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Tax Secrecy is Dying a fast death.
Internal Administrator
Posted: Saturday, August 13, 2011
Joined: 10/12/2010
Posts: 5780


Posted: 11/5/2008 5:24:44 PM

By: David S. Lesperance

Last week I was in London presenting a paper. At the conference there was also a presentation by a well-known international tax lawyer who outlined a very convincing case that those individuals (both U.S. and non-U.S.) who are relying on “secrecy” and not proper planning, will all be uncovered within the next two years.

In an hour and a half presentation he set out in exacting detail how the combination of the Qualified Intermediary Regime (with help from the recent UBS scandal, new more in-depth disclosure obligations, and recent massive funding of the officials responsible for dealing with the now very forthcoming banks); the LGT stolen information (apparently there are other similar cases which haven’t hit the wide press yet); the European Savings Initiative; and the extensive and ever-increasing use of Exchange of Information Treaties (he is monitoring the OECD working group) will result in information that is uncovered by the Americans (through the Q.I. reporting or the Whistleblower Program) or any OECD country (through their own regimes such as the European Savings initiatives, or formal or informal whistleblower programs) being shared.

The net result is that Americans who have undisclosed accounts in any large or small financial institution (even if the institution has no U.S. presence) will have that fact turned over to the IRS. In addition, like dolphin in a tuna net, any non-American client with a bank account that has US dollars OR a brokerage account that has either U.S. stock or non-U.S. mutual/hedge funds that contain even a single U.S. stock will have that information first turned over to the Americans and then promptly shared with the account holder’s national tax authorities.

In an interesting exchange, when various members of the audience proposed what they thought were novel ways of hiding the beneficial ownership of the American account holder (e.g. obscure jurisdictions, instiutions with no U.S. presence, foundations, trusts, anstalt etc.), the tax lawyer not only had the ready answer to how this was going to be pierced, he actually had PowerPoint slides prepared showing how it would be done. As he so poignantly stated to one rather emphatic audience member, “I got these slides from an IRS agent”.

On the upside, he did say that given the fact that a voluntary disclosure only required the last few years to be disclosed COMBINED with the fact that capital gains over those past few years had mostly been wiped out in the recent market, that he was preparing several voluntary disclosures to the U.S. where the taxpayer was not actually paying tax. This was very interesting to both the presenter and myself, as we discussed, how I could then help these individuals expatriate after the voluntary disclosure, so that the rebound of their portfolio would occur in a legal tax-free environment.

He did state that if Mr. Obama became the President Elect (which occurred 5 days later) the ever tightening noose around tax evasion may be speeded up as a result of his wholehearted support for Carl Levin's Stop Tax Haven Abuse Act. His bottom-line was that people who have offside accounts should clearly understand that they have a unique opportunity to disclose before pending discovery which as a result of current market conditions may result in little tax actually paid to “come clean”. In other words, people with non-disclosed accounts should understand that doing nothing will certainly seal their fate. As much as they may want to just bury their heads in the sand, WHEN (not if) the evasion is uncovered not only will all the money be lost that was offshore, but it may also result in criminal and civil prosecution against the individual and their assets within the U.S.

I also wanted to share something that John Micklethwait, the editor of the Economist outlined, which showed the speed of change that can occur to completely change events even nearly 200 years ago. Most interesting is how wrong the common wisdom can be.


"The following headlines appeared in the French newspaper Moniteur in March of 1815. These banners announced Napoleon's return from Elba to Paris. What do they tell you about the return of Napoleon?

March 9 The Cannibal has escaped from his place of banishment.

March 10 The Corsican Ogre has landed at Cape Juan

March 11 The Tiger has shown himself at Gap. The Troops are advancing on all sides to arrest his progress. He will conclude his miserable adventure by becoming a wanderer among the mountains.

March 12 The Monster has actually advanced as far as Grenoble

March 13 The Tyrant is now at Lyon. Fear and Terror seized all at his appearance.

