Senate Hearing, 110TH Congress - Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends

S. Hrg.
110778
DIVIDEND TAX ABUSE: HOW OFFSHORE ENTITIES

DODGE TAXES ON U.S. STOCK DIVIDENDS
HEARING
BEFORE THE
PERMANENT SUBCOMMITTEE ON INVESTIGATIONS

OF THE
COMMITTEE ON
HOMELAND SECURITY AND
GOVERNMENTAL AFFAIRS
UNITED STATES SENATE
OF THE
ONE HUNDRED TENTH CONGRESS

SECOND SESSION
SEPTEMBER 11, 2008
Available via http://www.gpoaccess.gov/congress/index.html

Printed for the use of the
Committee on Homeland Security and Governmental Affairs
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DIVIDEND TAX ABUSE: HOW OFFSHORE ENTITIES DODGE TAXES

ON U.S. STOCK DIVIDENDS
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S. Hrg. 110778
DIVIDEND TAX ABUSE: HOW OFFSHORE ENTITIES

DODGE TAXES ON U.S. STOCK DIVIDENDS
HEARING
BEFORE THE

OF THE
COMMITTEE ON
HOMELAND SECURITY AND
GOVERNMENTAL AFFAIRS
UNITED STATES SENATE
OF THE
ONE HUNDRED TENTH CONGRESS

SECOND SESSION
SEPTEMBER 11, 2008
Available via http://www.gpoaccess.gov/congress/index.html

Printed for the use of the
Committee on Homeland Security and Governmental Affairs
(
U.S. GOVERNMENT PRINTING OFFICE
WASHINGTON
45575 PDF
2008
For sale by the Superintendent of Documents, U.S. Government Printing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 5121800; DC area (202) 5121800
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COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS

JOSEPH I. LIEBERMAN, Connecticut, Chairman
SUSAN M. COLLINS, Maine
CARL LEVIN, Michigan
TED STEVENS, Alaska
DANIEL K. AKAKA, Hawaii
GEORGE V. VOINOVICH, Ohio
THOMAS R. CARPER, Delaware
NORM COLEMAN, Minnesota
MARK PRYOR, Arkansas
TOM COBURN, Oklahoma
MARY L. LANDRIEU, Louisiana
PETE V. DOMENICI, New Mexico
BARACK OBAMA, Illinois
JOHN WARNER, Virginia
CLAIRE MCCASKILL, Missouri
JON TESTER, Montana
JOHN E. SUNUNU, New Hampshire
MICHAEL L. ALEXANDER, Staff Director
BRANDON L. MILHORN, Minority Staff Director and Chief Counsel
TRINA DRIESSNACK TYRER, Chief Clerk

CARL LEVIN, Michigan, Chairman
THOMAS R. CARPER, Delaware
NORM COLEMAN, Minnesota
MARK L. PRYOR, Arkansas
TOM COBURN, Oklahoma
BARACK OBAMA, Illinois
PETE V. DOMENICI, New Mexico
CLAIRE MCCASKILL, Missouri
JOHN WARNER, Virginia
JON TESTER, Montana
JOHN E. SUNUNU, New Hampshire
MARK
ELISE J. BEAN, Staff Director and Chief Counsel

ROBERT L. ROACH, Counsel and Chief Investigator
ROSS K. KIRSCHNER, Counsel
L. GREENBLATT, Staff Director and Chief Counsel to the Minority
TIMOTHY R. TERRY, Counsel to the Minority
MARY D. ROBERTSON, Chief Clerk
(II)
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CONTENTS
Opening statements:
Senator Levin ....................................................................................................
Senator Coleman ..............................................................................................
Page
1
6
WITNESSES
THURSDAY, SEPTEMBER 11, 2008
Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan
School of Law, Ann Arbor, Michigan ..................................................................
Joseph M. Manogue, Treasurer, Maverick Capital, Ltd., Dallas, Texas .............
Richard Potapchuk, Director of Treasury and Finance, Highbridge Capital
Management, LLC, New York, New York .........................................................
Gary I. Wolf, Managing Director, Angelo, Gordon & Co., New York, New
York .......................................................................................................................
John DeRosa, Managing Director and Global Tax Director, Lehman Brothers
Inc., New York, New York ...................................................................................
Matthew Berke, Managing Director and Global Head of Equity Risk Management, Morgan Stanley & Co., New York, New York .........................................
Andrea Leung, Global Head of Synthetic Equity Finance, Deutsche Bank
AG, New York, New York ....................................................................................
Hon. Douglas Shulman, Commissioner, Internal Revenue Service, Washington, DC .............................................................................................................
ALPHABETICAL LIST
OF
8
16
19
20
31
34
35
50
WITNESSES
Avi-Yonah, Reuven S.:

