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Non-Tech : Shorting with Offshore Accounts -- Ignore unavailable to you. Want to Upgrade?

To: Philip S. LaMar Jr., J.D. who wrote (27)	2/20/1999 2:01:00 PM
From: Colin Cody	Read Replies (2) \| Respond to of 127

Philip, Re: when there is no legal connection between an individual and a structure there is nothing to report. This requires that there not be control,indices of ownership or any relationship between the individual and the structure other than one which is truly "arm's length." How would such "a structure" be funded? Assuming there are few sugar daddies out there funding offshore accounts, this pretty much leaves the "individual" himself to do the funding. Transferring assets by gift is subject to federal and some State gift tax provisions, I believe. Additionally transferring assets out of the Country (U.S.A.) is subject to some newly enacted tax, as I understand it. Transferring assets "in exchange" for an equity interest in "the structure" would bring back the control issue. Are you saying the "individual" should pay these taxes and then work with the net funds remaining "at arms length"? Colin