., (SMA), and its trading partner Schweizerische Metallhandel AG, (SMH) are operating together throughout Europe and the Americas focusing on the trade and distribution of rare industrial and precious metals. *_Our business is not Stocks, Bonds, Shares Certificates, or Futures_* Five years ago three German entrepreneurs realized that there was a need for people to exchange the paper cash into real assets such as metals. They began selling Silver and Gold only, but after speaking with the owner of Haines & Maassen, one of the top traders in the world in rare industrial metals they made an agreement to offer Rare Industrial Metals to the general public for the first time as a contingency to secure and preserve wealth. Together they set up a company where you can invest in these metals and store them in the Swiss duty free zone, Zürcher Freilager AG, a Swiss Warehouse Operator since 1923. Since then we have converted cash into real metals assets worth millions of dollars for Germans and many other Europeans. Now for the first time this is available in the Americas. (more)

The following process is supposed to be followed:

Purchase Process:
  • 1. Sign Purchase and Storage Contracts
  • 2. Receipt of Client’s funds by Swiss Metal Assets
  • 3. Transport of Metal Asset to the Entrepot Warehouse
  • 4. Assets are assigned a Charge Number and an Invoice Generated
  • 5. Client receives Invoice and Ownership Certificate
  • 6. Time line is generally three weeks from receipt of funds
Resale Process:
  • 1. Two Options Client Request for ReSale or Industry Request for Purchase
  • 2. With Client Request we will ask our Metal Trader for the daily price of each metal and advise client
  • 3. With Industry Request our Metal Trader will provide the purchase price to the seller
  • 4. Funds will be transferred to any Bank Account world wide

Floor 18, Office O of the Aseguradora Ancon tower,
presumably the office of Swissmetal, Inc. 
 More recently, the SMH website announces that:
Panama City, Panama – Strong demand and rapid growth of Schweizerische Metallhandels A.G. (SMH AG), and their partner in the Americas Schweizerische Metallhandel Panama S.A. (SMH Panama) , a Panama based supplier of rare strategic metals, has allowed them to welcome Swissmetal Inc (SMI), as their second service provider. Knut Andersen, previously the sales manager of Swiss Metal Assets (SMA), their first provider, is spear-heading the new venture. SMI has been running at full capacity from their new Panama location in Costa Del Este since October 2012.


Clients of SMH are asked to sign this waiver of rights
Several clients who hired lawyers found to their surprise that:
  • SMH SCHWEIZERISCHE METALLHANDEL PANAMA,S.A., had as first directors:
  • DIRECTOR: ULRICH SCHWARK
    PRESIDENTE: PETER BERND STEHLING
    TESORERO: CATHERINE VERBEL
    SECRETARIO: BIRGIT RUNGE
    • SMH SCHWEIZERISCHE METALLHANDEL PANAMA, S.A., never had a business license.  The company was dissolved on October 16, 2016.   This means that a period of 3 years is open for liquidation of its assets with their last directors as trustees liable for its debts.

  • No Panama company called Swiss Metal Assets S.A. exists in the Public Registry but a New York LLC was registered in New York by Juliette Passer since July 21, 2011 https://opencorporates.com/companies/us_ny/4121004
  • The Panama Ministry of Commerce lists a company called Swissmetal Inc. with offices in Costa del Este, Panama City:
Número de Aviso de Operación:2276052-1-786004-2014-407589 
Nombre Comercial:SWISSMETAL INC.

RUC:2276052-1-786004 DV 23
Fecha de Generación:10-Feb-2014
Representante Legal:KNUT EGIL ANDERSEN
Ubicación:PANAMÁ, PANAMA, JUAN DIAZ
Urbanización:COSTA DEL ESTE


Edificio:PH TORRE ASEGURADORA ANCON
Apartamento:PISO 18 LOCAL O
Actividad Comercial:SERVICIO DE PROMOVER Y MERCADEAR LAS VENTAS DE METALES Y OTROS SIMILARES

This office is now part of an unrelated French company.