Testimony ..........................................................................................................
Prepared statement ..........................................................................................
Berke, Matthew:
Testimony ..........................................................................................................
DeRosa, John:
Testimony ..........................................................................................................
Prepared statement with an attachment .......................................................
Leung, Andrea:
Testimony ..........................................................................................................
Manogue, Joseph M.:
Testimony ..........................................................................................................
Potapchuk, Richard:
Testimony ..........................................................................................................
Shulman, Hon. Douglas:
Testimony ..........................................................................................................
Wolf, Gary I.:
Testimony ..........................................................................................................
8
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34
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31
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35
16
67
19
70
50
94
20
75
APPENDIX
Staff Report entitled Dividend Tax Abuse: How Offshore Entites Dodge
Taxes on U.S. Stock Dividends ..........................................................................
101
(III)
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IV
Page
EXHIBITS
1. How Offshore Entities Dodge Taxes on U.S. Stock Dividends: Swaps .........
DOCUMENTS RELATING TO MAVERICK CAPITAL, LTD
2. UBS email, dated November 2004, re: Dividend Enhancement Flow. (Attaching Dividend Enhancement.doc) ...............................................................
3. Dividend Enhancement Transactions, DRAFTAS OF 4/26/99, prepared
by Maverick Capital .........................................................................................
4. Description of Dividend Enhancement Transactions, dated December 12,
2006, prepared by Maverick Capital ...............................................................
5. Maverick Capital, Dividend Enhancement Transactions Memo, dated June
30, 2005 .............................................................................................................
6. Maverick Capital emails, dated November 2004, re: Microsoft strategy
on capturing the $3.00 dividend for non-US holders only. (Jim has been
working on this for the last 2 months and he got UBS to match the
more aggressive offers we were getting from the Street. For LDC only
we lent the stock out and will get 97 percent of the dividend.) ......................
7. Maverick Capital emails, dated June 2007, re: FIN 48 Tax Positions
DRAFT memos ..................................................................................................
8. Maverick Capital/Ernst & Young emails, dated February 2007, re: AMTD
Dividend ............................................................................................................
9. Domestic Dividend Enhancements, undated document prepared by Maverick Capital ......................................................................................................
10. Excerpts from UBS Documents regarding UBS Cayman Ltd. (UBSCL) .....
DOCUMENTS RELATING TO HIGHBRIDGE CAPITAL MANAGEMENT,
LLC
11. Lehman email, dated November 2004, re: Highbridge Utility FundElectronic Execution into CFD. (. . . also in discussions with them around
yield enhancement on their long positions by using a CFD. This service
involves tax risk for the firm which would be reduced if we can route
their electronic trades direct to CFD instead of their PB account.) ...............
12. Lehman email, dated November 2004, re: Highbridge LPS Basket. (. . .
I would like to move the positions back to their PB account. . . . Would
hate to do this and find out down the road that HB owe withholding
tax on the dividends.) .......................................................................................
DOCUMENTS RELATING TO ANGELO, GORDON & CO
13. Angelo Gordon email, dated August 2004, re: CFDs. (a cfd is used to
circumvent the tax.) ..........................................................................................
14. Angelo Gordon email, dated July 2006, re: Notes from last meeting with
Anthony Harpel. (Contracts for Differenceused mostly in offshore fund
so we dont have dividend withholding CFD is probably about 20 percent
of portfolio) ........................................................................................................
15. Lehman email, dated December 2004, re: Bloomberg internal message
sent from PATRICK RYAN. (. . . it tuns out the majority have partial
withholding so need to stay in CFD. TYPICAL!) ...........................................
16. Lehman emails, dated May 2002, re: SWAPS FOR ANGELO GORDON.
(rich, I agree . . . if the positions are for longer term we can pay 100
percent. * * * I think we have to do this to keep AGs business) ....................
DOCUMENTS RELATING TO LEHMAN BROTHERS INC
17. Equity Finance Yield Enhancement, presentation document prepared by
Lehman Brothers Inc .......................................................................................
18. Lehman Brothers/Highbridge Capital email, dated July 2004, re: CFD
Presentation. (The CFD is usually used for yield enhancement purposes.
. . .) ...................................................................................................................
19. EFG US Dividend Exposures, February 2005, Lehman Brothers presentation ..................................................................................................................
20. Lehman Brothers email, dated September 2005, re: MCIP. (HB looking
for Yield Enhancement on a large position.) ...................................................
21. Lehman Brothers emails, dated October 2004, re: Trade Confirm. (fyi,
the only reason for HB to SWap is for yield enhancement.) ..........................
22. Lehman Brothers letter to Maverick Capital, dated April 24, 2001, (Dividend Enhancement SolutionsWe have a variety of solutions using swap
and securities lending vehicles for achieving yield enhancement.) ................
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23. Lehman Brothers emails, dated January/February 2004, re: Long Transfers. (. . . tell them about doing long swap/cfd business around record
date items so that they get enhanced div treatment on us stocks. . . .) ........
24. Lehman Brothers emails, dated June 2003, re: US Cayman 70 percent
trade ...................................................................................................................
25. Lehman Brothers emails, dated January 2005, re: Conclusions of US
div meeting. (Are all the major competitors in the yield enhancement
game? * * * Borrow via Cayman is considered by Tax dept to be lower
risk than CFD in LBIE. . . .) ..........................................................................
DOCUMENTS RELATING TO MORGAN STANLEY & CO
26. Morgan Stanley email, dated July 2004, re: MSFT Total Return Swaps.
(Here are the main points regarding total return equity swaps on MSFT:
. . . Morgan Stanley can enhance the dividend payout from 70 percent
or 100 percent through a total return equity swap.) .......................................
27. Morgan Stanley email, dated August 2004, re: CRM (MOORE CAPITAL)Microsoft total return equity swap/Moore Capital ...........................
28. Morgan Stanley email, dated July 2004, re: MSFT div timing ....................
29. MSDW Equity Finance Services (Cayman) Limited (Cayco), Outline operating procedures, undated Morgan Stanley document ...............................
DOCUMENTS RELATING TO DEUTSCHE BANK AG
30. Deutsche Bank email, dated October 2004, (. . . LOOKING FOR A WAY
TO MAINTAIN EXPOSURE TO MSFT BUT AVOID THE DIVIDEND
PAYMENT.) .......................................................................................................
31. Deutsche Bank emails, dated September 2004, re: Extraordinary Dividend Rules and Microsoft One-Time Dividend ...............................................
32. PROJECT: DBIL Rehypothecation, February 2007 Deutsche Bank document ...................................................................................................................
33. New Product Application, dated January 2005, Deutsche Bank International Limited (DBIL) Equity Finance alternative structure ..................
34. New Product Application, dated December 2003, Deutsche Bank International Limited, Jersey (DBIL) Securities Borrowing and Lending
NPA Support document ....................................................................................
35. Correspondence from Maverick Capitol, dated September 30, 2008, to
the Senate Permanent Subcommittee on Investigations, supplementing
Mavericks testimony of September 11, 2008 .................................................
36. Supplemental information provided by the Internal Revenue Service regarding Notice 9766 ........................................................................................
37. Additional documents regarding Citigroup, Inc .............................................
38. Additional documents regarding Deutsche Bank ...........................................
39. Additional documents regarding Goldman Sachs Group ...............................
40. Additional documents regarding Lehman Brothers Holdings, Inc ...............
41. Additional documents regarding Maverick Capital Management LLC .......
42. Additional documents regarding Merrill Lynch .............................................
43. Additional documents regarding Morgan Stanley .........................................
44. Additional documents regarding UBS Investment Bank ..............................
45. Documents relating to Footnotes found in the Staff Report, Dividend
Tax Abuse: How Offshore Entities Dodge Taxes on U.S. Stock Dividends,
prepared by the Minority and Majority Staff of the Permanent Subcommittee on Investigations in conjunction with the Subcommittee hearing held on September 11, 2008: [Note: Footnotes not listed are explanative, reference Subcommittee interviews for which records are not available to the public, or reference a widely available public document.] ..........
* SEALED EXHIBITS retained in the files of the Subcommittee.
Footnote No. 50, See Attachment ....................................................................
Footnote No. 51, See Footnote No. 50 (above) .................................................
Footnote No. 52, SEALED EXHIBIT ..............................................................
Footnote No. 64, See Footnote No. 63 (above) .................................................
Footnote No. 68, See Hearing Exhibit No. 19 (above) ....................................
Footnote No. 70 and 71, See Hearing Exhibit No. 18 (above) .......................
Footnote No. 74 and 75, See Footnote No. 73 (above) ....................................
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7679, See Hearing Exhibit No. 12 (above) ..............................

