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GreenTrader Weblog
GreenTraderTax & GreenTraderFunds
September 1, 2010
Can American off-exchange retail forex traders evade strict new CFTC rules by trading on offshore platforms?
Congress and regulators have thrown the forex trading industry a huge curve ball and we are all scurrying to get answers to important questions.
Many questions remain regarding trading offshore to evade leverage and other constraints posed by the new CFTC rules. Today we try to answer a few more questions along these lines. The answers are still unclear, and we await new NFA guidance, which was promised to one forex dealer executive. A forex dealer executive told me the NFA may actually be waiting on the CFTC regarding the overseas issue, and he expects it will take more than a few days. The overseas firestorm is probably underway.
According to one leading forex broker executive, the CFTC author of these new retail forex trading rules said the Dodd-Frank (DF) change classifying financial institutions (FI) as "U.S. only" (see CFTC Q&A "who can offer.." section) won't be made for 360 days from DF enactment (7/21/10). This gives EU banks offering forex trading to U.S. customers time to register in the U.S. But I think FI refers to banks and not CFTC-registered FCMs, which probably include the FDMs (forex-dealer merchants, the prior designation) too. The DF list has FI, SEC-registered and CFTC-registered companies, plus insurance companies and more. FI and FCM seem to be different categories.
So if this forex broker says its U.S. retail forex traders using offshore platforms from its affiliates have more time to close accounts, that may not be true in my view. If the foreign account is deemed a foreign affiliate of an existing CFTC-registered FDM, then using the 360-day extension seems inappropriate to me for financial institutions. If it's a foreign institution such as an EU bank with no U.S. CFTC-registered FCM or FDM registrations, then maybe it’s okay to use the 360-day extension.
Hopefully the NFA and/or CFTC will clarify this important issue soon. There are plenty of people asking these important questions, as thousands of Americans have offshore retail forex trading accounts.
It makes sense to me that DF gives 360 days to foreign institutions to form U.S. affiliates if desired. To spring a prohibition on foreign financial institutions offering forex trading to U.S. customers as of Oct. 18, 2010 (the effective date of the new CFTC rules) would be extremely undiplomatic on a global country-by-country dealing basis. There may be lawsuits and diplomatic requests made and this takes plenty of time to deal with properly.
This type of financial transaction/trading protectionism is rearing its ugly head on several international stages already. The U.S. is upset about EU rules and proposed rules requiring U.S.-based investment advisers to register in the EU for a required "passport" to raise money from EU investors. This is a huge problem for the U.S.-based investment-management industry. EU banks are upset about new U.S. “FATCA” tax rules requiring EU banks to report to the IRS U.S. customers in their ranks. FATCA ties in with this FI U.S.-only forex trading rule too, as it can help enforce it.
According to the forex dealer executive I spoke with, the NFA plans to issue a notice to members perhaps today or in a few days to clarify DF and the new CFTC retail forex trading rules, mostly for implementation issues. This expected notice may not speak to the foreign trading issues, although hopefully it will.
One big implementation issue is how currently CFTC-registered FDMs (under CRA) go about converting their registrations to the new DF-category of RFED. Will this be automatic? How can FDMs make many changes in their registration by Oct. 18, the implementation date for the new CFTC rules?
This executive said many U.S. forex dealers currently use offshore platforms and affiliates for segregation of funds in the UK for asset protection purposes. He said if a person files for bankruptcy in the U.S., their UK forex trading account capital and rights are protected from U.S. bankruptcy courts. Leverage is unlimited in the UK, but usually 100:1. U.S. customers avoid the NFA's controversial hedging rule when trading in the UK. He said capital isn't a big issue because many U.S. forex dealers can absorb more U.S. customers to repatriate from the UK and other international affiliates. I presume leading forex dealers can move UK capital back to U.S. too as needed. This executive says non-residents (international business) may want to stay in the UK since the U.S. leverage is lowered to 50:1. He said U.S. platforms can handle things. The biggest concern is upsetting some U.S. clients who already set up foreign-based accounts and now may have to redo all the paper work back into the U.S.
U.S. FDMs in the forex dealer coalition are fine on these new rules per this executive. Most are already registered as FDMs and compliant with the NFA, and 50:1 leverage is reasonable in their view. They expect the RFED change to be fairly easy to accomplish.