Investors should ask a lawyer to review a contract or conduct due diligence of its directors before sending funds to accounts related to any investment.  Your suggesitons or corrections to this data are welcome and may be posted anonymously in the comments.

See also:
http://www.panama-guide.com/article.php/20110107163500673
http://smhpa.com/contact/
https://www.panamaemprende.gob.pa/publico.php?pag=certificAO&anio=2014&ao=11692&Suc=655436&a_buscar=__swiss_______on_on&np=1
http://www.ripoffreport.com/reports/smh-schweizerische-metallhandel-panama-s-a/panama-city-other/smh-schweizerische-metallhandel-panama-s-a-smi-swissmetal-inc-i-have-also-invested-i-1355113



Monday, February 20, 2017

Bermuda Deputy PM: "The UK is a Tax Haven"

Bermuda Deputy PM and Finance Minister said it the way it is: OECD founder UK is actually a tax haven.   And Richards is no parochial nationalist: he has experience working at a pension fund, courses at the IMF and an MBA in Canada.




'The UK is a tax haven' – Bermuda attacks plan to end financial secrecy 



Juliette Garside 
Monday 6 February 2017 15.32 GMT Last modified on Monday 6 February 2017 22.00 GMT

The government of Bermuda has hit back at British efforts to end offshore financial secrecy, claiming the UK itself is a “tax haven”.

Speaking ahead of a meeting on Wednesday between Theresa May and the leaders of Britain’s overseas territories, Bermuda’s deputy premier and finance minister, Bob Richards, pushed back against proposed legislation that would create public registers naming the owners of offshore companies.

Richards said the UK should get its own house in order before making demands from its dependencies.

“The UK is a tax haven,” he said, citing non-dom laws that allow foreign nationals to live in Britain without paying tax on overseas income.

“You have more billionaires resident in London than any place on earth. They are not here for the weather, they are here for the tax climate. We have a double standard going on here.

“We have a much more transparent, much cleaner system than the countries that promulgate these rules in the first place. The popular notion that somehow there is something nefarious going on in a small island that is relatively successful is false.”

From April 2017, however, non-doms will lose some of their advantages and foreign nationals will no longer be able to enjoy tax breaks indefinitely in the UK. Those resident in the UK for 15 out of the previous 20 years will be liable for inheritance, capital gains and income tax on their worldwide assets.

A cross-party group of 88 MPs, led by the tax campaigner Margaret Hodge, is backing an amendment to the government’s criminal finances bill that would force British territories to follow the UK in making public their company ownership registers by 2020.

“There is a thing in this world called privacy and at least in my island privacy still exists,” added Richards. “There is no public right to know anybody’s private business.”

The Panama Papers exposed how thousands of offshore companies have been used to help hide the proceeds of fraud, political corruption and tax evasion.

Unlike most tax havens, Bermuda does keep a central government record of who owns its offshore entities. This information is available to other governments on request, but not to the general public.

Deputy PM Richards
Richards told the Guardian he would resist calls, first made by David Cameron in 2013, to open up the register. “The register in Bermuda is there to protect the government’s reputation ... It is not the public’s business. We are not here to tell you who is doing business in Bermuda,” he said.

“There is a thing in this world called privacy and at least in my island privacy still exists,” added Richards. “There is no public right to know anybody’s private business.”

The Panama Papers exposed how thousands of offshore companies have been used to help hide the proceeds of fraud, political corruption and tax evasion.

Unlike most tax havens, Bermuda does keep a central government record of who owns its offshore entities. This information is available to other governments on request, but not to the general public.

Richards told the Guardian he would resist calls, first made by David Cameron in 2013, to open up the register. “The register in Bermuda is there to protect the government’s reputation ... It is not the public’s business. We are not here to tell you who is doing business in Bermuda,” he said.