80, See Attachment ....................................................................
8183, See Footnote No. 80 (above) ...........................................
84, See Attachment ....................................................................
85, See Attachment ....................................................................
86, See Hearing Exhibit No. 21 (above) ....................................
87, See Attachment ....................................................................
88, See Attachment ....................................................................
9193, See Hearing Exhibit No. 23 (above) ..............................
94, See Attachment ....................................................................
95, See Footnote No. 94 (above) .................................................
97, See Attachment ....................................................................
98, See Attachment ....................................................................
99, See Attachment ....................................................................
100102, See Hearing Exhibit No. 24 (above) ..........................
103, See Attachment ..................................................................
104, See Footnote No. 88 (above) ...............................................
105, See Attachment ..................................................................
106 and 107, See Hearing Exhibit No. 19 (above) ...................
108, See Attachment ..................................................................
109, See Attachment ..................................................................
110, See Hearing Exhibit No. 17 (above) ..................................
111, See Attachment ..................................................................
114, See Attachment ..................................................................
122, See Attachment ..................................................................
123, See Footnote No. 122 (above) .............................................
125, See Attachment ..................................................................
127, See Attachment ..................................................................
128, See Attachment ..................................................................
129130, See Footnote No. 128 (above) .....................................
132134, See Hearing Exhibit No. 26 (above) ..........................
136, See Attachment ..................................................................
137141, See Footnote No. 136 (above) .....................................
142, See Attachment ..................................................................
144, See Attachment ..................................................................
147, See Attachment ..................................................................
148, SEALED EXHIBIT ............................................................
149 and 150, See Hearing Exhibit No. 3 (above) .....................
152, See Attachment ..................................................................
154, See Attachment ..................................................................
159, See Attachment ..................................................................
161, See Attachment ..................................................................
163, See Footnote No. 148 (above), SEALED EXHIBIT ..........
169, SEALED EXHIBIT ............................................................
170, See Attachment ..................................................................
171 and 172, See Footnote No. 170 (above) ..............................
179, See Attachment ..................................................................
180, See Attachment ..................................................................
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Footnote No. 186 and 187, See Hearing Exhibit Nos. 33 and 34
(above).............................................................................................................. 268, 275
Footnote No. 188 and 189, See Footnote No. 169 (above), SEALED EXHIBIT ....................................................................................................................
*
Footnote No. 190, See Attachment and SEALED EXHIBIT...................... 544, *
Footnote No. 191, See Footnote No. 181 (above) ............................................. 542
Footnote No. 199, See Attachment .................................................................. 702
Footnote No. 202204, See Footnote No. 201 (above) ..................................... 706
Footnote No. 205, See Hearing Exhibit No. 2 (above) .................................... 190
Footnote No. 208, SEALED EXHIBIT ............................................................
*
Footnote No. 209, See Footnote No. 208 (above), SEALED EXHIBIT ..........
*
Footnote No. 210213, See Hearing Exhibit No. 2 (above) ............................ 190
Footnote No. 220, SEALED EXHIBIT ............................................................
*
Footnote No. 271, See Attachments (2)...................................................... 854, 864
Footnote No. 272 and 273, See Footnote No. 271 (above) ........................ 854, 864
Footnote No. 274, See Footnote No. 271 (above) ....................................... 854, 864
Footnote No. 286 and 287, See Footnote No. 285 (above) .............................. 875
Footnote No. 290, See Footnote Nos. 285 and 289 (above)....................... 875, 881
Footnote No. 302, See Attachments (2) and Footnote No. 300
(above) ..................................................................................................... 909, 911, 907
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DIVIDEND TAX ABUSE: HOW OFFSHORE

ENTITIES DODGE TAXES ON U.S. STOCK
DIVIDENDS
THURSDAY, SEPTEMBER 11, 2008
U.S. SENATE,
PERMANENT SUBCOMMITTEE ON INVESTIGATIONS,
OF THE COMMITTEE ON HOMELAND SECURITY
AND GOVERNMENTAL AFFAIRS,
Washington, DC.
The Subcommittee met, pursuant to notice, at 9:10 a.m., in Room
106 of the Dirksen Senate Office Building, Hon. Carl Levin, Chairman of the Subcommittee, presiding.
Present: Senators Levin and Coleman.
Staff Present: Elise J. Bean, Staff Director and Chief Counsel;
Robert L. Roach, Counsel and Chief Investigator; Ross K. Kirschner, Counsel; Mary D. Robertson, Chief Clerk; Mark L. Greenblatt,
Staff Director and Chief Counsel to the Minority; Timothy R. Terry,
Counsel to the Minority; Alexandra Brodman, Intern; Tesia
Schmidtke, Intern; and Mark LeDuc (HSGAC/Senator Collins).
OPENING STATEMENT OF SENATOR LEVIN
Senator LEVIN. Good morning everybody. The Subcommittee will