March 18 The Usurper has ventured to approach to within 60 hours' march of the capital.

March 19 Bonaparte is advancing by forced marches, but it is impossible he can reach Paris.

March 20 Napoleon will arrive under the walls of Paris tomorrow.

March 21 The Emperor Napoleon is at Fontainebleau

March 22 Yesterday evening His Majesty the Emperor made his public entry and arrived in the city. Nothing can exceed the universal joy."

Food for thought?

David S. Lesperance
Barrister and Solicitor



Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/7/2008 10:59:19 AM

By: Question

“recent massive funding of the officials responsible for dealing with the now very forthcoming banks”

Are you referring to the bank executives who have used tax payers money to pay themselves luxury trips and insane bonuses?



Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/7/2008 9:47:44 AM

By: Not so fast

“any non-American client with a bank account that has US dollars OR a brokerage account that has either U.S. stock or non-U.S. mutual/hedge funds that contain even a single U.S. stock will have that information first turned over to the Americans and then promptly shared with the account holder’s national tax authorities.”

I do not know how that would be possible since bank accounts and securities can be held by a nominee, a corporation etc.

Also for example a Trust that owns a Panamanian company that invests in a fund of fund in Asia and this fund of fund holds one fund that invest in US securities, how would the IRS know who is the ultimate beneficial owner?

And if true, that would be like shooting yourself in the foot. That would lead every non-American to dump their US cash holdings and US securities. Can you say hello to DOW 500?

What did the expert have to say about Delaware companies by the way? The next VP will not allow anyone to touch his State’s golden eggs.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/7/2008 7:45:54 AM

By: David S. Lesperance

Actually the lawyer gave an interesting new way of looking at one's planning. Instead of saying "onshore vs. offshore", it should be "non-compliant vs. compliant". In other words you can be offshore but compliant (which is good) or onshore and non-compliant (which is bad).

I wonder if David will want to change his newsletter to "Non-Compliant Alert"?

David S. Lesperance
Barrister and Solicitor

P.S. Interesting that there is no comment from the "usual suspects" challenging this analysis. Maybe they are afraid to go down in reality flames?


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/6/2008 9:15:41 AM

By: sorcerer

I have been offshore for 20 years. the thought that someone could hide this fact is ridiculous. only the bumpkins would try this. or those given advice from shady outfits ,e.g. the Sovereign society newsletter of yore.or tax lawyers that "really aren't all there in the head". automatically when you get an account,it is reported to someone. so if anyone was foolish enough to think that they got a "secret account",then they get what they deserve.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/8/2008 12:15:28 PM

By: David S. Lesperance

Mostly right EXCEPT that it is not offshore planning that is dying, it is non-compliant evasion that is dying. There are still go non-tax reasons (asset protection, transfer pricing etc.) to have a non-domestic element to a compliant structure.

David S. Lesperance
Barrister and Solicitor


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/8/2008 9:42:19 AM

By: Somebody who knows

The Levin-Coleman-Obama initiatives are all but certain now, and as David says there will be much greater pressure now for the offshore havens to open their records as to past transgressions in the interests of clawbacks of past tax moneys evaded.

Get ready for much higher fines for even simple noncompliance, and much harsher criminal penalties for willful noncompliance in relation to transfers to offshore havens.

Unless people are ready to physically expatriate and not just attempt to do so on paper, the compliance burdens will be made so heavy that offshore planning will be a thing of distant memory for U.S. citizens, and probably very soon for most E.U. citizens as well.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/8/2008 8:12:33 AM

By: David S. Lesperance

Dear OA: Are you saying that financial institutions are deciding not to be QI's (which I would have thought would have a significant limiting effect on their ability to buy and sell U.S. securities for any of their clients) or that having become QIs they ALSO decide not to take on US person clients because of the additional paperwork and regulatory hassle?

