Different deferral provision allowed companies to stockpile an estimated three point one trillion years dollars offshore and some of them for example apple have already said that they they would be paying those taxes directly in the United States you just said that it is a statistical irrelevance as far as the Cayman Islands. Are concerned but i wonder if this shift in the u. S. Taxation regime may alter the course of globalization in any way surely arlen should be feeling the pinch or do you think. Truly island should although there are other reasons why arlen has been successful particularly you know and efficient and low cost labor force. But the you know bear in mind the three point one trillion number you mentioned came about because u. S. Law wanted us corporations to be able to defer tax offshore because it. Operated what was known as a capital export neutrality system and if it hadnt allowed for the deferral us corporations would under the previous law have been taxed twice on the global profits and therefore been noncompetitive with with say european corporations which was only tax once now in the us they they have just found under the tax cuts and Job Performance theyve just amended that structure so that us corporate for now be taxed only territoriality basis that is to say in the jurisdiction where they make the profit and therefore there isnt as you rightly say towards globalization because that brings us corporations Global Trading profits more into line with the system that has operated for say european corporations which are also taxed on a territoriality basis well miss a traverse you just said that this deferred taxation regime was intended and in fact it was promoted by the American Government but at the same time the previous American Administration was very critical about it and i think thats the most ironic thing in all of that for me that these kind of changes were implemented not by the Obama Administration which one would think ideologically would have been most predisposed to it but by the time put ministration your opinion it wasnt ultimately an issue of political will corporate might have perhaps something else. I have to say i agree with you i am completely confused about why a Republican Administration made a change that was essentially part of the democratic philosophy and which the democrats have been frustrated about try to change for well over fifty years i can only think that sound way deep within what they call the deep state in the us treasury there were left leaning. Bureaucrats who who implemented this change to a territoriality based system of taxation without anybody actually being aware of what was going on. But it is i agree with you very hard to ricks blame in terms of the the political positions of the two us parties historically well mr travers i think you would agree that as a flayed mary Many American political positions are extremely hard to explain from a rational point of view but we have to take a very short break here lets go back to the discussion in a few moments they chant. Manufacture consent to public will. When the ruling classes protect themselves. In the final. Week nor middle of the room. Welcome back to worlds apart with Anthony Travers senior partner at an offshore law firm based in the Cayman Islands and just before the break we were talking about the United States finally returning to the territorial principle of tech taxation and some would argue that the. Americans want to take it there even further there is another standing initiative aimed at the repatriation of taxes im talking about before an account Tax Compliance act which compels non the u. S. Financial institutions to report on the assets of both u. S. Citizens and the u. S. Residents worldwide do you think trump is likely to make it work and dont you think that perhaps this territorial principle. May be taking way too far with essential of the extraterritorial nature of that act well i think think there are actually two quite Different Things moving us corporations to a territoriality based system of taxation with regard to Global Trading activity is one thing. The foreign account Tax Compliance a whole fat corrosive snow was directed at something quite different that was directed at ensuring that u. S. Citizens who are also tax on a citizenship basis. As were u. S. Corporations pay taxes on overseas and so what fat did was ensure that u. S. Citizens outside of the United States have to report on all accounts that they maintain outside the United States to cherish its not just about the american citizens or residents reporting on those accounts i want to with understand that but its about the making norms u. S. Financial institutions essentially be responsible for. Implementing that reporting in turning the branches of foreign Financial Institutions essentially into subsidiaries of the i rest dont you think thats a bridge too far now rio i agree with you i was describing what fact was intended to do what you just said is absolutely correct the way it is implemented is to do effectively make known u. S. Banking organizations or u. S. Banking organizations operating overseas as effective tax collectors for for the i. R. S. And there is worse legislation that has now come out of europe called the comma reporting standard which does exactly the same thing as between about ninety countries now that have signed out to it and clued in to that russia which requires those ninety countries to make automatic reporting to the home jurisdiction of every investor who has an account in a signatory jurisdiction so for example if we have russian. Citizens with accounts in the Cayman Islands we must ascertain against the of those citizens and make reports on their trading profits in any Cayman Island account to the russian authorities. I will tell you why the russians see at least the majority of the russian people and that the some part of the russian government dont see much problem but