come to order.
One of the problems that this Subcommittee has tackled in recent years is the stunning fact that the United States loses perhaps
$100 billion in tax revenues each year to offshore tax havens that
aid and abet corporations and wealthy individuals dodging payment of taxes owed to Uncle Sam.
Since 2001, this Subcommittee has examined this problem from
multiple angles, exposing the ways that people use tax havens to
hide their assets and income, and how tax havens have created a
whole industry to help them exercise control over their offshore assets and use those assets and the revenues they produce for their
own benefit, often sneaking funds back into the United States without paying the taxes owed. Just 2 months ago, in July, this Subcommittee held a hearing showing how banks in offshore tax havens have knowingly helped U.S. clients hide billions of dollars in
secret bank accounts never reported to the IRS.
Today, our spotlight is on another facet of tax haven abuses; we
call it dividend tax abuse. And the focus today is not on U.S. citizens, but on non-U.S. citizens who are supposed to be paying taxes
on the dividends they receive from U.S. corporations but do not.
They do not pay those taxes because major financial institutions
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like Lehman Brothers, Morgan Stanley, Deutsche Bank, UBS, Merrill Lynch, Citigroup, and others have created financial gimmicks
whose primary purpose is to enable clients to dodge U.S. taxes
owed on U.S. stock dividends, but which are dressed up with
phrases like dividend enhancement, yield enhancement, and
even dividend uplift. Using stock swaps, stock loans, and exotic
financial instruments, the financial institutions have built a series
of financial black boxes, surrounded by mind-numbing complexity,
designed to keep their clients money tax free.
Foreigners who invest in the United States already enjoy a minimal tax burden. For example, non-U.S. persons who deposit money
with a U.S. bank or securities firm pay no U.S. taxes on the interest earned. They pay no U.S. taxes on capital gains. U.S. citizens
do pay taxes on that income, but the tax code lets foreign investors
operate without tax in an effort to attract foreign investment.
But there is one tax on the books that even foreign investors are
supposed to pay. If they buy stock in a U.S. company and that
stock pays a dividend, the non-U.S. stockholder is supposed to pay
a tax on the dividend. The general tax rate is 30 percent, unless
their country of residence has negotiated a lower rate with the
United States, typically 15 percent.
In addition, to make sure those dividend taxes are paid, U.S. law
requires the person or entity paying a stock dividend to a non-U.S.
person to withhold the tax owed Uncle Sam before any part of the
dividend leaves the United States. If the withholding agent fails
to retain and remit the dividend tax to the IRS, and the tax is not
paid by the dividend recipient, the tax code makes the withholding
agent equally liable for the unpaid taxes.
That is the law. But the reality is that many non-U.S. stockholders never pay the dividend taxes that they owe. In 2003, the
latest year for which data is available, the Government Accountability Office determined that about $42 billion in dividend payments were sent abroad, but less than 5 percent, or $2 billion, was
sent to the IRS. In other words, billions of dollars left the country
untaxed.
The Subcommittees investigation has determined that part of
the reason for unpaid dividend taxes is that, for more than 10
years, U.S. financial institutions have been helping non-U.S. clients
dodge payments.
Now, listen to this roll call of well-known financial institutions.
Morgan Stanley enabled its clients to dodge payment of $300 million in U.S. dividend taxes from 2000 to 2007. Lehman Brothers estimated that in 1 year alone, 2004, it helped clients dodge perhaps
$115 million in U.S. dividend taxes. For UBS, the figure is $62 million in unpaid dividend taxes over a 4-year period, from 2004 to
2007. One hedge fund adviser, Maverick Capital, calculated that
from 2000 to 2007, its offshore funds used so-called dividend enhancement products from multiple firms to escape dividend taxes
totaling nearly $95 million. In 2007, Citigroup surprised the IRS by
paying $24 million in unpaid dividend taxes on a select group of
swap transactions from 2003 to 2005, where no dividend taxes had
been paid.
Who were the clients? Hedge funds organized offshore, often by
Americans; tax haven banks; and a host of sophisticated foreign in-
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3
vestors with the means and the know-how to engage in financial
transactions beyond the reach of ordinary folks. But that is not the
whole story. Some of those foreign investors begin to look a lot less
foreign once you take a closer look.
I am referring in particular to the so-called offshore hedge funds.
When the Subcommittee began contacting them, all of their key
personnel turned out to be here in the United States. The so-called
offshore hedge funds main offices were here in the United States;
their key decisionmakers were here; their investment professionals
and technical people live here. Most of these offshore hedge funds
claim to be located in the Caymans. The Cayman Islands, in fact,
has 10,000 hedge funds, more than any other country in the world.
But the Cayman hedge funds we examined did not operate in any
meaningful sense from the Caymans. Instead, their physical presence often amounted to little more than a Cayman post office box
or a plaque on the wall of the infamous Ugland House, that small
white building where more than 18,000 companies maintain a Cayman address.
Hedge funds run by Americans and invested in the U.S. stock
market often create a shell of a presence in tax havens, presumably
in part to avoid paying U.S. taxes. Then, when confronted by the
one U.S. tax imposed on foreign investors receiving U.S. stock dividends, they turn to financial gymnastics to escape paying that tax
as well. It adds insult to injury when hedge fund managers who
live in the United States, enjoy all its benefits, protections and
prosperity and use U.S. markets to make money, arrange tax
dodges so their offshore hedge funds escape the minimal U.S. tax
obligations they are supposed to pay.
Hedge funds and other offshore entities could not perform their
dividend tax escape act without the cooperation and assistance of
financial institutions. It is those financial institutions that devise
the abusive transactions and send the U.S. dividend payments offshore to their clients in the form of dividend equivalent or substitute dividend payments, without remitting any taxes to the U.S.
Treasury. Their own emails show that they took these actions
knowingly to attract and retain clients and to profit from the fees.
With their assistance, billions of dollars in U.S. dividends flowed
out of this country, and few taxes were withheld.
Now, let me just explain briefly two of the most common schemes
used to dodge dividend taxes. They involve swaps and stock loans.
In both cases, financial sleight of hand is used to recast taxable
dividend payments as untaxable transfers offshore.
First consider swaps. Swaps sound complicated, but they are essentially a financial bet, in this case a bet on the future of a stock
price.
If we take a look at a chart,1 it shows an offshore hedge fund
in blue, which is controlled by a U.S. investment manager in green.
The financial institution, shown in red, tells the hedge fundwhich
owns U.S. stockthat it can escape the 30-percent withholding tax
on an upcoming stock dividend by purporting to sell the stock to
the financial institution and simultaneously entering into a swap
with the financial institution tied to the price of that stock.
1 See
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Exhibit No. 1, which appears in the Appendix on page 189.
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Under the swap, the financial institution promises to pay the
hedge fund an amount equal to any appreciation in the stock price
and the amount of any dividend paid during the term of the swap.
The payment reflecting the dividend is called a dividend equivalent. In return, the hedge fund agrees to pay the financial institution an amount equal to any depreciation in the stock price. The
financial institution hedges its risk by holding the physical shares
of stock that were sold to it by the hedge fund. It also charges
a fee, which usually includes a portion of the tax savings that the
hedge fund will obtain by dodging the withholding tax.
The swap gives the hedge fund the same economic risks and rewards that it had when it owned the physical shares of the stock.
So why do it? Because under the tax code, dividend payments are
taxed, but dividend equivalent payments made under a swap are
not.
Dividend equivalent payments made under a swap are tax free,
because in 1991, the IRS issued a series of regulations to determine