The mid-Atlantic nation is a major centre of tax avoidance, with Google and other multinationals attracted by a zero corporation tax rate. Oxfam found that US corporations reported $80bn (£64bn) in profits in Bermuda in 2012 – more than their combined reported profits in Japan, China, Germany and France.

Bermuda should do what guarantees the future of its next generation.
Destroying its financial center will not provide jobs for the future.
“People are pressuring overseas territories because they feel we are defenceless, in some way easy pickings,” said Richards. “They are moving the goalposts on us almost every three weeks.”

The Bermudian premier, Michael Dunkley, has joined Richards in London this week for a series of briefings with UK ministers, with Brexit top of the agenda. Richards said his government was in listening mode but, if pushed, it would not hesitate to protect its interests.

He said last year he “would not hesitate to go for independence” if his country were threatened by Brexit. Bermuda’s last push for independence was in a 1995 referendum.

Richards said: “At the moment our interests are aligned but if that changes then we will have to think of ourselves. We must protect Bermuda’s interests. This amendment being proposed [by Hodge] is not in the interests of Bermuda.”

See full text in https://www.theguardian.com/business/2017/feb/06/uk-tax-haven-bermuda-financial-secrecy-offshore-companies
See also:
Bermuda Ministry of Finance https://www.gov.bm/ministry/finance




Thursday, February 16, 2017

LIVE Streaming - Conference on Tax Competition Feb 15-17

Speakers from US, Latin America, Germany, UK, France and other OECD countries speaking in Panama about tax competition and individual freedom at Widening Pathways to Open Societies conference

https://www.acast.com/docthompson/short-stack-adolfo-linares-from-widening-the-pathways-to-open-societies-tmb

Monday, August 29, 2016

Panama City property auction seeks qualified buyers


The Panama Stock Exchange reported that an auction will be held for the lot of land and improvements for the Hotel Unicorn (Park Inn by Radisson under construction on Finca 1025) in 44 Street and Justo Arosemena Av., in Bella Vista, one of the prime neighborhoods of downtown Panama City.

Corporate bonds were issued of which about $ 2.7 million were placed on the market for the issuer UHR Development (BVP: UHRD).  The property will be auctioned by the bond trustee to interested qualified buyers under the terms and conditions of said issue.

For more information contact lagrealty @ laglex.com

The appraisal of the property is available in:
Panama Stock Exchange website http://www.panabolsa.com/PDFs/Informacion%20Corporativa/UHRD/informe%20inspeccion%20avaluo%20abr2016.pdf
Slideshare copy http://bit.ly/2bOoZmw






Monday, May 09, 2016

How Panama Papers' sponsor George Soros made billions offshore

 
The Independent provided this 1994 glimpse into how George Soros made billions with an offshore Netherlands Antilles fund using tax breaks which are now villified under the Panama Papers by the International Consortium of Journalists he sponsors.  The Quantum fund was formed by Citco (Curacao Investment Trust Co) instead of a Panama law firm.


Lifting the lid of the Soros money machine: 
In an exclusive journey through the labyrinthine empire of the master speculator, Stephanie Cooke and Charles Raw find gains are 'reallocated' to a charmed circle of associates

STEPHANIE COOKE and CHARLES RAW Saturday 5 March 1994


'I STILL consider myself selfish and greedy,' says George Soros. 'I am not putting myself forward as any kind of saint. I have very healthy appetites and I put myself first.'
Mr Soros is the man who made dollars 1bn when Britain left the European exchange rate mechanism in September 1992, earning him the status of a legendary investor. But that status was tarnished last month, when he lost a similar sum on the yen.

Nevertheless, he has set the tone for a new generation of large-scale professional investors who run so-called hedge funds on behalf of wealthy private clients. Markets regularly hang on his predictions for the course of gold, currencies and shares.

The size of these hedge funds means they are regularly singled out as the cause of seismic shifts in financial markets. That is putting Mr Soros into sharper focus, simply because he is the leader of the pack. If he should falter, the knock-on effect could be widespread.

