Bank Deposit Amounts Reported To Irs

Haven for the rich, hell for the rest of us.

The time when tax havens consisted of exotic islands where a few
gangsters or corrupt dictators hid their fortunes is long gone. Tax
havens have become sanctuaries for an array of multinational firms and
their subsidiaries or corporate parents. They form part of the
background to most of the financial crises and scandals of the last 20
years. “Madoff Spotlight Turns to Role of Offshore Funds,” ran
New York
 Middle Atlantic state of the United States. It is bordered by Vermont, Massachusetts, Connecticut, and the Atlantic Ocean (E), New Jersey and Pennsylvania (S), Lakes Erie and Ontario and the Canadian province of
 Times headline on December 30, 2008. It had taken just 19
days after Bernard Madoff’s $65 billion
 v. to cheat through trick, device, false statements or other fraudulent methods with the intent to acquire money or property from another to which the swindler is not entitled. Swindling is a crime as one form of theft. (See: fraud, theft)
 broke into the open
on December 11 to draw the link between the swindle and tax havens. (1)

Since the financial crisis of 2008, politicians’ attitudes
toward tax havens have changed. Government leaders now recognize that
tax havens endanger public finances and their countries’ political
stability. The
 see Organization for Economic Cooperation and Development.
 is stepping up the fight against international tax
fraud and, increasingly, promoting international tax transparency. At
the London G20 summit in April 2009, countries announced the advent of a
new era of transparency and tax cooperation. (2)

Despite these advances, the problem remains unresolved. Trillions
of dollars continue to accumulate beyond the reach of government in tax
havens, with the middle class left to fill the public coffers and make
up for this shortfall. As protesters outside the G20 summit at Cannes,
France, in November 2011 called for an end to tax havens, officials of
the G20 inside issued a list of 11 countries, including Switzerland,
that they said were doing too little to cooperate. (3) However, no
sanctions were announced.

What is a tax haven?

According to

1. As stated or indicated by; on the authority of:

2. In keeping with:

 a study published in December 2006 by the U.S.
National Bureau of Economic Research, about 15 per cent of countries
around the world are tax havens. Most of these countries appear to be
financially well off and are relatively small in size. (4) Few OECD
member countries have precise definitions, though. Most see tax havens
as states with systems enabling nonresidents to

 tax obligations to
other governments, along with
bank secrecy


The OECD uses three criteria to determine whether a country is a
tax haven: absence or near-absence of income taxes; absence of
transparency in the tax system; and a refusal to exchange financial or
tax information with other governments. In addition to tax havens, there
are three other types of haven-type zones. In offshore zones that are
home to banks, insurance companies or fund managers but lack a true
financial regulatory apparatus, companies can avoid various restrictions
by having addresses only in these states. Then there are bank havens,
states characterized by a high level of bank or financial secrecy.
Finally, there are judicial havens, which evade criminal and other laws
generally adopted by other states and refuse any exchange of information
with other states.

Some may be multihaven zones, falling into more than one of these
Strictly speaking

, a tax haven differs from the three other
types, but in practice these distinctions are often blurred. It is not
uncommon for offshore zones to be regarded as tax havens.

Where are these tax havens located?

Ronen Palan, professor of international political economy at the

University of Birmingham

, separates tax havens into two
n. (used with a sing. verb)
1. The study of the relationship among politics and geography, demography, and economics, especially with respect to the foreign policy of a nation.

 poles. (5) The first group gravitates around the London financial
centre, mainly encompassing dependencies of the British Crown such as
Isle of Man

, the Channel Islands of Jersey and Guernsey, the

 , British dependency (2005 est. pop. 44,300), 100 sq mi (259 sq km), comprising three islands in the West Indies.
, Bermuda, the
British Virgin Islands

A British colony in the eastern Caribbean east of Puerto Rico and the U.S. Virgin Islands. Road Town, on Tortola Island, is the capital. Population: 21,700.

Noun 1.
, the Turks and Caicos and
Gibraltar, as well as former parts of the
British Empire
 overseas territories linked to Great Britain in a variety of constitutional relationships, established over a period of three centuries. The establishment of the empire resulted primarily from commercial and political motives and emigration movements
 such as

 , Mandarin Xianggang, special administrative region of China, formerly a British crown colony (2005 est. pop. 6,899,000), land area 422 sq mi (1,092 sq km), adjacent to Guangdong prov.
, Singapore, Malta, the Bahamas, Bahrain and Dubai. The other group
developed around economic activities in the rest of Europe and includes
the Benelux countries (Belgium, the Netherlands and Luxembourg) together
with Ireland and, of course, Switzerland and Liechtenstein. Two other
tax havens, Panama and–to a small extent–Uruguay, operate
independently of these poles.