what types of income will be treated as coming from the United
States and, therefore, taxable. These so-called source rules treat
U.S. stock dividends as U.S. source income because the money
comes from a U.S. corporation. But, the 1991 regulation takes the
opposite approach with respect to swaps. It deems swap agreements to be notional principal contracts and says that the
source of any payment made under that contract is to be determined, not by where the money comes from, but by where it ends
up. In other words, the payments source is the country where the
payment recipient resides.
That approach turns the usual meaning of the word source on
its head. Instead of looking at the source or origin of the payment
to determine its source, the IRS swap rule looks to its end point
who receives it. That source is not really a source by any known
definition of the word. It is the oppositenot the point of origin but
the end point.
The result is that when a financial institution makes a dividend
equivalent payment to an offshore client under a swap agreement,
the payment is deemed under the tax code as being from an offshore source. And then under that interpretation, the swap payment is free of any U.S. tax.
In our example, the U.S. financial institution makes the swap
payment to the offshore hedge fund, minus the fee, and stiffs Uncle
Sam for the amount of taxes that should have been sent to the IRS.
The swap is then terminated, and the stock is sold back to the
hedge fund. And the sham nature of that sale is disclosed. And,
under this gimmick, the hedge fund ends up in the same position
as before the swap, as a stockholder, except it has pocketed a dividend payment without paying any tax.
Now, stock loans are also used to dodge dividend taxes, and
these transactions pile a stock loan on top of a swap to achieve the
same, or are intended to achieve the same, tax-free result. And for
the sake of time I am going to put my explanation of this transaction in the record.1
1 Stock Loan. Stock loans are also used to dodge dividend taxes. These transactions pile a
stock loan on top of a swap to achieve the same tax-free result.
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Suffice it to say that it is complex and relies on another gimmick,
and this gimmick is that the parties claim that the substitute dividend is tax free by invoking the wording of IRS Notice 9766,
which was never intended to be applied to this situation. That notice says that when two parties in a stock loan are outside of the
United States and subject to the same dividend withholding rate,
they do not have to pay the dividend tax when passing on a substitute dividend. But the assumption is that the tax was already
paid by another party in the lending transaction. Some tax lawyers
have seized on the wording to claim that this IRS notice, which
was intended to prevent overwithholding, could be used to eliminate dividend withholding entirely, so long as one offshore party
passes on a substitute dividend to another offshore party subject to
the same dividend tax rate. The IRS has told this Subcommittee
that Notice 9766 was never intended to be interpreted that way,
but in the 10 years since it was issued and abusive stock loans
have exploded, the IRS has never put that in writing.
The end result in our example is that the client pockets a substitute dividend paymentminus the financial institutions fee
without paying any tax. The stock loan is terminated, and the
stock is returned to the client. The big advantage of this approach
over a swap is that the client does not have to explain why he got
his stock back after the transaction. The stock was, after all, only
on loan.
Tax avoidance was clearly the economic purpose of the two transactions just described. The client owned U.S. stock both before and
after each transaction. Neither the swap nor the stock loan altered
the clients market risk. The only risk involved in either transaction was that Uncle Sam would catch on and assess the dividend
taxes that should have been paid but were not.
To make it harder for Uncle Sam to catch on and prove what is
going on, financial institutions have added more complexity, more
bells and whistles, to these transactions. But the purpose of the
transactions remains the sameto enable clients to escape paying
the taxes that they owe.
And it is clear that the participants knew their transactions were
little more than tax dodging. In one email exchange about a proposed stock loan, a potential client informed Merrill Lynch that its
tax counsel had said the transaction works, as I said, once, maybe
twice, but repeated use, coincidentally around dividend payment
time, would provide a strong case for the IRS to assert tax evasion. Another client explaining a Lehman Brothers swap transaction to a colleague wrote that the swap is used to circumvent
the tax. That is the unvarnished truth.
The first step is that the client with an upcoming dividend loans its stock to an offshore
corporation controlled by the financial institution. This offshore corporation promises, as part
of the loan agreement, to forward any dividend payments back to the client.
The next step is that offshore corporation enters into a swap with the financial institution
that controls it, referencing the same type of stock and number of shares that is the subject
of the stock loan. Essentially, two related parties are placing a bet on the stock, which makes
no economic sense except, once that stock pays the dividend, the swap arrangement allows the
financial institution to send it as a tax-free dividend equivalent payment to the offshore corporation it controls. The offshore corporation then forwards the same amount to the client. Because
the payment is sent to the client as part of a stock loan agreement, it is called a substitute
dividend. The tax code treats substitute dividends in the same way as the underlying dividend.
So if the underlying dividend came from a U.S. corporation, the substitute dividend would normally be taxed as U.S. source income.
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The participants in these transactions also took steps to limit
their exposure in case the IRS stepped in. Some of the financial institutions, for example, set an annual limit on the amount of unpaid dividend taxes that they would facilitate through their transactions to limit their exposure as withholding agents. Some of the
clients demanded that the financial institutions indemnify them
against any tax liability. A few financial institutions, such as UBS,
Merrill Lynch, and Morgan Stanley, have stopped offering the most
blatantly abusive transactions, while others have continued doing
as many deals as ever.
Now, some may claim that by exposing this tax dodge and being
determined to end it, we are trying to discredit structured finance
or the financial markets. I support financial transactions that are
used for legitimate purposes, including swaps and stock loans that
facilitate capital flows, reduce capital needs, or spread risk. What
I oppose is the misuse of financial transactions to undermine the
tax code, rob the U.S. Treasury, and force honest Americans to
shoulder the countrys tax burden. And what I oppose are transactions whose patent economic purpose is tax dodging.
For the last 10 years, as dividend tax dodging took hold and became an open secret among market insiders, the U.S. Treasury Department and the IRS sat on their hands. When firms began claiming they could turn taxable dividend payments into untaxed dividend equivalents under swaps, Treasury and the IRS said nothing.
When firms began claiming that the 1997 IRS notice designed to
cure overwithholding could eliminate all withholding in offshore
stock loans, Treasury and the IRS failed to issue corrective guidance. When firms openly advertised so-called dividend enhancement products to clients, Treasury and the IRS saw nothing, heard
nothing, and took no enforcement action.
The governments failure to act does not in any way excuse the
actions of the financial institutions or their clients. They are not
saved from their own abusive conduct by the failure of regulators
to stop them, any more than going through a red light is OK if you
are not caught. Nonetheless, the silence and inaction of the Treasury and the IRS in the face of rampant dividend tax dodging has
encouraged and continues to encourage financial institutions to
offer their clients financial concoctions designed to enable them to
dodge U.S. dividend taxes. It is past time to end that silence, to
end that inaction, and to get those concoctions off the market. It
is also past time for Congress to take on this billion-dollar offshore
tax abuse and, like so many others, enact the legislation needed to
put a stop to it.
I want to thank my Ranking Member, Senator Coleman, for his
support of this investigation, for the support of his staff, and now
invite him to make opening remarks.
OPENING STATEMENT OF SENATOR COLEMAN
Senator COLEMAN. Thank you, Senator Levin.