That is why central banks have started to ask questions about unregulated offshore operations such as his.

Ever the master of public relations, Mr Soros welcomed the central banks' probe. 'I feel there is an innate instability in unregulated markets,' he told the Reuters news agency.

Until now, however, remarkably little has been known about how the Soros financial empire is organised.

The first detailed analysis of the funds' published documents reveals that he has created a complex and bizarre financial creature in which the interests of Mr Soros, his family, close friends and key executives in the business are incestuously intertwined with those of his public investors.

Some of those investors may not have noticed that in the past few years Mr Soros has altered the structure of the organisation so as to reallocate some of the profits in favour of his private circle.

Mr Soros started his offshore fund operation with dollars 4m in 1969, at the age of 39, after learning the arbitrage and investment business in London and New York.

He appears from the start to have aimed at wealthy individuals and professional European investors. He told prospective clients that the purpose of his key Quantum fund was 'to enable sophisticated investors to participate in an internationally diversified investment portfolio'. The Quantum fund is active in currency, commodity and interest- rate markets as well as equities and fixed-interest securities.

Later, in the early 1980s, Soros honed to perfection the technique of charging buyers a premium based on the supply and demand of fund shares.

Normally an open-ended investment fund is sold or redeemed at net asset value, with a sales charge added or an administrative charge deducted. But the Quantum fund can issue shares at a premium to its net asset value. The premium, however, is not based on an open market value.

Instead it is set by the fund's managing director, Citco (Curacao Investment Trust Co) in Curacao in the Netherlands Antilles. This is declared to be 'by or at the direction of the fund's board of supervisory directors', which is chaired by Alberto Foglia of the Banca del Ceresio in Lugano, Switzerland. Its seven other members are mainly European bankers and brokers, including in London the renowned fund manager Nils Taube of Lord Rothschild's St James's Place Capital.

In the late 1980s the Quantum fund's documents stated that the premium would not rise above 25 per cent. As the premium for buying the fund was as low as 1 per cent during that period, it was not an unduly onerous restriction. But in the past few years, as the fund's fortunes have risen, the restriction has been quietly dropped and the premium soared at one point to nearly 40 per cent. After the Japanese loss last month, it dropped four points to 35 per cent, but is now back to 36 per cent.

Possibly to avoid problems with the US authorities, Soros states that his funds are barred to Americans - whether in the US or abroad. At least one exception to this is Soros himself, who became a US citizen in 1961.

By 1972 the fund was worth dollars 20m. For reasons not made clear in recent documents, the operation was relaunched under the Quantum name in 1973. The fund was registered in the Netherlands Antilles, but Soros ran it from New York through Soros Fund Management. No information is given about this firm's precise corporate status, other than that it has always been wholly owned by him personally.

Although Soros now leaves the running of SFM to his executives, the documents state that in his 'personal capacity, he manages a securities trading partnership formed for the benefit of members of the Soros family and several other family accounts'.

By the end of 1980 the fund was worth more than dollars 380m and the net asset value of each share had risen by almost 4,400 per cent. In 1981 Quantum shares fell by 23 per cent, their first drop in value, and the fund nearly halved to dollars 193m. The following year a new category of share was created - the B share - in which Soros placed money invested by himself and his trusts and charities. His own main investment in the fund is now via these shares. It is through them that he apparently exercises control over the fund, although the voting rights of these shares are not explained in more recent documents. He can and does convert B into A shares from time to time, but these are primarily held by outsiders. No single external investor is allowed to exercise more than 4.9 per cent of the votes.

Although the fund recovered and grew once more, it hit another rocky patch in the late 1980s when more investors were selling Quantum shares than were buying. Around this time Soros made serious efforts to expand his operation.

In 1989, in spite of the fact that very few investors came into the fund, the net asset value of Quantum increased by 31.6 per cent.