Each year, the OECD draws up a list of uncooperative tax havens. In
2000, the OECD identified 38 such entities, most of them Caribbean and
Pacific islands and European microstates. In 2009, in coordination with
the G20 summit, the OECD published a new listing of tax havens divided
into four categories, depending on the level of noncooperation (white,
pale grey, dark grey and black). The white list encompasses
jurisdictions that have broadly applied a standard of transparency and
information exchange. This standard involves an obligation to exchange
information on request in all taxation-related areas for the
administration and application of national tax laws. The two grey lists
cover tax havens and financial centres that have made commitments
concerning this standard but have not yet applied it. To go from a grey
list to the white list, countries must sign at least 12 agreements with
other countries. Finally, the black list consists of jurisdictions that
have not agreed to apply the internationally recognized tax standard. As
of December 15, 2011, there weren’t any countries on the black list
and just three on the two grey lists (Nauru, Niue, Guatemala). (6)

These results are surprising. It is not as if there is any reason
to believe tax havens are disappearing. In one year, tax havens such as
Liechtenstein, the Cayman Islands, Monaco, the Bahamas, Bermuda and
Singapore ended up on the white list by signing most of their
information exchange agreements with other tax havens. (7) At the very
least, it is too early to judge the effectiveness of the recently signed
agreements, the application of which will be subject to meticulous
follow-up by the Global Forum on Transparency and Exchange of
Information for Tax Purposes. We will take a closer look at this
body’s role further on.

What are the results of tax havens?

Tax havens cause harm to countries that are not tax havens, which
suffer deterioration of public finances, increased financial instability
and injustice. Let us take a closer look at each of these problems.

The existence of tax havens leads to capital flight from non–tax
havens, which are deprived of taxes they would otherwise collect as
companies move head offices or activities to tax havens. On January 5,
2010, Canada’s then–Revenue Minister Jean-Pierre Blackburn stated
Canadian companies

 and individuals had a total of C$146 billion
invested in tax havens in 2009, a substantial increase from the $88
billion total in 2003. “Safeguarding cash in those places is not
illegal,” noted a Reuters report, “but makes it easier to
avoid declaring income for tax purposes.” (8)

The reported amounts are just approximations. Whether at the
national or international level, nobody has yet managed to put an exact
figure on the scale of revenues lost to tax havens. But there are some
credible estimates.

* A study published in March 2010 by Global Financial Integrity, a
Washington-based international organization that works to curtail
illicit financial flows, estimates the total amount deposited by
nonresidents in offshore financial centres and tax havens at about U8510
trillion (for the sake of comparison, annual worldwide
 (guanosine diphosphate): see guanine.
 in 2010 was
$74 trillion). The study also states that these deposits are growing by
an average of 9 per cent a year, substantially more than the rate of
increase of worldwide wealth in the last decade. (9)

* According to an October 2007 report published by Tax Analysts, a
U.S. tax policy organization, “At the end of 2006, there were
$491.6 billion of assets in the Jersey financial sector beneficially
owned by non-Jersey individuals who were likely to be illegally avoiding
tax on those assets in their home jurisdictions. We estimated the
comparable figure for Guernsey to be $293.1 billion.” If we add
$150 billion in investments in the Isle of Man, as estimated by Tax
Analysts in a November 2007 report, we get assets totalling $935.2
billion in these three islands alone. (10)

* According to a March 2005 study published by the Tax Justice
Network, a pressure group that opposes tax havens, the total of large
private fortunes held in tax havens was about $11.5 trillion, producing
an annual return of about $860 billion (at a rate of 7.5 per cent) and a
$255 billion loss of tax receipts. (11) These figures do not take into
account tax losses resulting from the multinationals’ offshore tax
strategies or transfer costs or assets below $1 million held by
individuals. Rates of return were probably less than 7.5 per cent in
recent years, but international capital markets have grown substantially
in that time.

* A report issued on July 16, 2008, by a U.S. bipartisan Senate
Permanent Subcommittee on Investigations estimated that offshore abuses
cost U.S. taxpayers an estimated $100 billion each year. (12) And again,
that study did not consider the public revenues that are lost by
industrialized countries because of tax strategies of the multinationals
in tax havens.