I want to begin by thanking Chairman Levin for initiating this
investigation, and I want to commend his longstanding commitment to identifying institutions and individuals who facilitate the
inappropriate avoidance of legitimate taxes through complex offshore schemes.
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Today, we turn our attention to the findings of another bipartisan inquiry, which the Chairman has just described: That some
U.S. financial institutions have been structuring equity swap and
loan transactions to assist their offshore clients in avoiding U.S.
taxes on stock dividends. The factual findings at issue today and
identified in this Subcommittees bipartisan Staff Report are compelling. They raise valid concerns that demonstrate the need to reevaluate the wisdom and effectiveness of tax laws and policies respecting the treatment of specific equity swap and loan transactions.
For a foreign investor, there is a significant difference in the
United States withholding tax consequences between investing synthetically through an equity swap versus directly in physical U.S.
equities. This difference in treatment has led to certain abuses.
While the activities may not rise to the level of criminal tax evasion, there is no doubt that some institutions have taken advantage
of ambiguities in U.S. tax law and pushed the tax-avoidance envelope too aggressively.
I want to be clear. Our target here today is neither derivatives
generally nor equity swaps specifically. Derivatives serve many
purposes critical to the health and dynamism of American markets,
as well as the U.S. economy, writ large. Swaps, in particular, often
offer superior leverage, accounting treatment, market access, and
transactional efficiency, all of whichincluding the preferential tax
treatment afforded to swaps under current laware legitimate factors that may influence the decision to trade in swap form.
That said, a swaps transaction with no business purpose other
than the avoidance of withholding tax is a bridge too far. For the
most part, I am talking about a subset of aggressively structured
dividend enhancement trades that are short-lived; clustered around
dividend record dates; involve so-called crossing in just prior to the
dividend date; and feature the reacquisition of the physical shares
after the completion of the synthetic transaction.
During the course of our investigation, we have seen these aggressive schemes executed far too often, and, frankly, some of the
more egregious fact patterns that we have examined reflect a
shameless and cynical abuse of U.S. tax policy.
While there is no doubt that certain financial institutions and
hedge funds have crossed the line, as the Chairman has noted, the
conditions for these abuses were largely created by Treasury and
the IRS. The reality is that the state of the tax law here is muddled; the Treasury and the IRS have known about these ambiguities and have done woefully little to clarify the situation, failing
to offer taxpayers clear guidance and direction. Therefore, while
some financial institutions undoubtedly raced to the bottom, Treasury and the IRS bear some responsibility as well.
We are not just in the blame business, however. We are in the
problem identification and problem-solving business. The Chairman
has done a good job in identifying the problem. How do we fix this
problem?
In light of the Subcommittees findings, we need a comprehensive
and in-depth analysis of the potential legislative or regulatory responses to these abuses. The relevant Executive Branch agencies,
the congressional committees of jurisdiction, and experts on tax law
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and policy should engage in a deliberative process to evaluate the
various possible responses and determine the most appropriate
path.
I strongly urge, however, that any response to these abuses be
clearly defined and carefully targeted to preserve the integrity and
efficiency of our capital markets and avoid unintended consequences. In particular, any response should avoid negatively impacting foreign investment in the United States. Such investments
are critical to job growth and opportunity expansion and are undeniably necessary for the economic well-being of our citizens.
Which brings me perhaps to the most important issue: As I have
said many times beforemost recently in the Subcommittees hearings on tax cheats and tax sheltersinappropriate tax avoidance
by a privileged few forces millions of honest American taxpayers to
shoulder a disproportionate share of the tax base, to dig deeper to
maintain investment in crucial areas like health care, homeland security, and education. That tax loss sits like a millstone around the
neck of honest American taxpayers, who are struggling with high
taxes, ever-increasing gas prices, and rising health care costs.
Those honest taxpayers are the real victims here.
Thank you, Mr. Chairman.
Senator LEVIN. Thank you, Senator Coleman.
And now let me call our first witness to this mornings hearing:
Professor Reuven Avi-Yonah, who is the Irwin I. Cohn Professor of
Law at the University of Michigan Law School in Ann Arbor.
Professor Avi-Yonah, I would like to welcome you back to the
Subcommittee, having testified at the Subcommittee in August
2006 on tax haven abuses. We appreciate your sharing your experience in international tax law and your attendance at todays hearing. We look forward to your testimony and your perspective on
this dividend tax issue.
Before we begin, pursuant to Rule VI, all witnesses who testify
before the Subcommittee are required to be sworn, and so at this
time I would ask you, Professor, if you would please stand and
raise your right hand. Do you swear that the testimony you are
about to give before this Subcommittee will be the truth, the whole
truth, and nothing but the truth, so help you, God?
Mr. AVI-YONAH. I do.
Senator LEVIN. We will use the usual timing system today, and
about a minute before the red light comes on, you will see the light
change from green to yellow, giving you an opportunity to conclude
your remarks, and your entire testimony and the testimony of all
of our witnesses will be printed in the record. We ask you, if you
would, to limit your oral testimony to no more than 8 minutes.
Professor Avi-Yonah, please proceed with your statement.
TESTIMONY OF REUVEN S. AVI-YONAH,1 IRWIN I. COHN PROFESSOR OF LAW, UNIVERSITY OF MICHIGAN SCHOOL OF
LAW, ANN ARBOR, MICHIGAN
Mr. AVI-YONAH. Thank you very much, Chairman Levin and