I see a big problem for foreign forex dealers operating from tax havens. Most don't have U.S. operations or branches and they won't want to register in the U.S. Registration for foreign companies probably requires a U.S. operation, subsidiary or branch office designation. Branch office taxes can lead to trouble on Section 482 transfer pricing tax issues (where the profits are booked). If the IRS finds trouble with tax haven cheating, it can pounce on these institutions. Therefore, I presume many tax-haven forex dealers may lose forex trading business to CFTC-registered RFEDs who will be happy to win back this business.
Forex IB (Introducing Broker) CFTC-registration changes are important too. The final rules are better than expected from the proposed rules. With final rules, a forex IB can simply register with the NFA on its own in the same manner as futures IBs do now. They don't need that troublesome (proposed rule) guarantee from an FDM, although they have that choice too. Few FDMs want to take that kind of risk or tie up their capital by guaranteeing a forex IB.
There are many characters in the forex industry that inappropriately blur the lines between education, investment advice, money management and other related services. Many of these forex players may be drawn into registration in some capacity with the NFA and CFTC, perhaps as an IB, and many will want to avoid that registration for many different reasons. Some may have trouble passing NFA back ground checks. Others don't want the NFA oversight over their perhaps fraudulent or inappropriate business models. Many don't want to be burdened with other rules like disclosure and reporting. Many will surely have trouble with the conflicts of interest rules too.
My colleague Brent Gillett, JD and his associate at the Investment Law Group wrote an article on these rule changes. It includes a nice history of regulation (or lack thereof) of off-exchange retail forex, the new registration categories and how it works. It's a good primer on the subject.
The attorney and author of this article said to me via email: I spoke with an attorney at the CFTC Monday who is dealing with these rules. His interpretation was that because of the change to the CEA by Dodd-Frank from "financial institution" to “U.S. financial institution”, overseas forex intermediaries that are not registered as FCMs or RFEDs will not be able to serve as counterparty to U.S.-based retail investors with respect to OTC forex transactions. This would apply to futures and options and futures “look alike” contracts. I say that the enforcement issues are unresolved in our article both because of the practical realities involved in enforcing this rule and because this was just an opinion of one regulator, not of the Agency.
Excellent comment on our FaceBook page:
Robert: I spoke with both the NFA and the CFTC by phone. The most knowledgeable was a guy in the compliance dept at the CFTC. He says the rules apply to any brokerage, foreign or domestic, that wants to do business with U.S. traders. So, while the regulations are not aimed at traders themselves, they are indeed aimed at any/all brokers that do business with U.S. traders. In other words, if we have accounts at FXCM UK or Dukascopy (Switzerland) or anywhere else in the world, the CFTC will force those brokers to change our leverage to 50:1. The only good news I heard was the definition of what the "major currencies" are. Apparently the NFA has a list of what it considers the major currencies. This is in the Financial Regulations section of the NFA manual. The link is here: http://www.nfa.futures.org/nfamanual/NFAManual.aspx?RuleID=SECTION+12&Section=7 . Fortunately this includes (in addition to USD) the EUR, GBP, JPY, CHF, CAD, AUD, NZD and even the Norwegian, Swedish and Danish currencies. In other words, any currency that retail traders are likely to trade will be at 50:1 not 20:1. I can live with that. I'm not happy about the excessive intrusion of our government into our business, but I can live with this.
New CFTC forex trading rules call for 50:1 leverage
The CFTC has published its highly anticipated final rules for trading off-exchange retail forex. As discussed on prior blogs, the recently enacted Dodd-Frank Fin Reg bill forced the hand of the CFTC to act by Oct. 19 because it would otherwise bar non-eligible contract participants from off-exchange retail forex trading. The CFTC acted in the nick of time because these new rules are effective on Oct. 18, 2010 — one day before the Dodd-Frank deadline.
Some of the changes are crystal clear — like new 50:1 leverage limits on major forex currencies — but the equally important rule about allowing or barring offshore trading is not yet clear per documents published to date. One off-exchange retail forex broker concluded Tuesday that offshore trading won’t be allowed after the effective date, implying that offshore forex brokers will have to register with the CFTC as well and will be subject to these same new rules.