If the former, can you list for all the readers some of the viable institutions that readers might want to deal with

David S. Lesperance
Barrister and Solicitor


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/7/2008 2:07:33 PM

By: Offshore Atty

David-

I agree with you on the QI regime. However, it is important for people to be aware that not every bank participates in a QI arrangement with the IRS. In fact, many banks affirmatively choose not to participate because it's an expensive headache.

Bank secrecy will likely succumb to joint US and OECD demands to put tax evasion (gasp!) in the same category of horrific, malevolent, shocking international banking crimes such as drug money laundering and financing of terrorism.

...and then they will add evading parking ticket fines to the list... and then they will add not paying your cable TV bill to the list... oh, and if you mistakenly use imperial measures, they'll put that on the list of horrific financial crimes as well... and if you don't return that overdue library book, they will send the US Army after you... ...and on and on and on...


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/7/2008 1:07:55 PM

By: David S. Lesperance

Dear NSF: With the new rules that have been proposed (and which will pass) on QI, the tables have been finally completely turned. You need to re-orient your thinking to the new reality.

You ask: "I do not know how that would be possible since bank accounts and securities can be held by a nominee, a corporation etc. Also for example a Trust that owns a Panamanian company that invests in a fund of fund in Asia and this fund of fund holds one fund that invest in US securities, how would the IRS know who is the ultimate beneficial owner?"

The real question is one that the QI will now ask (and report to the US)as soon as there is any American stock in the woodpile (whether directly, through a fund, or a fund of funds of funds [which would have some pretty nasty fees I imagine]):

"We need to know the beneficiary or we cannot open or keep open this account".

Here is the exchange in your scenario:
-Who is the beneficial owner of the Panamanian company? The trust
-Who is the beneficiary of the trust? Individual X
-Please provide copies of the KYC documents for Individual X. If you don't like it then there's the door, and you will find the same story at any financial institution you would care to deal with.


Non-Americans who have compliant structures (with their home countries) won't really care. Non-Americans who have non-compliant structures can either a) become compliant with a voluntary disclosure; or b) remain non-compliant and limit themselves from the U.S. market (not smart from an investment point of view to limit yourself from the world's largest market) and then wait for their country to adopt (which they are all eagerly doing) QI like strategies. IOW: You can either voluntarily comply now or you can be forced to comply later.

You also asked ,what the expert have to say about Delaware companies. Well in general he said that there was a big political push for compliance both onshore and offshore. Trying to argue that the U.S. is unfair or inconsistent is a mug's game. Hell, a progressive tax system isn't "fair", but that's the way it is.

David S. Lesperance
Barrister and Solicitor


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 11:07:10 AM

By: Fear is the best salesman

Well I don’t know if the lawyer that is generating fear on this board for his business is aware that apparently you don’t go to jail for evading $200 million in U.S. taxes:

“Olenicoff get off with just one year of probation and a $3,500 criminal fine”

http://www.forbes.com/2008/04/02/taxes-irs-olenicoff-biz-billies-cx_jn_0402olenicoff.html

On top of that you have the potential to make a lot more money by saying “the bank made me do it”:

“Olenicoff seeks $500 million in damages — more than 10 times what he paid the IRS.”

http://ocbiz.freedomblogging.com/2008/09/16/billionaire-olenicoff-sues-ubs-over-his-tax-woes/


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 10:19:39 AM

By: Joe the Investor

“remain non-compliant and limit themselves from the U.S. market (not smart from an investment point of view to limit yourself from the world's largest market)”

Pretty ridiculous statement considering the US market is back where it was in 1997 and the US dollar has been in a down trend against other major currencies well before that.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 10:02:06 AM

By: Constitutional law professor

The fear mongering attorneys posting here have such dismal understanding of the rule of law that I would recommend to anyone to ignore their desperate attempts to generate new business for themselves.

Furthermore I would state that under the Vienna Convention on Treaties (1969) a treaty is void if its conclusion has been procured by the threat or use of force in violation of the principles of international law embodied in the Charter of the United Nations. This would encompass most TIEA forced onto small offshore jurisdictions.





Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 9:28:06 AM

By: David S. Lesperance

Fascinating arguments to make to one's cellmate, if you want to beleive this will save you from tax evasion charges which are uncovered because you stick your head in the sand about the impact of the QI regime uncovering your non-compliant undeclared account.

Same thing goes for those who want to argue the inadmissibility of evidence from LGT, because the information was stolen.

David S. Lesperance
Barrister and Solicitor


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 8:14:22 AM

By: Constitutional law professor

The Qualified Intermediary Program employed by the IRS is illegal on every ground of international law and U.S. constitutional law.

First, it offends the principle of comity between nations, it is in breach of UN Resolution 2131, and it is an agency-to-state treaty having no basis in law.

Second, it violates US constitutional law, having usurped Congressional Authority, and it violates rules of administrative law by failing to have regard for alternative arguments from the parties affected by its regulations.

Furthermore, it is an outright breach of a common law rule of international law and a law jealously guarded by the fifty states in America that provides that no state shall be obliged to enforce the financial laws of any other state.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/8/2008 1:00:30 PM

By: Read the Bill

The Stop Tax Haven Abuse Act will make it expensive for even compliant taxpayers to engage in offshore planning. The bill contains a provision permitting the Treasury Secretary to blacklist jurisdictions and thereby lock them out of the US banking system.

It is laughable to think that the US would lock countries like Switzerland out of the US banking system. Who will finance those extreme American deficits?

I smell an unfunded Social Security liability.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 3:25:36 PM

By: Pay up or go away

I think David should get 20% referral fee for any business generated through his web site


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 3:00:26 PM

By: Funny

“Interesting that there is no comment from the "usual suspects" challenging this analysis. Maybe they are afraid to go down in reality flames?”

Looks like the “usual suspects" took Lesperance down in flames


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 12:36:20 PM

By: Exactly

"Fascinating arguments to make to one's cellmate, if you want to beleive this will save you from tax evasion charges which are uncovered because you stick your head in the sand about the impact of the QI regime uncovering your non-compliant undeclared account.

"Same thing goes for those who want to argue the inadmissibility of evidence from LGT, because the information was stolen."

Exactly, exactly.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 11:50:54 AM

By: Note About Constitutionality

Something is only unconstitutional if the judges agree that it is unconstitutional, and so far there has not been even the slightest indication from the courts that either the QI rules or any of the offshore rules are unconstitutional.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/10/2008 11:34:12 AM

By: Offshore Joe

Whilst it is true that there will be more pressure put on offshore centers because executives of financial companies now rely exclusively on tax payers for their bonuses and their $5000 manicures, I believe that this crisis represents an enormous opportunity for those that provide safe havens. The traditional financial centers such as NY and London being on life support, new leadership will arise in places where this mess has been avoided.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/11/2008 4:28:35 PM

By: Note to offshore bashers

Note to offshore bashers: before you continue your bashing, I suggest you learn the difference between onshore and offshore, or you will continue making fools of yourselves on this board.

UBS gave US onshore bank client data

UBS has admitted giving details to the United States of US onshore bank accounts as part of a tax probe that is testing Swiss bank secrecy and UBS's reputation.

UBS and the Swiss finance ministry deny however any data has been transferred from offshore or undeclared bank accounts located in Switzerland that are key to the country's long-standing tradition of bank confidentiality.

http://www.swissinfo.ch/eng/news_digest/UBS_gave_US_onshore_bank_client_data.html?siteSect=104&sid=9958897&cKey=1226426145000&ty=nd


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/11/2008 4:19:35 PM

By: Down in flames

Looks like the offshore basher in support of david went down in flames too, jajajaja


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/11/2008 11:57:17 AM

By: Still wrong

Do you know what "U.S. onshore" means?

Now please take your ignorance somewhere else...