Ranking Member Coleman, and the whole Committee and Subcommittee for inviting me to testify today on dividend tax abuse.
1 The
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prepared statement of Mr. Avi-Yonah appears in the Appendix on page 59.
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There are three basically economically equivalent ways of investing in U.S. stock and receiving dividend or dividend equivalent
payments. The first is simply to invest in a physical stock. A foreign buyer buys stock of a U.S. corporation, receives a dividend,
and that, as you have indicated, Mr. Chairman, is subject to a 30percent or sometimes a 15-percent withholding tax. That is what
our law says.
The second alternative is to engage in an equity swap. This is
a type of transaction in which you enter into an agreement with
a financial institution, a U.S. financial institution, under which you
will at the end of the swap receive the appreciation or pay the depreciation in the value of the stock, and during the course of the
swap, you will receive dividend equivalents every time that the underlying stock pays a dividend.
And the third one is a stock loan, where you have the stock, you
lend it to a U.S. institution, and in exchange you receive dividend
substitute payments.
As their names indicated, dividend equivalents are equivalent to
dividends, and dividend substitutes are substitutes for dividends.
And, economically, the foreign investor is in the same position in
all three transactions. In all of them, they are exactly at the same
level at risk for the depreciation of the stock; they have the up side
of the appreciation of the stock; and they receive the full amount
of the dividends minus any fees that they have to pay for the financial institutions arranging the transaction.
However, for tax purposes, as was mentioned, these transactions
are not treated alike. The actual dividend is subject to a dividend
withholding tax per the code. The dividend substitutes are also
subject to a dividend withholding tax; they are treated as dividends
based on a regulation issued, proposed by the Treasury Department in 1992 and finalized in 1997. But dividend equivalents on
the swaps are tax free because of the source rule that was mentioned in the introduction.
So when you have a situation like that where three identical,
economically identical equivalent transactions are taxed differently,
there is an open invitation to taxpayers to try to avoid the taxed
ones and convert them or use the only tax-free one. And that is an
invitation to abuse, and the abuse occurs, for example, as was mentioned, when a foreign taxpayer actually holds a stock, sells it just
before the record dividend date, receives a dividend equivalent, and
then it reacquires the stock back. And sometimes, as was mentioned, even sells it to the financial institution with which it enters
the equity swap and receives the dividend equivalent from that financial institution. That is really the most extreme example, but
I would say that even if they buy and sell the stock in the market,
it does not matter, as long as they hold the actual stock before the
record date and receive it back, buy it back after the record date
and receive the dividend equivalent, that is a dodge as well. That
is an abusive transaction, in my opinion.
Now, Treasury has been aware of this problem for a long time.
They first issued thethey created the loophole, as it were. They
issued the regulation that made dividend equivalents under swaps
tax free in 1991, as was mentioned. Already in the preamble to the
proposed 1992 regulations on stock loans, they voiced concerns
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about this, and, again, in another preamble to another regulation
in 1998, they repeated their concerns. But it has now been 16 years
since the first time they voiced a concern, and they have not really
done anything.
Moreover, in 1997, they issued Notice 9766, which has had the
effect, as interpreted by taxpayers, of making dividends subject to
payments also tax free because of what I regard as a blatant misinterpretation of the language of the notice. But because the notice
did not say explicitly that the condition for not withholding on dividend substitutes from one foreign payer to another is that there
will be an actual dividend withholding somewhere in the chain, because the notice was, as was mentioned, intended to prevent overwithholding, taxpayers have used this to structure transactions involving stock loans and try to avoid the dividend withholding tax
this way.
Now, in my opinion, the solution is to make the three equivalents
the same; that is, dividend equivalents should be taxed the same
way the dividend substitutes are, and the dividend substitutes are
treated as dividends, so all three should be treated as dividends.
Moreover, because of the risk that it will be possible to structure
transactions involving baskets of stock, for example, that behave
equivalently to a single stock from an economic perspective, I think
we should use the substantially similar or related property standard, which is already well established and well developed in regulations that is addressed to these kind of transactions. That is, we
should tax dividend equivalents whenever they are either dividend
equivalents or a single stock or in a basket of stocks that is substantially similar or relates property to a single share of stock.
Moreover, the IRS should clarify Notice 9766 to make clear that
it never intended, as it states, to apply that notice to the situation
where the taxpayer cannot show that the dividend has actually
been collected anywhere in the process.
Basically, the policy issue here is, if you step back for a moment,
there is an argumentand I think it is a valid argument, although
I do not ultimately agree with it. The argument is that we do not,
as was mentioned, withhold taxes and interest payments typically
with foreigners, and we do not withhold taxes typically by treaty
and royalty payments, and those payments are deductible. Why
should we, as a policy matter, withhold taxes on dividends when
dividends are not deductible so we already collect the corporatelevel tax?
However, there is an argument that this policy is OK because
dividends represent investments in unique U.S. taxpayers. For example, you cannot find many Microsofts in the world, and when
Microsoft pays a dividend, foreign taxpayers would want to get that
dividend, and they do not have an alternative investment opportunities like they have in the case of interest. But in any case, even
if you disagree with the policy analysis and think that dividends
should not be subject to withholding, that is a matter for Congress
changing the law, and for the Senate, for example, to ratify treaties
maybe that we reduce the dividend withholding to zero.
A lot of taxpayers over the years and a lot of tax policy people
have lobbied and have argued for a portfolio dividend exemption,
just like we have a portfolio interest exemption. But, in my opinion,
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as long as they are not persuasive, as long as they have not managed to persuade Congress to change the law, it is inappropriate
for taxpayers to try to use dividend equivalents or dividend substitutes to achieve a result that they have not been able to get Congress or the Senate to change by way of the code or the treaty.
And, moreover, it is inappropriate for Treasury and the IRS to turn
a blind eye because one way of explaining their behavior is to say
they do not really believe in the withholding tax on dividends, and,
therefore, they allow this kind of dodge to take place. And I think
that is an inappropriate approach. It is up to Congress to determine whether there should be withholding on dividends, and as
long as that is the law, it is up to Treasury and the IRS to make
sure the dividend withholding is, in fact, enforced.
Thank you very much.
Senator LEVIN. Thank you very much, Professor. That was very
clear testimony, as always.
Financial institutions selling these financial products to their
non-U.S. clients to enable them to dodge U.S. dividend taxes, would
you agree has just become an accepted way of doing business?
Mr. AVI-YONAH. Yes, exactly. I think that this was identified as
a problem as early as 1992 by the Treasury and as early as 1993
in the literature. And since then, numerous articles have been written about it, but basically what is happening in the last 10 years
is that the scope of it has really exploded, probably because of the
growth of the hedge funds, and probably becauseI once heard a
tax lawyer describe this as an approved loophole. That was the
language that was used.
The interpretation of the inaction by the Treasury and the IRS
has been that this must be an OK way of doing business.
Senator LEVIN. Now, take a look at Exhibit 6,1 if you would,
which is an email between two employees of Maverick Capital,
which runs a number of offshore hedge funds. The email is from
2004. It describes a Microsoft special dividend announced that year
to pay $3 on every Microsoft share for a total of $32 billion.
On the second page of the email, it says the following: Jim has
been working on this for the last 2 months, and he got UBS to
match the more aggressive offers we were getting from the Street.
For LDC only, we lend the stock out and will get 97 percent of the
dividend.
Would you say that these hedge funds pressuring financial firms,
playing one off against the other to get dividend enhancement
products to relieve them of having to pay a 30-percent dividend tax
rate, that it has gotten to the point where financial institutions
have to offer dividend enhancement products to be competitive,
even if there is a tax risk?
Mr. AVI-YONAH. I believe that is the case. And, in fact, one thing
that is interesting about this is that if you watch it over time, the
fees keep declining, so that in the beginning you can charge 15 percent and in the end you can charge 3 percent or 2 percent or 1 percent. And that is because there is so much competition, and the
hedge funds can go from one financial firm to the other.
1 See
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Exhibit No. 6, which appears in the Appendix on page 200.
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Senator LEVIN. And, that percentage that you gave was a percentage of the dividend. Is that correct?
Mr. AVI-YONAH. That is a percentage of the dividend. So anything above 70 prercent is good from the taxpayers perspective because 70 percent is what they get if they pay the full tax. So if they
get 85 percent, it is good. But, of course, if they can get 97 or 98
percent, it is even better.
Senator LEVIN. Now, there is no hard data on how much the
Treasury loses based on these gimmicks, these tax avoidance approaches to these dividends, the way these payments are avoided.
Would you estimate that this loss to the Treasury involved billions
of dollars?
Mr. AVI-YONAH. Yes, certainly. I mean, the only hard data is the
one that I believe you cited, and that is the GAO report based on
2003 data. What they say is that in that year, $42 billion in dividends were paid to non-U.S. corporate holders. They do not specify
non-corporate holders. And of that, only less than $2 billion was
collected as withholding tax.
What is striking to me about that number is that it is less than
5 percent, and 5 percent is typically the rate that by treaty we collect on direct dividends, that is, dividends paid to foreign parents
of U.S. subsidiaries.
So my conclusion from that is that essentially there is no withholding tax on portfolio dividends at all, dividends paid on people