The CFTC’s new leverage rule calling for a minimum 2 percent deposit on trading major forex currencies off exchange (50:1 leverage) seems on par with what commercial banks like Citi FX Pro offer their retail forex trading customers now.
It’s a wise move by the CFTC to reduce leverage by two times — 100:1 to 50:1 under the new rules — rather than going way over board with its original proposal of 10:1 leverage. Unlike most off-exchange retail forex dealers in the U.S., Citi FX is not regulated by the CFTC; it is subject to bank regulation.
It’s important to note the CFTC grants the NFA powers to set leverage rules higher than these new minimum percentages.
Thankfully, the CFTC responded to the pleas from the off-exchange retail forex trading industry saying the CFTC’s proposed 10:1 leverage rule would put the industry at a huge competitive disadvantage to on-exchange currency futures trading (30:1), commercial bank forex trading (50:1) and offshore off-exchange retail forex trading (200:1). The new deposit rule for non-major currencies is 5 percent (20:1).
Regulators and Congress are often sensitive to chasing business (and fraud) abroad with new rules as well as taking business away from small businesses and handing it over to big banks. The CFTC also wants the U.S. to remain competitive for foreign traders, as foreign traders can continue to trade offshore without concern about registration in the U.S.
It seems these new rules will put a stop to Americans trading retail forex offshore to evade CFTC rules. That trend picked up the pace in recent years and it may need to be reversed quickly. But we aren't completely certain of this yet. We will study the new rules and see if offshore trading remains feasible for Americans under extraterritorial provisions of the Dodd-Frank Fin Reg bill. (We discussed how offshore trading might be a problem for American’s using offshore forex platforms on our recent blog and podcast.)
We base our initial thoughts on the first documents released by the CFTC (links below). In the CFTC’s Q&A document, see the “Who can offer off-exchange forex transactions to retail customers” section. It states that Dodd-Frank Fin Reg changed the definition of allowable financial institutions to “only U.S. financial institutions.” The next section, “What is the scope of the CFTC’s jurisdiction,” implies that unless the entity is regulated by the SEC or bank regulators – again for U.S.-only financial institutions - the default catchall regulator is the CFTC. It makes sense that the CFTC would act in this manner, but again, we aren't certain of these rules yet. Nothing in these CFTC documents specifically exempts offshore forex platforms or brokers from these new rules, either. Stay tuned for further observations.
For more information:
CFTC releases final rules regarding retail forex transactions: Click here.
Final rule regarding retail foreign exchange transactions (summary): Click here.
Federal Register: Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries: Click here.
Questions and answers regarding final retail foreign exchange rule: Click here.
CFTC unveils retail currency-trading rules: Click here.
August 15, 2010
Is widening progressive tax rates unconstitutional?
President Obama wants to widen progressive income-tax rates to redistribute more money from the upper income to the middle-class. Does this targeted tax attack infringe on the constitutional rights of upper-income taxpayers?
Progressive tax rates have been an integral part of the American tax system for a long time. When Presidents Kennedy and Reagan reduced the top marginal rates, it spurred growth and the upper income people felt better about fairness. Lowering their top rates gave them an incentive to invest in innovation and spend on consumer items, all of which grew the economy and tax receipts.
But President Obama proposes to do the reverse, which could hurt the economy. The President wants to retain the lower Bush tax rates for all but the upper two highest income tax brackets, raising the two top brackets from 33 to 36 percent and 35 to 39.6 percent, respectively. (Actually, the top bracket would be 41 percent with phase-outs.)
With health care taxes on investment income and higher Medicare taxes coming in 2013, the top federal rate will be closer to 45 percent. Add in state taxes of 5 percent (on average in many states), and the top marginal tax rate is 50 percent. Social security FICA taxes are another 12 percent on the base amount of $106,800. The President campaigned on subjecting incomes over $250,000 to the FICA tax again too. If that happens, the top tax rate will be 62 percent.
There are more taxes to consider as well. Sales taxes average 5 percent around the country, property taxes are on the rise and there are various excise taxes, too. The deficit commission could even propose a national sales tax (VAT) as well.