that is because they believe that the main purpose of legislation is to provide a more intense Information Exchange between tax authorities well but at least theoretically at least would make tax evasion which is a huge problem for this country a little bit more difficult especially as the new Technology Come on board then expedite this process is it too naive to suggest that big golden era of hiding assets especially ill gotten assets which is the problem for russia for example is slowly but surely coming to an end i think its absolutely right. I would say that it had come to an end in the Cayman Islands almost twenty years ago when we entered into the tax Information Exchange agreements for tax evasion which is what youre describing now. That was off the table for at least twenty years and that came at all it just was not possible to do it because of the ability of tax or thought has to make inquiry under the treaties the common reporting standard takes it to a new and higher level by requiring proactive reporting with regard to those accounts of any known resident of the Cayman Islands back to the tax authorities in question so i think youre right it is true to say that not every country in the world is a signatory of the common reporting standard fatca operates in relation to the United States only it is extraterritorial globally as a matter of u. S. Law to cover reporting said operates differently by way of a multilateral treaty and i would say that youre absolutely right it makes it virtually impossible now to evade taxes by way of known disclosure in a criminal way by use of any offshore account now you know i have a few friends wealthy relatively wealthy individuals who complain. And thats where this is how they call themselves starting to feel like refugees around the world and i understand thats a preposterous suggestion but it does relate a certain degree of desperation at the inability to find a home not just for yourself but for your capital and sometimes the origin of that capital is quite questionable youve been very forthcoming in saying that the Cayman Islands is stressing the transparency of the Cayman Islands and i believe it to the times just as network to verify your claims but i wonder if you believe there are still destinations in the world that may provide a drive to reach for the for the people who fill. They are not welcome in countries like iraq for example i dont think i dont think that people who hide their money should be encouraged and i think its going to be extremely difficult for them to do so but i do have the answer for them if you are a russian citizen and you want to avoid paying russian taxes then you must come and live in the Cayman Islands because russia also applies a territoriality based system of taxation and the problem is is out for High Net Worth a High Net Worth individuals who want to live in london paris or new york and not pay the a placable taxes as a result of doing so that game i think is effectively overwrought right here much as you say. So the answer therefore is that you actually need to take up residence in one of these indirect taxation jurisdictions and in that way you will be able to protect your assets and not pay Income Corporation profits or Capital Gains tax but that is i think the only legitimate way of doing it now now im not sure you should distribute such a such device especially for free on the airwaves but anywhere you mention london and there is an Interesting Development in that regard in the u. K. We just passed an order allowing the authorities to freeze and recover property in excess of fifty thousand pounds if individuals are unable to explain how they acquired those assets and it strikes me as a brilliant idea making the government the ultimate beneficiary of the large scale Money Laundering scheme that has been going on in london for decades what do you make of it do you see them the same light yes i mean i think i think the issue is this firstly its clearly borne out of frustration. Because the the problem the author or his have is this that the way the International Network works for Law Enforcement on Money Laundering. Requires you to have a preliminary if an offense committed in the in the jurisdiction of the residence of the individual for example russia or or the hypothetical african state ruritania you have to have a predicate offense there for the international Money Laundering system to work and thats whether thats where the system is broken down because even after Panama Papers panama was a jurisdiction with no transparency which was very popular with money or grows. Even out of Panama Papers you five very very few criminal offenses now in the originating jurisdictions. And until you have an offense in those jurisdictions the International Network of information gathering cant operate and so what the United Kingdom legislation is down is reverse the burden of proof but you know if there isnt an additional thing even if there isnt an information about you committing some crime in your original country you can always claim to political prosecution and in fact a number zero for russian bankers who stole money from the people on the very large scale doing exactly that in the United Kingdom it would be interesting to see whether the authorities will be able to go after them but i want to ask you something did different because youre always on the defensive when it comes to people from the u. K. Or the United States preaching transparency or you know taxes on avoidance but i think its also fair to turn the tables around because its not even controversial to say anymore that london and new york have become the largest offshore destinations i mean its its its i guess a statement of fact that in this day and age what do you think the most motivates the british authorities to pull the plug on it now to pass that low at this point of time did they finally find the courage to do that and that address the problem or