* An analysis produced for Oxfam in March 2009 by
James Henry

chief economist

 of McKinsey & Company, (13) suggests that at
least $6.2 trillion from developing countries is held by individuals in
offshore accounts, depriving these countries of $64 billion to $124
billion annually in tax receipts. Total losses may thus exceed the $103
billion these countries receive annually in development assistance. And
if the amounts held by private companies in offshore accounts were
included, this shortfall would be much higher. Henry indicates that this
capital flight from developing countries is growing quickly, with an
additional $200 billion to $300 billion moving into offshore accounts
each year.

It should also be noted that tax havens cause a deterioration of
public finances in non–tax havens by exposing them to fierce tax
competition. Because of the existence of tax havens, other countries are
tempted to reduce their tax rates to attract new investment or retain
companies already established on their territory. In Canada, the federal
government is planning substantial tax reductions for multinational
corporations. In 2012, Canadian multinationals were to be taxed at a
legal rate of 15 per cent at the federal level (or a total of about 25
per cent a year with provincial tax added), compared to 35 per cent in
United States
 officially United States of America, republic (2005 est. pop. 295,734,000), 3,539,227 sq mi (9,166,598 sq km), North America. The United States is the world’s third largest country in population and the fourth largest country in area.
 (to which must be added the corporate taxes applied in
certain states).

The opaque nature of tax and banking havens prevents fiscal,
judicial and financial authorities in other countries from enforcing
laws and regulations. Free from requirements to publish statistics,
financial statements and other information, multinationals can place
dicey assets outside public scrutiny and hide the origin of funds. These
veritable black holes are obviously valuable to transnational criminal
organizations as well.

This opacity also leads to significant errors in trade and
financial statistics. It disconnects a country’s real economy from
what shows on the books, depriving governments and investors of
information they need to assess risks and make the right decisions. For
example, going strictly by public information, one would learn that
Europe’s largest importer of bananas is the tiny island of Jersey,
off the coast of Normandy, but in fact no containers of bananas have
ever been unloaded in the port of Jersey.

A wide array of events proves that the presence of tax havens lurks
in the background of the 2007-10 financial crisis. For example, the
failed British bank Northern Rock charged its short-term debt to
Granite, a Jersey-based subsidiary. According to a February 2008

 News report, Granite, a “legal vehicle ultimately controlled by
Northern Rock but registered as a trust in Jersey,” was “set
up to allow the Northern Rock to sell off large parts of its mortgage
book to bondholders. It was this financing model which got Northern Rock
in trouble when the market for such mortgage-backed bonds dried up in
August [2007].” (14)


investigative report

 by McClatchy News in 2009 showed how the
investment bank
Goldman Sachs

 used the Cayman Islands to promote $40
billion in AAA-rated junk securities to private and institutional
clients. (15) The McClatchy report noted that Goldman Sachs “used
offshore tax havens to shuffle its mortgage-backed securities to
institutions worldwide, including European and Asian banks, often in
secret deals run through the Cayman Islands, a British territory in the
Caribbean that companies use to bypass U.S. disclosure
requirements.” In addition, Goldman “was the lead firm in
marketing about $83 billion in complex securities, many of them backed
by subprime mortgages, via the Caymans and other offshore sites,
according to an analysis of unpublished industry data by Gary Kopff, a


 expert. In at least one of these offshore deals, Goldman
exaggerated the quality of more than $75 million of risky securities,
describing the underlying mortgages as ‘prime’ or
‘midprime,’ although in the U.S. they were marketed with lower

This was how Goldman Sachs got rid of all the subprime mortgages it
held shortly before their value collapsed in 2007. At the same time, the
bank was speculating on the markets by taking short positions on these
same securities. Goldman Sachs used its Cayman Islands branches to
promote these securities without having to comply with U.S. regulations,
which would have required it to warn its clients that it was using its
own money to bet against its customers.