Why would anyone want to continue working hard if their make-an-offer-you-can’t-refuse partner — the government — grabs 65 percent of the income? No wonder the upper income seem to be on capital and job-creating strike. More deficit-stimulus spending and paying for spending with tax hikes will not spur job growth; retaining lower Bush tax cuts for all along with business friendly initiatives will do so.
The government argues that it needs to raise tax rates, yet it has done little to nothing to rein in spending, waste and fraud in its own ranks. Obama’s government never addressed Fannie Mae and Freddie Mac’s wasteful spending and policies in Dodd-Frank financial regulation, and it protected the personal injury attorneys in health care reform. Thankfully, the media, pundits and politicians have picked up on the story of government pay and benefits far exceeding private workers. I started on that concept in early 2009 when writers asked me about the escalating problems with state deficits. I also told everyone to let Wall Street pay the bonuses, as government collects half in taxes.
As of January 2010, the budget office (CBO) projects debt will rise to $13.7 trillion (more than 65 percent of GDP) — a difference of $8.6 trillion from 2008. Of this change, 57 percent is due to decreased tax revenues resulting from the financial crisis and recession; 17 percent from increases in discretionary spending, much of it the stimulus package; and another 14 percent due to increased interest payments on the debt — because we now have more debt. Hopefully, interest rates won’t skyrocket anytime soon, as that will really hurt taxpayers. By the way, deflation increases the value of what we owe — the opposite effect of inflation.
The biggest blow to the deficit was decreased tax revenues caused by businesses collapsing — not because tax rates were decreased by President Bush. Restore the financial system and the economy, spur growth and these tax receipts will reappear. Raise tax rates and regulations and the system will not restore itself; the problems will get worse.
It’s not widely understood that President Obama proposes to retain lower Bush progressive tax bracket rates for all but the two highest brackets, which means even the rich will benefit from those lower tax brackets under $250,000 of “married filing joint” adjusted gross income. In fact, the rich will have a small tax cut, because the third-highest marginal bracket (the 28 percent rate) will be widened to reach the threshold of President Obama’s declared cut-off for the new rich of $200,000 single and $250,000 married.
The simple message of the Bush tax cut story is true. The President wants to raise taxes on the upper income and reduce taxes on the middle-class. Conversely, Republicans want to retain the Bush tax cuts for everyone including the upper income. It’s important to note that if Congress can’t pass a new tax bill before year-end, the Bush tax cuts will expire as planned and tax rates rise for all brackets.
Pundits on both sides acknowledge that President Obama has an agenda to redistribute income, capital and benefits (like health care) from the upper income to the middle-class and poor. Popular Democratic rhetoric claims the rich enjoyed most of the benefits of the economy over the past decade while the middle-class stagnated. The left often blames the upper income, big corporations and Wall Street for their economic malaise. Republicans feel raising taxes on job creators during a potential double dip in the economy may reduce tax revenues and cause more job losses.
Let’s focus on the real issue of widening progressive tax rates to redistribute money. The majority of upper-income Americans don’t feel very wealthy now and handing over more of their hard-earned money to the middle-class may seem unfair to them, especially after a large chunk of benefits were already forked over with health-care reform.
Wikipedia says “Progressive taxes attempt to reduce the tax incidence of people with a lower ability to pay, as they shift the incidence increasingly to those with a higher ability to pay.” Even Adam Smith, the great author on capitalism thought progressive taxation is a good idea and most Americans probably agree.
However, there are many good arguments against applying progressive tax rates: “It has been argued that progressive taxation violates the principle of equality under the law — the principle under which each individual is subject to the same laws, with no individual or group having special legal privileges.”
This brings to mind the recent ruling overturning California’s passage of Proposition 8. The court ruled that the wishes of the majority to ban same-sex marriage could not trample the constitutional-rights of the minority. Upper-income taxpayers appear to be a minority too and they deserve constitutional protection from President Obama’s active redistribution agenda.
The President’s health-care mandate forces all taxpayers who can afford it to purchase health insurance or pay stiff penalties. State attorney generals along with their courts may strike down this mandate as unconstitutional based on the commerce clause. It’s amusing that the President’s side is calling it a health-care tax to win that lawsuit. This case shows the Obama administration is trampling on citizens’ constitutional rights.