Mr Soros had demonstrated the magical effect of simple mathematics, something not immediately apparent to laymen. Because of the high number of redemptions during 1989, the benefits were divided among fewer shares, so the net asset value still rose.

By then the operation was working as follows. Under an agreement approved by shareholders in 1988, Soros Fund Management is paid a basic investment advisory fee of 1 per cent a year, payable monthly. But the real cash cow is the annual performance fee. The fee is mainly composed of a sum equal to 15 per cent of any increase in net assets resulting from the fund's operation - before the deduction of the performance fee itself, of course.

There is another element in the fee - 15 per cent 'in net assets resulting from premiums realised on fund share subscriptions and premiums or discounts realised on fund share redemptions'.

Although the fund can issue shares at a premium direct to investors and - as is normal with open-ended funds - redeem them, in practice Quantum acts differently.

It has a subsidiary called Quasco which sells Quantum shares at a premium and buys them back either at a smaller premium or, should the situation arise, a discount of up to 1 per cent. Quasco makes a profit from the margin between the premiums charged to buyers and the price offered to sellers. In recent years the margin has been around 4-5 per cent.

Quasco's accounts are not available, but it is clear it makes a substantial amount of money through these dealings. This money has historically been reinvested in the fund and SFM has taken its 15 per cent cut.

Indeed, the very fact that the money was ploughed back has been used as a strong promotional point by brokers selling the funds.

But in 1991 things started to change. In a significant restructuring of the operation that included the launch of new funds, Mr Soros began the 'reallocation' of some of the gain for 'selected persons associated with SFM'.

By then Mr Soros had apparently finally decided that Quantum's growth had to be curtailed. In February of that year he announced the biggest distribution so far: dollars 4,000 per share, a total of dollars 611m. To satisfy investors who did not want cash, he offered shares in a new fund, Quasar International.

Quasar was a different animal to Quantum. Instead of investing directly in securities, it would invest only in one entity - Quasar International Partners. That in turn would carry out investment activities under advice from SFM. But Quasar, like Quantum, had a dealing subsidiary, Quinter.

The fund was not the only investor in the partnership, however. Mr Soros, 'certain members of his family and other selected persons associated with the partnership's management' also joined the club.

The Quasar fund has had a very successful run. In only its second year of operation it showed an increase in net asset value per share of 56.2 per cent, following a 44.9 per cent rise the previous year.

The accounts for the year ending 31 January 1993 show that of the dollars 18.2m netted on premiums, dollars 5.6m was 'reallocated to other partners'. In the previous year they were allotted dollars 2.55m in premiums. These reallocations were based on their share of the partnership, which had risen from 24.6 per cent at the outset to 29 per cent by the end of the second year, partly because of the reallocations.

Thus Mr Soros, his family and key members of his management team had effectively increased the membership dues for Quantum's sophisticated investors in the fund, and helped to dilute the fund's interest in the partnership.

In the explanatory memorandum about Quasar, Mr Soros explained that 'the Fund's net profit or loss from transactions in the Fund shares (whether realized directly or through Quinter) generally is accounted for as if earned by the Partnership, and thus is shared among the Fund and the other partners.'

Close examination of the accounts also reveals that the 'selected persons' appear to have benefited in another way from the establishment of the partnership.

In April 1991 Soros told Quantum shareholders that they had subscribed for a total of dollars 541m in 'Quasar', without specifying whether he meant the fund or the partnership.

In fact the accounts reveal that while dollars 541m of Quantum's assets were indeed transferred to the Quasar partnership, the Quasar fund's initial net asset value was only dollars 493m - a difference of dollars 48m.

The Quantum investors choosing to invest in Quasar were thus effectively paying a premium of about 9.5 per cent for their new shares.

Another discrepancy appeared in the calculation of the net asset value at the end of the second year. While the fund's holding of the partnership at that time was 71 per cent, when it came to dividing up the net increase in the partnership's capital resulting from operations, the fund got only 67.1 per cent. This is possibly because the 'selected persons' do not pay advisory fees.