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/11/2008 11:30:05 AM

By: in support of david

Straight from the horse's mouth :

ZURICH (Reuters) - A UBS AG spokesman said on Tuesday U.S. authorities have requested U.S. onshore client data from UBS. The spokesman said UBS is complying with the request.




Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/11/2008 9:40:34 AM

By: Wrong Wrong Wrong

"UBS has already traded 70 clients to the IRS to be able to continue being in business ... Swiss banking business model is no longer relying on tax planning to increase base of deposits.."

Please stop the disinformation:

"ZURICH: Switzerland said on Tuesday that it had not passed Swiss-based account details of U.S. clients of UBS bank to the United States, which is seeking the information as part of a tax inquiry that may threaten Swiss bank secrecy.

The U.S. investigation, looking at whether the Swiss bank UBS illegally helped wealthy Americans dodge taxes, risks further damage to the lender's reputation as it is suffering heavy subprime losses.

A spokeswoman for the Swiss Finance Ministry, the only authority which can make a decision to pass on bank client data to the United States, told Reuters that Berne was still assessing the request.

"No data has been transferred," the spokeswoman said. "The procedure is still ongoing."

http://www.iht.com/articles/2008/11/11/business/10swiss.php


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/11/2008 2:51:48 AM

By: in support of David

I am one of the usual suspect that tends to argue with David, sometime objects to his position, and more than often appreciate his reasoned arguments (something that rarely prevails on a message board).

I would say that the landscape of the offshore industry is fast changing and the mass promoters of offshore "tools" are the dinausorus facing extinction. Ok, it is easy to promote doom and gloom in the circumstances but I back up my analysis with following arguments :

- OECD is quietly driving an across board and overall consultation over impact of a rejuvenating international taxation system on the wealth holders. I suppose that those that do not have the lobbying powers will be left out, including the median income taxpayers in the losers...

- The market of "financial intermediary" and more precisely those promoting offshore solutions is under intense scrutiny and I suspect that there soon will be some regulation about who can and cannot give advice about tax planning solutions. Attorneys, solicitors, accountants , as regulated professions, will come out winner.
It will be the end of the so called consultant that promotes/sells offshore shelters in the targeted markets...As to web selling, let just consider the position of the FSA (UK) about offshore internet banking to see that the loophole is already closed.

- Front page today in Switzerland is about the "remotegate" blip that enables the US authorities to sift through international money transactions undetected. End of secrecy period.
UBS has already traded 70 clients to the IRS to be able to continue being in business ... Swiss banking business model is no longer relying on tax planning to increase base of deposits..

So I like to make an analogy of the market to the cereal industry :

- You have the branded cereal makers : Private banks and giants like UBS, HSBC, Switzerland, Luxemburg and some other jurisdictions... They exploded after WWII and became leaders of the market of wealth management and tax planning;

- In the 80s exploded some minor centres that I would compare to generic cereal makers- They mirrored the business model of the former and addressed to a larger audience. Ultimately biting into the margins of the giants.

- Then you have practice such as David's, offering high end service and very specialised..They are the bio-tec cereal manufacturers commanding higher prices.

This is leaving us with :

- Branded cereal makers that see their margins eroded by competition and financial crisis, facing negative public image reputation. Rising cost to attract new clients and to retain them.

- Generic makers that have a mixed reputation as to cost/benefit and quality/price with a declining market.

The two categories above showing no sign of innovation when onshore have developped "fiscal niches".

- Bio-tec providers that might seize a portion of the market.

So maybe David's business model is not being burned down in flames but is a glowing beacon (and this is no pay advertising).

Now that we have taken care of the industry aspect, which is from where professional will derive fees and revenues, maybe we should consider the moral aspect of the situation which is TAX COMPLIANCE ADHESION.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/13/2008 3:33:33 PM

By: David S. Lesperance

Wow. Gone away on a business trip and then the board starts humming. I haven't read the other threads about the latest UBS indictment or Liechenstein yet, but did see that someone here claimed that the comments I made (which were reporting from a presentation given by a much more renouned and smarter lawyer than I) that non-compliance (aka tax evasion) will be outed very quickly were "shot down in flames".