Big banks are also gearing up to fight the President’s proposed $90 billion bank fee (or tax) based on constitutional grounds. The banks’ attorneys claim it’s an unfair bill of attainder. The constitution bars bills of attainder in Section 9 of Article I. This is another example of soak the rich and people you demonize with higher taxes for redistribution. The banks have paid back TARP with high dividends already.
Progressive tax rates are fair, but widening them too much — especially during a recession cycle that won’t give up — is unfair and unwise. It may even be unconstitutional. August 10, 2010
U.S. forex traders may not be able to skirt rules by moving accounts offshore
The Dodd-Frank Fin Reg bill may extend the CFTC's rules for retail forex trading to foreign trading platforms that are also marketed to Americans. This might mean U.S. resident traders won’t be able to evade CFTC rules for the proposed 10:1 leverage and the recent LIFO trading NFA rule change by using a foreign trading platform. Some foreign forex trading platforms offer 200:1 leverage and spread betting (no requirement for LIFO accounting).
The CFTC hasn’t finalized its January 2010 proposed rule changes for "Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries", including a proposed reduction of leverage from 100:1 to 10:1.
A tax and regulatory attorney colleague replied to my questions on these issues: “Our Congress takes a very broad reach of the extraterritorial reach of our securities and commodities regulatory laws. Solicitation of customers who are U.S. persons — even though the solicitation is made outside the U.S. by a non-U.S. person — is covered. That is why, for example, foreign futures exchanges that want to offer their products to U.S. customers must obtain a 30.10 order from the CFTC qualifying them to solicit U.S. customers. As a practical matter, of course, enforcing that extraterritorial jurisdiction can be difficult (is the U.S. going to invade the Cayman Islands?)"
If 10:1 retail forex trading leverage is enacted by the CFTC/NFA, can U.S.-based retail spot forex brokers easily move their U.S. trading customers to their UK affiliates? It seems like the U.S. broker would be switching them to a foreign affiliate to evade U.S. regulations, and based on my colleague's statement, I think it could be a problem.
U.S. forex traders may be left with two unfortunate choices. Trade on CFTC-sanctioned foreign OTC platforms respecting CFTC rules on LIFO and perhaps 10:1 leverage or take their chances in offshore tax havens (reportable on tax returns). Why go to foreign platforms if the rules are the same and perhaps invite more IRS questions? Why go to offshore havens if it’s potentially illegal and a tax problem - with the IRS scrutinizing offshore accounts?
Tax-haven platforms may never get CFTC sanction, so will they be illegal under Dodd-Frank, or, will it be a viable way to navigate around the U.S. forex trading leverage constraints?
Many comments published on the CFTC site say it’s a bad idea to chase U.S. forex trading business to tax and regulatory havens where there’s much more fraud. The way Congress wrote Dodd-Frank, it seems like it's either going to be sanctioned by U.S. regulators or prohibited entirely. Can a U.S. person report forex transactions on their tax return from counterparties that are not sanctioned?
My colleague said Dodd-Frank Section 929Y has one reference to "extraterritorial" (which means ”foreign”) saying the SEC has jurisdiction to regulate extraterritorial swap contracts. We think this same extraterritorial concept may apply to retail forex trading too. The CFTC regulates retail forex, whereas the SEC has authority over swaps. The Dodd-Frank bill couldn’t possibly mention every point, leaving much to interpretation by regulators. We think the CFTC may interpret the legislative text to mean the CFTC has extraterritorial control over retail forex too. It would be too simple for Americans to avoid the new rules with foreign brokers otherwise. If the CFTC has extraterritorial powers on retail forex, then foreign-based brokers will probably not do business with non-eligible contract participants. Good size hedge funds and proprietary trading firms may be qualified participants. Foreign banks and brokers with U.S. affiliates will fear the U.S. regulators attacking their U.S. operations.
Might there be an opening for retail forex trading to move into prop trading firms — with traders joining these firms as partners — inside and outside the U.S.? By combining trading capital with other traders, a group of individuals may achieve eligible contract participant status. There are regulatory problems with prop trading firms too, as covered on this blog.
We’re working on these very important issues for U.S. forex traders. We hope to have more information on our conference call Thursday at 4:15pm ET. We discussed it on last week's podcast too.