is it just an opportune moment to fill the state coffers well i think youre absolutely right i mean no money launderer invests his proceeds in an offshore jurisdiction mr malkovich invested his seven billion dollars a lot of proceeds through new york missed a batch of the nigerian dictator vested his his four billion pounds in this in the city of london money orders need things to buy they need houses on the east side or in belgravia london says the ultimate destination for these proceeds is always being the on the shore capitals i think that that is all of a sudden a new age if you like you might call it political opportunism. By it is. It has become politically very incorrect to be a jurisdiction like london. And less so new york strangely but like london where this kind of. Cover a range meant is is is tacitly accepted by view authorities and i think its extremely difficult for the british or thought he is given the transparency theyve insisted on interesting like the Cayman Islands they have a double standard not to apply the same level of transparency with regard to. Places like london where these proceeds are actually loaned the special interest in this the charas because they dont seem to be losing much theyre only gaining as i said i think if that scheme is implemented at the end of the day the British Government will be the ultimate beneficiary of all those ill gotten assets because it can claim it for itself. Maybe maybe not i mean a government will claim it it may be the British Government will have to hand those money so its a Money Laundering occur for that if you need to cleanse ahmed rashid nation and that goes for years if not decades and theyre also political issues involved so its easier to keep it for yourself and for your budgets and thats where i think thats a really brilliant idea. Well it may it may if may well be as i say you know im not here to defend the way the system of international Law Enforcement works because we know it doesnt work. Its quite clear you know when i started in the offshore world over forty years ago it was said there were two trillion dollars of black man a king annually and the still two trillion dollars of black money circulating annually so im not sure what evolves is of really being made. But i do think there are there are systems if money was lorded out of nigeria if the British Government confiscates it in britain there are systems to ensure that money is paid out at the request of the nigerian authorities so its not its not just a smash and grab operation by the British Government well lets hope for that and lets hope that the price of russia as well anyway mr travers that we have to leave it there i really appreciate your being on the show and our viewers please keep the conversation going and social media pages as for me i hope to see you again same place same time here and will depart. I am yes. I am. I am. I am i. My. Syria calls on the un to hold the u. S. Led coalition to count. The targeted progovernment forces Central Command says the attack was to defend an american backed group. Final day before the start of the Winter Olympics and dozens of russian athletes are still awaiting a ruling on whether or not they can compete in south Korea Tensions over the games. As norway now faces doping allegations. Republican lawmakers in the u. S. Off threatening to cut funding to a Global CancerResearch Program americas most widely used killer business. Cancer. Great to have you with us this. This is our international. Syria has called on the u. N. To hold the u. S. Led coalition to account for wednesdays airstrikes against progovernment forces the number of casualties thats not yet been confirmed but some reports claim that up to one hundred people may have been killed u. S. Central command described that attack as a defensive move Russias Defense Ministry said the unit was hit as it was carrying out an operation against that i still sell. While carrying out an operation to locate and terminate an eyesore sleeper so near form oil refinery a unit of progovernment forces was suddenly shelled and then hit by airstrikes by the u. S. Led coalition vis was overkill if the numbers are true i would see a demonstration of she have brute force perhaps you know to send perhaps the send a message nevertheless the United States says that its its in syria and it will defend itself and it has the right to defend itself in this instance Syrian Democratic forces acted in self defense with support from the coalition to defeat an unprovoked attack by Syrian Forces in Eastern Syria if the situation is like how they describe that they were indeed attacks while fighting isis is then i have the right to self defense well if you take them at face value you could think so but the people they just killed were also fighting isis and recently they had been making much better progress against isis then the United StatesLed Coalition or their Partner Forces the the s. D. F. The Syrian Government has of course called all of this an act of aggression unwarranted and unjust but just for your information all of this happened in there is or near a rich oil field and refinery chronicle its called it was liberated last year by the u. S. Led coalition very quickly and in fact. U. S. Partner forces seem to have a knack for liberating areas with oil under them much quicker than they do those areas that dont have oil under them since since all the oil rich areas were taken in there as ordered by the s. D. F. Progress against isis seems to have dropped to a snails pace but you know regardless. Here america has said that it is in syria only to fight isis today isis has been all but defeated in syria but you dont see the pentagon packing its bags our military policy in syria has not changed our priority remains to defeat of isis whether its in iraq or in syria that is our intent to defeat isis and not do anything more than that the United States will maintain a military presence in syria