Treasure Islands - Nicholas Shaxson [146]
55.See Hogan speaking on video, embedded in “Hogan Loses High Court Battle to Keep Financial Records Secret,” Sydney Morning Herald, June 16, 2010.
CHAPTER 2 TECHNICALLY ABROAD
1.Philip Knightley, The Rise and Fall of the House of Vestey (London: Warner Books, 1993), p. 8.
2.Cain and Hopkins, pp. 150 and 157; statements in June 1929 and October 1929 by ambassador Robertson. The Argentine beef industry relied almost exclusively on the British market for its exports; by 1929 Argentina generated about 12 percent of Britain’s income from overseas investments.
3.Charles Edward Russell, The Greatest Trust in the World (1905; reprint New York: Arno Press, 1975).
4.Rodolfo Roquel, Nosotros, los Peronistas (Buenos Aires: Dunken, 2005), p. 34.
5.Vestey Group History, Vestey Group website, http://www.vesteyfoods.com/en/vesteygroup/vestey-group-history.html.
6.Knightley, The Rise and Fall of the House of Vestey, p. 63.
7.Ibid., p. 27.
8.Leslie Bethell, ed., Cambridge History of Latin America, vol. 8 (Cambridge: Cambridge University Press, 1991).
9.“A: The Secretary of the Treasury,” Washington, D.C., May 29, 1937, from Henry Morgenthau to FDR, from Franklin D. Roosevelt Presidential Library; given to author in 2008 by Morgenthau’s son Robert Morgenthau, then Manhattan district attorney.
10.For instance, in 1899 the state allowed corporations to own equity in other corporations, setting the scene for the emergence of large, interlinked networks of companies, the multinational corporation, and transfer pricing activities.
11.Some of this analysis is derived from Ronen Palan, Richard Murphy, and Christian Chavagneux, Tax Havens: How Globalization Really Works (Ithaca, NY: Cornell University Press, 2010).
12.Most accounts say it was Bedford Gunning Jr. who made that statement at the constitutional convention.
13.When Britain decided to tax the worldwide profits of any person resident in the UK, the judges decided that in the case of corporations they should be treated as resident where the company’s most important decisions were taken, at meetings of their boards of directors. This suited Britain, since thousands of firms with activities all over the world were financed through the City of London, and their boards were normally located there. Germany, by contrast, placed more emphasis on the “seat of management”—that is, where the company’s actual operations were managed—a subtly different definition. For more on this history, see Sol Picciotto, International Business Taxation (London: George Weidenfeld and Nicholson Ltd, 1992), pp. 4–13.
14.Until then, tax had not been a big issue for the Vesteys because Britain did not tax British-based companies on profits they made overseas—that is, unless they repatriated these profits. This had suited the brothers, who argued that most of their profits arose overseas.
15.Picciotto, International Business Taxation, pp. 1–37.
16.Knightley, The Rise and Fall of the House of Vestey, p. 34.
17.Some tax havens claim that trustees are required by law to know the identity of all beneficiaries. Contacts indicate, however, that generally offshore jurisdictions do not adequately police these laws, and trustees often do not know the real beneficiaries.
18.The U.S. Internal Revenue Service sums it up quite simply: “Although these schemes give the appearance of separating responsibility and control from the benefits of ownership, as would be the case with legitimate trusts, the taxpayer in fact controls them.” See Internal Revenue Service, “Abusive Trust Tax Evasion Schemes—Facts (Section I),” June 12, 2008, http://www.irs.gov/businesses/small/article/0,id=106537,00.html.
19.Vestey’s (Lord) Executors and another v. Inland Revenue Commissioners. Same v. Colquhoun (Inspector of Taxes.) Same v. Inland Revenue Commissioners, All England Law Reports, May 28, 1949, p. 1108.
20.Sol Picciotto also describes this in his “Offshore: The State as Legal