The pattern for spinning off new funds had been set.

When Quantum's next distribution of dollars 1.166m was made in February 1992, two further funds were launched: Quota and Quantum Emerging Growth.

Quota was different because it would be managed entirely by outside advisers (but, of course, under SFM's overall direction).

Quantum Emerging Growth remained inside the SFM stable - but its performance fee was set at 20 per cent and also spawned a partnership arrangement similar to the Quasar operation. In effect, therefore, it too raised the stakes for the growing ranks of investors in what was by this stage fast becoming the Soros phenomenon.

This time, though, there was no discrepancy between the assets of Quantum transferred to the partnership and the new fund's equity stake, according to the accounts issued for the first 15 months to 31 March 1993.

During that period the 'selected persons' put some dollars 100m into the partnership. Their share rose from less than 5 per cent at the outset to 15 per cent at the end of the period. Their allocation of the dollars 40m in profits, generated by the premiums from dealings in the fund's shares, was dollars 4.7m.

As the fund's fortunes rocketed, self-restraint among its management seemed to wane. The 25 per cent restriction on the premium had long since disappeared.

Then it spawned two property funds, each with a high- profile partner.

One, Quantum Realty Trust, was with Paul Reichmann, whose Olympia & York operation had collapsed as a result of the financial drain of the Canary Wharf development in London's Docklands.

The other, Quantum UK Realty Fund, was with John Ritblat of British Land. Again, capital was provided partly out of distributions from Quantum and Quasar as well as by Mr Soros and his family, but also this time by other participants.

Although the structure of these new funds is highly complex, they are essentially closed- end operations. What may not have been noticed was that in June 1993 the directors of the open-ended flagship - the Quantum fund - removed an important investment restriction: a prohibition on direct investment in property.

Until the audited accounts for 1993 are available (they are expected to be out in May or June), investors will not know whether advantage has been taken of this change, or what effect it may have had on the liquidity of the fund.

Last year, Quantum quietly transformed itself. On 1 August 'substantially all' of Quantum's assets and liabilities were transferred to a new Curacao partnership, Quantum Partners.

As with Quasar and Quantum Emerging Growth, the Quantum fund is not the only partner. 'Selected persons associated with SFM' - including SFM's managing directors - subscribed for 1.3 per cent of the new partnership's net equity.

In effect they were getting a share in Quantum without having to pay a premium. Already by the end of September their share of the net equity had risen to 1.9 per cent - dollars 78m - and, as with Quasar and Quantum Emerging, they would get a share of the net premiums made from dealings in the flagship fund.

Again, just how much this will be will not be known until the 1993 accounts are available. But in 1992 such dealings contributed dollars 68m towards the rise in the fund's net asset value.

Additionally, SFM's managing directors and 'trusts and charitable foundations created by them' have taken an insurance policy on the future of the fund. This comes in the form of dollars 220m of convertible debentures that pay 6 per cent a year and are convertible in 2003 into partnership shares at 120 per cent of their net asset value on the issue date. They may be worth considerably more than that by then.

In the great tidal wave of money into the Soros empire, which at the end of 1993 stood at dollars 4.9bn for Quantum alone and more than dollars 10bn for the whole group, there is another sum that may one day cause repercussions of its own: the size of the performance fee that SFM leaves in the fund. At the end of 1992, the latest reckoning available, that totalled nearly dollars 550m.

These deferred fees are so structured that they share in the appreciation of the fund, but investors are given no clear picture of when SFM can or will withdraw them.

It is curious that Mr Soros has not yet taken this money out, since it would be one way of reducing the size of the funds. But to take it out quickly now might suggest he was losing confidence in his own creation.



See full text in http://www.independent.co.uk/news/business/lifting-the-lid-of-the-soros-money-machine-in-an-exclusive-journey-through-the-labyrinthine-empire-1427341.html