Excerpts from the Dodd-Frank bill:
Dodd-Frank SEC. 742. RETAIL COMMODITY TRANSACTIONS.
PROHIBITION-‘(I) IN GENERAL- Except as provided in subclause (II), a person described in subparagraph (B)(i)(II) for which there is a Federal regulatory agency shall not offer to, or enter into with, a person that is not an eligible contract participant, any agreement, contract, or transaction in foreign currency described in subparagraph (B)(i)(I) except pursuant to a rule or regulation of a Federal regulatory agency allowing the agreement, contract, or transaction under such terms and conditions as the Federal regulatory agency shall prescribe.
Dodd-Frank SEC. 929Y. STUDY ON EXTRATERRITORIAL PRIVATE RIGHTS OF ACTION.
(a) In General- The Securities and Exchange Commission of the United States shall solicit public comment and thereafter conduct a study to determine the extent to which private rights of action under the antifraud provisions of the Securities and Exchange Act of 1934 (15 U.S.C. 78u-4) should be extended to cover-
(1) conduct within the United States that constitutes a significant step in the furtherance of the violation, even if the securities transaction occurs outside the United States and involves only foreign investors;
(2) conduct occurring outside the United States that has a foreseeable substantial effect within the United States.
(b) Contents- The study shall consider and analyze, among other things--
(1) the scope of such a private right of action, including whether it should extend to all private actors or whether it should be more limited to extend just to institutional investors or otherwise;
(2) what implications such a private right of action would have on international comity;
(3) the economic costs and benefits of extending a private right of action for transnational securities frauds; and
(4) whether a narrower extraterritorial standard should be adopted.
(c) Report- A report of the study shall be submitted and recommendations made to the Committee on Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial Services of the House not later than 18 months after the date of enactment of this Act. August 7, 2010
Dodd-Frank bill seeks to crack down on forex arena
Congress took a new approach with the CFTC in the Dodd-Frank bill. The CFTC was dragging its feet on Congress's CFTC Reauthorization Act of 2008 (part of the Farm Bill) calling for forex regulation, which had been mostly overlooked by regulators for decades. With Dodd-Frank, retail forex trading will become illegal for non-eligible contract participants (most retail traders) unless the CFTC finishes its new forex regulations in short order (Dodd-Frank Bill Section 742(c)). The comment period on the CFTC proposals published in January expired and I expect rules to be published soon.
We imagine the CFTC will drastically reduce allowable forex leverage from existing 100:1 to a significantly lower amount, but perhaps not as far as its proposed rule change of 10:1 leverage. Will American forex traders be able to continue using foreign trading platforms to escape the reach of Fin Reg and the CFTC (including these new rules)? You can follow the progress of these regulatory changes here. Also, see the WSJ article "Financial Bill Could Set The Stage For Uneven Retail Forex Rules" dated July 30, 2010.
Dodd-Frank Section 742(c) has two areas of concern. It updates the Commodity Exchange Act (CEA) Section 2(c)(2)(D) Spot Commodities (Metals) and Section 2(c)(2)(E) Spot Forex. Google these sections to learn more.
Prop-trading update
Goldman Sachs told one of the largest prop-trading firms to change its payouts to prop traders to 80 percent or less, down from 100 percent. FINRA Regulatory Notice 10-18 said that 100 percent payouts were indicative of “beneficial owners” (disguised customer accounts and these firms are not registered customer-account broker dealers). Goldman seems to be closely following all rules now to stay out of trouble with the SEC. (Click here for the background on this issue.)
These hot topics, along with those listed below, are covered in this week's podcast. Click here to listen.
Q&A:
Trader tax status, mark-to-market accounting and entities.
Update on the SE tax loophole for investment managers. Recent Republican filibusters blocked repeal of this tax loophole from current jobs and tax extender bills. Green explains how investment managers use S-Corps to reduce SE tax. He further explains how it's the reverse effect for traders.
Should prop traders join prop trading LLC-firms as an entity member or as an individual? Green points out how using an entity can be better for legal protection and better for tax reasons too - unlocking the opportunity for AGI deductions (retirement and health insurance premiums).
Foreign trading to escape Fin Reg and tax implications.
Commentary from Green sprinkled in to Q&A.
Brent Gillett on new English-version Form ADVs.