Maybe I am a bit slow, so can you please spell out the counterarguments clearly for me. That would be a bit more convincing then some blanket statement that my reporting was incorrect.

Thank you.

David S. Lesperance
Barrister and Solicitor


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/13/2008 12:11:27 PM

By: Baseless accusations

Baseless accusations are easy to do on this message board. What they really show is the desperate state of the bashers.

"It would be just like the Swiss to cooperate with the tax authorities behind the scenes, while telling their customers/marks that their information is 100% confidential."

On what basis are you saying this?

Now if we were talking about WMD in Iraq you would have a case...or "not having sex with that women" etc.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/12/2008 10:36:48 AM

By: Just like the Swiss

It would be just like the Swiss to cooperate with the tax authorities behind the scenes, while telling their customers/marks that their information is 100% confidential.

Don't trust them.


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/12/2008 4:13:06 AM

By: in support of david

And just to add to the subject for the fools that still believe that privacy will be upheld by the swiss banks against their own interest while they want to remain in the QI programme

quote from IRS
In addition, banks using foreign-based external auditors, including foreign branches of United States auditors, will have to work with an American auditor, which in turn will accept joint responsibility for the audit.
Unquote

So I would appreciate my bashers point out to me which auditors (supposedly a big five) will accept such liability to the IRS...


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/12/2008 3:56:04 AM

By: in support of David

come with serious rather than wishful thinking..You are basically saying that Swiss banks are reneging, with assistance of authorities, to their qualified intermediary status...

Just for your info :

US probe into UBS offshore services may lead to indictments.

http://www.wealth-bulletin.com/home/content/3452447079/

"U.S. investigators are concentrating on senior and mid-level executives and bankers, the paper says. Monday, the Washington Post said names of 70 U.S. customers had been handed over to U.S. authorities.

UBS wasn't immediately available for comment.

Earlier this year, the Zurich-based bank sped up the closure of its private banking services from Switzerland for Americans after the U.S. began probing allegations of tax evasion.

The decision was disclosed in July by Mark Branson, financial officer of UBS's wealth-management and business-banking unit, during testimony before a U.S. Senate hearing into how banks allegedly help wealthy Americans hide assets.

-Zurich Bureau, Dow Jones Newswires; +41 43 443 8040"


And if you are apt readers (doubtful) go to the New York Time web page that runs the story.

The bank has given the name of 70 US clients that have wired money from their US bank accounts (onshore) into their Swiss bank accounts (offshore).
The datas that have been passed where covered into the subpoena of the DA, not a fishing expedition then that could have been squashed... The denial that the bank privacy rule of Switzerland has not been breached is purely rethorical and technical : "not swiss based datas" as the spokewoman for the bank said... Tell that to the clients I am sure they will appreciate the thin distinction...


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/14/2008 8:33:37 PM

By: David S. Lesperance

Yes you are right. One lame offpoint comment, a quick shout of victory and then scurry back to the hole before anyone can laugh. Not quite the devastating rebuttal one would hope for from an advisor in an audit or legal proceeding.

David S. Lesperance
Barrister and Solicitor


Anonymous
Posted: Saturday, August 13, 2011

Posted: 11/14/2008 3:13:34 AM

By: in defense of David

David, there is still some people that bury their head in sand and refuse to acknowledge the changes in the landscape of tax planning.
I would divide the board on this post in 2 camps :

The self righteous that believe privacy is a God given tool to the enlighted Swiss bankers to pursue a business model attracting clients wishing to evade tax (without admitting such assistance). They thus set down in flames all other counter arguments (yours or mine) in a pure and typical Calvinist tone.

The "down to earth", agnostic, relying on a bundle of facts that point to an end of such business model ... There is no moral involved but rather where and how to move into this changing market ...Probably acknowledging as well the shift of power and decline of the Swiss market in this...


 

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