- Investigative Report -
Editor’s Notes: All references used in the following article are denoted with an asterisk (*), and are accessible via the “References” link, provided below the following article. Also, the following article was written with support from WikiLeaks*.
January 22, 2010 (FinancialWire) (Investrend Information Syndicate) (By Lucy Komisar) — In September 2004, David Beringer, the tax director of the $20-billion Noble Group Ltd. (SGX: NOBL) (SGX: N21) (OTC: NOBGY) based in Hong Kong, wrote a memo* to company officials, expressing concern that if Swiss officials discovered that employees of a Swiss subsidiary were doing work for a company that claimed to be operating out of Bermuda, the subsidiary might have to pay Swiss taxes.
He said, “In the disclosure to the Swiss tax authorities we have not advised that personnel working in Switzerland conclude NIL’s contracts for fees for products structure and portfolio performance; and NIL’s intermediary agreements.” NIL was a Bermuda shell company called Noble Investments Ltd.
“There is concern that if the Swiss tax authorities learn that Swiss personnel are concluding NIL contracts, that NIL will be deemed to have a permanent establishment in Switzerland or that NIL will even be treated as a Swiss resident company,” he said. That could mean that “NIL would be exposed to a Swiss tax on a portion or all of its profits.”
The document was provided by Rudolf Elmer, a German who worked for Noble Investments SA, Zurich (NISA), a hedge fund consultant, as operations manager from June 2003 to October 1, 2005. His responsibility included doing the accounts.
He said that the company had created a shell company in Bermuda in order to cheat on Swiss taxes. He provided company documents and memos exclusively to this writer.
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FirstAlert(tm) Daily 1/22: Uppers And Downers
- Market Commentary -
All these changes operated on the backdrop of darkening news in China, concerning tightening money policies, not to mention a general sell-off that saw U.S. markets off between 1% and 2%. China is becoming the basket that a lot of people are putting their eggs into. Therefore any mention of slowing money flow causes a collective investor blood pressure increase. Everybody needs a little stress to be healthy, though. Right?
President Obama's announcement that certain funds might become off limits to banks caused a lot of sweaty brows and worries over where next year's giant bonuses could be squeezed from. And the plan isn't even close to hatching; so far, it's only an announcement.
Back to insurance, Humana was one of the 22% of NYSE companies that gained. Nobody is threatening its operations with changes. Many have tried–even presidents of nations. Insurance laughs.
Drug makers have a variety of reasons for being off; one is that it's unlikely that more people will be getting insurance. In fact, the opposite is more the case. And in that case, fewer people will be able to get the drugs they need. Especially the higher priced, non-generic ones.
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