The first form of injustice caused by the existence of tax havens
arises from the fact that it creates a two-tier international tax
system: one tier for ordinary people and another for the rich. Tax
havens are used by the wealthy and the powerful to hide wealth and avoid
taxes. They help shape a certain type of

 in which the gap
between the very wealthy and everyone else keeps growing. A report
issued in July 2010 by the American group Business and Investors Against
Tax Haven Abuse noted that “Wainwright Bank, a socially responsible
local lender based in Boston, paid 11.8 per cent of their income in
federal taxes in 2009. Yet they have to compete against
Bank of America

Bank of America (NYSE: BAC TYO: 8648 ) is the largest commercial bank in the United States in terms of deposits, and the largest company of its kind in the world.
which paid no federal taxes in 2009, thanks in part to overseas tax
havens.” (16)

The second form of injustice tax havens create is that they
facilitate abuse by multinational firms of the natural wealth of
undeveloped or developing countries. Jersey’s bananas are an
example of this. These bananas, transiting virtually through Jersey,

 profits that accumulate in the accounts of
multinationals. In 2008, OECD secretary-general Angel Gurria said that
developing countries lose huge amounts to tax havens–three times what
they get in assistance from developed countries. (17)

A third form of injustice caused by tax havens is the way they lead
citizens and tax authorities to bend and possibly break laws. The
HSBC-2010 and Liechtenstein-2008 affairs are examples.

In the HSBC-2010 affair, Herve Falciani, a former bank executive

HSBC Humane Society of Bay County  
 , Fr. Genève, canton (1990 pop. 373,019), 109 sq mi (282 sq km), SW Switzerland, surrounding the southwest tip of the Lake of Geneva.
, was arrested by the Swiss police on suspicion of
data smuggling. He took refuge in France and helped authorities

 the stolen data. France opened a
money laundering

 investigation and used
the information obtained from Falciani to identify the alleged
fraudsters. France then shared its information with other countries,
including Canada. In response to the ensuing criticism, French President
Nicolas Sarkozy defended the use of stolen data: “The fight against
tax fraud is normal and moral. It is up to the justice system to say
what happened. But what would you have said if the finance ministry had
disregarded these data when it received them? Would we have been
congratulated for abiding by French law?” (18)


The Liechtenstein-2008 scandal involved taxpayers from various
countries, including Germany, France, Australia, the United States and
Canada, who had transferred funds to trust accounts in Liechtenstein
with the complicity of banks such as
LGT Bank

, owned by the
Liechtenstein royal family. In February 2008, computer technician
Heinrich Kieber sold financial data that incriminated 4,500 taxpayers to
the German government for 4.2 million [euro]. The German government was
criticized for using secret information stolen by an


revealed theft by Mercury; turned to touchstone. [Gk. and Rom. Myth.: Walsh Classical, 47]

Cenci, Count Francesco

old libertine ravishes his daughter Beatrice. [Br. Lit.
. (19) Two
lawyers took action against Germany’s federal government for
“infidelity toward the taxpayer” and “spying of
data.” Questions were raised as to the legality and ethics of the
government’s move in paying a bribe to an officer of a foreign bank
to essentially steal confidential data.

How tax haven planning is done

Using new means of communication, and aided by e-commerce and
capital mobility, residents of countries with high rates of taxation may
easily establish, or pretend to establish, their tax residence or income
source in tax havens. Here are the main ways this is done.

The first way is by holding assets. A trust or corporation is set
up in a tax haven to hold assets, normally administered by a resident of
another tax haven. This

 means, in essence, that the nominal
owners of these assets are not residents of a highly taxed country,
enabling them to escape the tax burden that would apply to the real
owner. This method is very popular. In Ireland and Switzerland, for
example, total assets of these various subsidiaries work out to about
$4.5 million per employee of the corporation. In Barbados, it comes to
$22 million per employee, and in Bermuda to more than $45 million per
employee. (20)

A common tool for holding assets in a tax haven is the use of
international business corporations (IBCs). These are companies that
guarantee the owner’s anonymity, with no reporting requirements and
a registration fee of about $500. There are 500,000 IBCs in Hong Kong
and more than 60,000 in the Cayman Islands. (21)

Another way is by exporting commercial activities. Many companies
(or portions of companies) that do not require a specific geographic
location or qualified staff are set up in tax havens. Common examples
are insurance or

 (secondary insurance) companies with head
offices in Bermuda. Others include various financial corporations,
Internet-based firms and companies in the oil industry.

