Jack Horgan / Sunday Business Post continues to be well ahead of the rest of media in understanding this issue.
(perhaps because the SBP is a specialist business paper and has better contacts / sources to understand it, and are clearly able to quote from more than one source that are involved with NAMA bids?)
SUNDAY BUSINESS POST: What did Noonan know about vultures’ tax?
http://www.businesspost.ie/what-did-noonan-know-about-vultures-tax/
SBP are following the NAMA / IBRC paper trail (NAMA sold, and is currently selling today, loans to vulture bidders with Irish tax avoidance Section 110 schemes). The great thing about the NAMA / IBRC trail, is that it is truly rich in paper. All NAMA / IBRC bidders have to give full disclosure on the structure of their bidding vehicle. NAMA / IBRC has complete visibility into the Section 110 status and that the equity owner is an Irish Charity. This is to vet and police any conflicts or links with the source borrower, who is not allowed to be involved in any way with the vultures bid. And of course NAMA Chairman, Frank Daly, is the ex. head of Irish Revenue? And of course the IBRC Liquidator, Kieran Wallace, was a KPMG partner, the Irish tax gurus?
Sunday Business Post wrote:
A person familiar with several loan sales by state agencies said: "Vendors of loan portfolios would have been fully aware of structures being used by acquirers, and it is highly likely that all potential buyers proposed using S110, or structures with similar outcomes.
Sunday Business Post wrote:
A second source with knowledge of the bidding process said: "In the sale process with NAMA and others, it's generally been assumed that everyone would use the same structure - Section 110s. Critically, the bids would have to include who the purchasing entity is and its shareholding [sic ... the Irish Charity as equity owner] so it's hard to see how all parties wouldn't be aware of the structure of the purchasing entity."
Pity the SBP failed to do the sums here. If they did, they would also show that when NAMA sells to a vulture with Section 110 status, the taxes the vulture will avoid, will equate to the equity cheque paid to NAMA.
Also, from mid 2013, Bank of Ireland began to appear in all IBRC / NAMA loan bids. From late 2013 onwards, Bank of Ireland, AIB and even Ulster Bank and KBC Bank, have been bidders on almost all NAMA / IBRC loan bids. If NAMA / IBRC had checked the tax structuring in assessing bids, they could have sold to any of BOI, AIB, UB, KBC for 1 euro, and the state would still been better off financially. How can NAMA / IBRC claim that they were dumb to this angle (given Frank Daly is ex. Head of Revenue and Kieran Wallace is KMPG?
Sunday Business Post wrote:
The government is coming under severe pressure to explain how much it knew about tax structures deployed by vulture funds before Nama and IBRC sold billions of euro worth of loans to them.
SBP is also reporting that FF are now looking for Noonan to make a statement on this and may recall the Dail to force it.
I'm guessing FF have the evidence here, but need Noonan to formally deny all responsibility, before revealing it.
Sunday Business Post wrote:
This weekend, Fianna Fáil finance spokesman Michael McGrath called on Minister for Finance Michael Noonan to make a statement on the issue, and said the Dáil should be recalled to deal with it if necessary.
Nothing on the real "smoking gun" of this scandal - that Irish Revenue (obviously under direction from Dept of Finance), has been making constant rulings over the last 4 years to help the vultures Section 110 schemes (equity owned by Irish Charities) overcome Irish anti-avoidance tax law. Section 110 schemes are so "alien" to domestic Irish tax law that they fall foul of several Irish anti-avoidance provisions. Revenue have even leveraged the fact that they are owned by Irish Charities to fix some of the issues (i.e the CG50 certs, per posts above). Of course, these "fixes" by Revenue have caused such fundamental breeches into our core domestic tax law, that other entitles, are bound to use them for their own Irish tax evasion schemes in the future. Watch this space however.....
Statistics: Posted by observer35 — Sun Aug 07, 2016 8:56 pm