focused on ensuring isis cannot reemerge total withdrawal of american personnel at this time would restore assad continue his brutal treatment against his own people so as to principal only but if the lack of a fundamental commitment to our agreement is typical of current u. S. Diplomacy including the reasons why the americans stay in syria Rex Tillerson peter he stated that their only goal in syria was the defeat of ice or now theyve got far more ambitious plans with more of the most with the mixed messages here is the pentagon staying general mattis said that the United States will stay in syria well fight in syria for as long as the United States wants to fight in syria i mean thats you know pretty direct now you see how this might sound strange going to syria and the vital and while there you start killing syrians in syria in selfdefense. Lets person told us that with Islamic State practically gone now from syria washingtons targeting the countrys government instead. They are not just in syria to fight their own so. I have been in syria for a long time because they want to throw our side as the spate of feeds as it becomes clear that it is the Syrian Forces themselves and largely defeated di age the priority of overthrowing assad begins to reassert itself in the pentagon and in the white oh so i think thats true the answer the question the overthrow of assad was always the probably got prominent reason why the americans were in syria the army in treating these groups intervening with air strikes and sword they were diverted from that by no with the possibility of a defeat of diet inside syria that policy that reasserts itself this is coming at the end of a long war the United States has taken about twenty eight percent of syrian territory and over fifty percent of its oil this is led british in order to roll back iran and get rid of us on our side just like if he wants to do well for himself there was a race only a few months ago that would get those fields and hes broadening undoubtedly under the pretext of biting isis the United States didnt think it was so the United States is trying to lay down the law here and not let anybody pro and as we know the turks threatened in mendo to take on the americans over there so the United States i think its very patience that both syria and turkey will begin to push america out try to push america out of Northern Syria but he likes. The start of the Winter Olympics in south korea is just stunned a day away now but the fate of dozens of russias athletes still hangs in the balance forty seven sports men and women from russia have appealed to the court of arbitration for sport to overturn the decision over alleged doping violations that ruling is due to be in. On friday and among those who filed appeals are some of russias most celebrated athletes for example six time olympic Gold Medalist victor on also sort she games champion and dont shoot pool in aunties elaborate trying to reports from the olympic host city of pyongyang. For almost two and a half hours the court of arbitration for sport was listening to the russian side which have now left led by their lawyer so these people wont get another chance to give their arguments to the court and now it is all up to the cast members they promised to announce some sort of decision by noon korean time on friday to go over to the phone we came here to defend the caspar listen to our arguments and the decision will be reached within twenty four hours so things wont be decided to with a few hours before the Opening Ceremony which of course puts extra pressure on the russian athletes on wednesday the secretary general hinted that still their mind to be at delay now here we are looking at three scenarios either cas decides to do nothing about the International Olympic committees move not to invite the russian athletes who have never been caught for cheating and without specifying particular reasons for doing that or the court of arbitration for sport chooses to give the green light to the russians and in that case that would be a massive blow for the audio scene and that would in turn mean that the International Olympic committee discriminated against the russians the third scenario we heard about from an online leak that cannot be confirmed but reports are suggesting that there could be a split decision on the russian athletes im standing by here at the temporary home of the court of arbitration for sport and ill give you any news as soon as it comes out. Showing the support for russian athletes sports fans are protected the light show on to a building opposite the World Antidoping Agency had quote in canada and the message that said the only doping among the Russian Olympic Team is the support and love of russian people russians are coming. But athletes use participation in the games is not in question they are now too embroiled in controversy after a documentary published a list of drugs norways team doctor brought to pyong chang a remarkable amount of ass medication was noted six thousand doses in fact they contained obviously banned substances ten times more usman drugs as well for example neighboring finland had brought to south korea and the quantity of asthma medicine is raised a lot of concern most of these drugs contain substances that have been banned by wide open watchdog argues they can enhance an athletes performance by expanding lung capacity the norwegian Anti Doping Agency has also admitted the country has a problem with the over use of asked medication it is common practice in norway to occasionally use asthma medicine in major elements in the respiratory system even with the diagnosis vastly is not specific of the latest revelation that comes after the release of a documentary that alleged the existence of an organized doping system at Norway Ski Federation we spoke to one the journalist behind that film the region ski federation is very angry about this and they dont want to talk about this problem