For example,
Deepwater Horizon

, the oil rig that exploded in the

Gulf of Mexico

 on April 20, 2010, was registered in a tax haven. The
Deepwater Horizon rig was leased by BP but remained the property of
Transocean, an
offshore drilling

 contractor. Transocean moved its
country of registration from the United States to the Cayman Islands in
1999 and from there to Switzerland in 2008. Transocean justified its
decision by the need to “improve our ability to maintain a
competitive worldwide effective corporate tax rate.” (22)

The growing scope of intangible assets within companies facilitates
the use of these stratagems. According to a study published in March
2007 by the consulting arm of Ernst & Young, intangible assets
accounted for more than 60 per cent of the value of Europe’s 100
largest corporate groups. (23) And it is relatively easy to justify the
location of patents, copyrights, rights to the use of logos and the like
in tax havens. In these cases, to export income to tax havens, all that
is needed is to show that the offshore company is the entity legally
holding the right to exploit these invisible assets. We have thus seen
Microsoft, pharmaceutical firms Pfizer and Bristol-Myers Squibb and
telecoms giant Vodafone relocate invisible assets and intellectual
property to Dublin.

An article on the Bloomberg news wire in October 2010 reported that
Google Inc. had reduced its tax payments by nearly $3.1 billion since
2007 and brought its international taxation rate down to a record low of
2.4 per cent. This tax optimization was made possible by a legal
technique commonly called “Double Irish,” which apparently is
open to various large companies in the technology sector, such as
Microsoft, Apple and

. In Google’s case, its use relies on an
agreement with the U.S. tax authorities on the transfer price of
intellectual property. It enables Google to benefit from a lower tax
rate provided these profits are not repatriated to the United States.

A third way is through financial intermediaries. Much of the
economic activity in tax havens consists of financial services provided
by mutual funds, hedge funds, life insurance companies and pension
funds. Funds are usually deposited with an organization set up in a tax
haven that serves as an intermediary and are then invested, most often
in the original highly taxed jurisdiction. Although such stratagems do
not normally allow taxation to be avoided in the taxpayer’s main
jurisdiction, they enable suppliers of financial services to offer
multijurisdictional products without adding an extra layer of taxation.

Efforts to overcome the scourge of tax havens

Banking secrecy for tax purposes came under scrutiny in a report on
access to bank information issued by the OECD’s working party on

tax avoidance

 and evasion in 2000. A Model Agreement on Exchange of
Information in Tax Matters was reached between the OECD and certain
non-OECD member countries in 2002. Since then, this model has served as
a basis for several agreements on exchanges of tax information
worldwide. This led, in 2004, to the first major revision of the
OECD’s Model Tax Convention, specifying that banking secrecy should
not constitute an obstacle to the exchange of information. (25)

Following the HSBC and Liechtenstein affairs and the recent
financial crisis, the issue of transparency and information exchange to
tax evasion

 has been the focus of new activity. The standard of
transparency and information exchange developed by the OECD is now
approved by all the main players. (26)

In 2009, the Global Forum on Transparency and Exchange of
Information for Tax Purposes approved a process of peer examination that
was set to last three years. All members of the Global Forum and all
jurisdictions listed by the Global Forum must be examined in two phases.
Phase 1 assesses the quality of each jurisdiction’s legal and
regulatory framework on information exchange. Phase 2 focuses on
practical implementation of frameworks. It was expected that, by 2014,
all of its more than 90 members will have gone through Phase 1 and Phase
2 examination. Canada was one of the first countries to be scrutinized
by the forum, and this examination found that the elements for effective
information exchange are in place. (27)

The European Union has emerged in the last few years as the real
leader in the worldwide fight against tax havens, especially through its
Code of Conduct and its savings directive.

The Code of Conduct for Business Taxation, in force since 1998,
provides an informal method of regulation that is much appreciated by
member governments. This code is not a legally binding instrument, but
it clearly has political backing. The countries adopting it agree to
eliminate various harmful practices in tax competition and prevent new
ones from arising. The goal is to ensure that all tax rules are applied
uniformly to each firm in a country, whether national or foreign.

The savings directive, (28) in force since 2005, provides that
income from savings in the form of interest paid in one country to a
resident of another country is taxed effectively in accordance with
legislative provisions in the country of residence. To this end, there
are rules favouring the automatic exchange of information between
governments. Since this directive does not cover corporate entities or
trusts, it can be circumvented by creating a trust in Jersey, for

It is worth mentioning that the EU provides a way to overcome tax
barriers faced by companies that operate in more than one member country
in its Internal Market: companies can be taxed on the basis of a Common
Consolidated Corporate Tax Base covering all their activities in the EU.
In this way, a group’s profit would be taxed only once in the EU,
and the proceeds would be divided among the countries based on an
agreed-on criterion. (29)

The EU had set itself a deadline of 2008 to come up with a
directive on corporate taxation, but Irish voters’ rejection of the
Lisbon Treaty in a referendum on June 12, 2008, motivated in part by the
threat it posed to the Irish tax system, delayed the project. On March
16, 2011, the EU finally produced its directive. (30) It aims for a
sizable reduction in administrative burdens, compliance costs and legal
uncertainties faced by companies in the EU in complying with various
national systems in establishing taxable profits. The common corporate
tax base would enable companies to use a one-stop scheme for their tax
statements and consolidate the profits and losses they record throughout
the EU.

In the United States, one of the government’s key tools is the
qualified intermediary (“QI”) program. QI status is a special
standing given by U.S. tax authorities to banks worldwide enabling them
to buy and sell U.S. securities for foreign investors. In exchange for
this, they agree to provide the Internal Revenue Service with
information on all income credited to American taxpayers who have
accounts with them and, above all, to collect tax for the

withholding up to 30 per cent at source on dividends or interest from
these investments. (31)

In March 2010, the United States adopted foreign account tax
compliance legislation that will oblige all financial institutions to
reveal to the IRS the identity of all clients of American nationality.
Clients who refuse to reveal their identity will face the automatic
withholding of 30 per cent of income from these investments.

In most cases, withholding will begin on or after January 1, 2014.
(32) The legislation has a far more extensive area of application than
the QI system (which will continue to operate) and will involve more
members of the public in an attempt to cover all foreign financial
institutions and not just the traditional sector of deposit-taking

Like other jurisdictions, Canada has instituted rules targeting the
advantages that accrue to users of tax havens. The key measures that
have been taken are: rules to manage the transfer price of
goods and

 transacted between related parties (e.g. corporations and
subsidiaries); restrictions on the deductibility of expenses; imposition
of a deduction at source when payments are made to beneficiaries living
in tax havens; rules for taxing income from a company or trust
established in a tax haven and controlled by a resident of a highly
taxed country; imposition of a departure tax when an individual, company
or trust ceases to reside in Canada; and compulsory disclosure to the
authorities of improper tax planning in which tax havens play a
prominent role.

In the 2007 federal budget, Finance Minister Jim Flaherty stated
that his government would crack down on those who avoid paying corporate
income tax by intensifying the fight against the use of offshore tax
havens. Canada has asked countries that are not signatories to a
convention to reach an agreement on exchanging tax information within
five years of a request by Canada to do so. If a territory accepts such
an agreement, corporate income earned in the territory by foreign
companies affiliated with Canadian companies will be exempted from
Canadian income tax. Otherwise, the income will be taxable in Canada as
earned. Canada was negotiating tax information exchange agreements with
various territories. (33) Among those signing deals with Canada have
been the Bahamas, Bermuda and the Cayman Islands.

Despite these positive actions, Stephen Harper’s government
seems ambivalent about tax havens, and some of its decisions have
received mixed reviews. Its 2010-11 budget contained a measure making it
possible for Canadian taxpayers to avoid tax on profits from the sale of
shares in Canadian companies by having them held through an intermediary
residing in a tax haven.

The various advances enumerated here have reduced the extent to
which fraud and tax evasion are protected. However, the problem remains,
and tax havens have not truly been challenged. It is necessary to go
further, and to act more quickly.


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A political movement beginning in the 1960s that blends traditional liberal concerns for social justice with an emphasis on economic growth.

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(1) (Confidentiality Integrity Authentication) The three important concerns with regards to information security. Encryption is used to provide confidentiality (privacy, secrecy).
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Hedge Fund
 in finance, a highly speculative, largely unregulated investment device. Originating in the 1950s, the funds “hedge” by offsetting “short” positions (borrowing a security and then selling it at a higher price before repaying the lender) against “long”
 Research Inc.,

HFR Huge Fast Router
HFR Hold for Release
HFR Hybrid Fiber Radio
HFR High Force Research
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At the home of; at or by.

[French, from Old French, from Latin casa, cottage, hut.]


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Brigitte Alepin is a Montreal chartered accountant and tax
specialist. She has been a tax columnist for CA Magazine and Le Journal
de Montreal. This article is excerpted with permission from Bill Gates,
Pay Your Fair Share of Taxes … Like We Do! [Toronto: James Lorimer and
Co., 2012), a translated and updated version of her 2011 book La crise
fiscale qui vient. It was translated by Bob Chodos, Eric Hamovitch and
Susan Joanis.