who do not own 10 percent or more by vote of the shares. And the
reason for that is that nobody except the hopelessly uninformed
would engage in direct dividend bearing stock investment into the
United States.
What everybody does is what we have been talking about, namely, they get dividend equivalents, and we do not have data as to
the size of dividend equivalents being paid to foreigners because no
tax is collected, so nobody has the data.
But I am convinced that billions are lost, and, in fact, the data
that the Subcommittee has collected shows that for each bank it is
hundreds of millions, or at least tens of millions, sometimes hundreds of millions. And over time, of course, it adds up to billions.
Senator LEVIN. We have lost a lot of income to the Treasury, you
estimate billions. I agree with that. What distortions to the market
result when this occurs? You have dividends taxed, but dividend
equivalents not taxed, substitute dividends not taxed.
Mr. AVI-YONAH. The obvious distortion is that people engage in
the transactions that are not taxed and do not engage in the transactions that are taxed. So sometimes as an economic matter or as
a business matter, they would prefer to have the actual stock, the
physical stock, or they would prefer to engage in a direct stock loan
into the United States. And since both of these transactions are
taxed, instead what they do is that they engage in a swap, which
is economically equivalent in terms of their returns, but the terms
of it and the precise business terms may be different. Or they
would engage in transactions that are really meaningless in order
to avoid the tax, like inserting an artificial foreign entity into a
stock loan transaction so that the stock loan will be foreign-to-foreign benefit from Notice 9766; whereas normally they would do
the stock loan directly into the United States.
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So I think the main distortions are the distortion between the
three forms of transactions, but also just useless and wasted transaction costs when there are transactions that are engaging only for
the purpose of avoiding taxes, all of the other transactions are just
a burden on the economy.
Senator LEVIN. Now, these problems have been known for 10 or
more years. What in your judgment is the reason that the IRS and
the Treasury have not taken this issue on and corrected it? Is it
because there is a debate over the policy? Or is it because there is
a debate over, whether that interpretation is clearly wrong? What
is the reason?
Mr. AVI-YONAH. I do not think there is a debate on the interpretation or the fix because we know they know how to fix it because
that is what they did with dividend substitutes. They issued the
dividend substitute rule. They proposed it in 1992. They finalized
it in 1997. They knew how to fix that. I mean, before that rule, dividend substitute also could be arguably tax free.
They made the mistake with Notice 97-66. I do not think that
was deliberate. I think they were duped, essentially, into thinking
there was an overwithholding problem that did not really exist,
and they did not think about the waysthey did this very fast,
within a month of issuing the final regulations, so they did not
really think about the way the notice could be abused.
Fundamentally, I do thinkor at least this is my surmisethat
on some level it is a policy debate. I have had this discussion with,
for example, former Clinton Administration tax officials who told
me that fundamentally the issue is whether there should be withholding on dividends, and they do not fundamentally believe there
should be withholding on dividends because the corporate tax is already paid and dividends are not deductible and because we have
a portfolio interest exemption and, arguably, it is possible to convert dividends to interest and vice versa. So, therefore, why should
they try to enforce the law in this particular regard? And as I said,
I think that is inappropriate.
Senator LEVIN. Now, if we decideand I hope we dothat the
clear intent of the law is that dividends or these foreign distributions of dividend amounts be taxed, that is the clear intent of the
law, if we decide that, how do we enforce the law? Do we need to
amend the law, particularly as it relates to swaps? As it relates to
the loans? If the Treasury refuses to clarify their regulation, do we
pass a law? Assuming that we want to enforce the policy, which is
clearly intended currently, how do we do that?
Mr. AVI-YONAH. Well, in principle, since this is all regulatory, it
is either regulations or even just a notice, Treasury can tomorrow,
at least certainly prospectively, amend its regulations and clarify
the notice.
Senator LEVIN. On both swaps and
Mr. AVI-YONAH. Yes, on both swaps and
Senator LEVIN. And if they refuse to do this, as they have
Mr. AVI-YONAH. Then I think
Senator LEVIN [continuing]. For 10 years, then what?
Mr. AVI-YONAH. Then I think legislation is appropriate, and I
think the legislation should say that dividend equivalents on single
stock swaps and on economically equivalent baskets of stocks
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should be treated like dividend substitutes and that dividend substitutes should be subject to withholding if there is no showing that
there was an actual withholding somewhere in the chain. I think
that would be appropriate.
Senator LEVIN. Thank you. Senator Coleman.
Senator COLEMAN. Thank you. Thank you, Mr. Chairman.
In some ways, this is complex. But in many ways, it is actually
pretty simple. And yet your testimony took a very complex issue
and made it very simple. There is a form of transaction here involving dividend-paying U.S. securities, and the Treasury and IRS
have set it up so that it is very easy to avoid the tax consequences
of these transactions. And folks have known about that for years.
And the Chairman asked the $64,000 question: Why have we not
acted on this? Your response confirms what I have been reflecting
on.
Our tax policies are such that they favor foreign investment. We
want foreign investment in this country. Is that correct?
Mr. AVI-YONAH. Yes.
Senator COLEMAN. So non-U.S. persons who deposit money with
a U.S. bank or securities firm do not pay tax on interest earned or
capital gains, and it almost seems to me that this situation exists
because Congress has failed to clarify this one way or the other.
Mr. AVI-YONAH. Well, there are policy issues going in both directions. The argument for interest is pretty clear, and that is why
since 1984 we have not been withholding on interest, and that is
that interest is simply money lent, and money can be lent anywhere in the world, and the interest rate is basically determined
on the global market. And if we impose, try to impose withholding
taxes on interest, then either the money will simply go somewhere
else, and instead of coming here, it will go to another one; or maybe
more likely because we are a big market, the interest cost will simply be shifted forward to American borrowers, and they will have
to bear it. And that is not particularly good either because it increases the cost of capital. That is the argument for interest.
And the other one for royalties, for example, which are exempt
by treaty, is that because we have a lot of intangibles in this country developed, we benefit more from foreigners not taxing royalties
coming to us than we do by excusing royalties paid to them. So as
a revenue matter, it is a gain.
Now, dividends are different, though, because dividends are an
investment in U.S. companies. So if you take Microsoft, which is
a prominent company in these examples because it pays very big
dividends out afterthe dividend tax was reduced in 2003$32
billion, as was mentioned. Now, that particular stock represents a
unique investment opportunity. There is no other Microsoft in the
world. They have what the economists call rents; that is, they
have unique intangibles that they developWindows software and
all the rest of itand that is the only company that has it and the
only company where you can make that particular money.
So, in my opinion, even if we tax the dividend on Microsoft and
tax dividend equivalents on Microsoft stock, the foreigners will still
come, and they will still invest in Microsoft because of this unique
opportunity. And my judgment is that in most situations that is
the case.
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In addition, one thing that needs to be investigated on the policy
level is what is the policy of our trading partners on dividends and
dividend equivalents? And at least in one casenamely, the U.K.
I know that they tax dividends and what they call manufactured
dividends, which is dividend equivalents, etc.
Senator COLEMAN. If I can follow up on that question about
whether the folks would simply accept the 30-percent haircut in
order to get Microsoft, are there close, overseas alternatives, areas
where the investors would simply shift their capital?
Mr. AVI-YONAH. Yes.
Senator COLEMAN. What are they?
Mr. AVI-YONAH. Well, there are, I would imagine, American companies where you canI mean, if you are looking at an investment
at, lets say, General Motors or Toyota or Volkswagen, maybe they
are equivalent enough so that if we tax GM, they would shift to
Toyota or shift to Volkswagen, or Daimler or whatever. And in
those kind of industries where American companies do not have a
unique competitive advantage, there would be a risk of imposing a
tax that you would be shifting the investment elsewhere. So that
is the policy debate about whether we should be taxing dividends
or not.
Senator COLEMAN. And that is a legitimate policy. One part of
the concern I have hereand the Chairman has done a tremendous job of identifying the problem is: What is the solution? I am
not sure I am there yet. But one of the solutions could simply be
lets not tax dividends, treat them like capital gains, treat them
like interest, and then what you do is you take a lot of folks out
of the business, but you no longer have the ambiguity and you no
longer have agencies involved in turning a blind eye to something
that we all see going on.
Mr. AVI-YONAH. Yes, and I think that is a legitimate argument
for Congress to have. The problem is that this argument has been
made to Congress for many years, and they have not acted. And
as long as they have not acted, I do not think it is appropriate for
taxpayers to avoid the actual dividend tax that we have in place.
Nor is it appropriate for Treasury and the IRS to close a blind eye
to these transactions.
Senator COLEMAN. I do not disagree with that assertion, Professor. Thank you, Mr. Chairman.
Senator LEVIN. Thank you. I think that is exactly the issue. The
IRS here is not the policymaker. They are supposed to be enforcing
the law. The law is that these dividends are supposed to be taxable. I do not think there is any doubt about the intent of this law.
The IRS, indeed, I think knows that is the intent. And so even
though you may have a policy debate going on in the IRS, which
may be a perfectly appropriate debate, that is not the issue before
us. The issue before us is we have a tax law, and it is being avoided and evaded by these kinds of gimmicks which clearly are intended to avoid what is the clear intent of the law. And the IRS,
knowing that, is doing nothing. And that is unacceptable in terms
of any kind of a separation of powers.
Mr. AVI-YONAH. Yes.
Senator LEVIN. You cannot have the IRS become the policymaker. They can recommend changes in policy if they want to, and
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that is a perfectly fair issue. But what they cannot do is not enforce
the law because that opens up the kind of lawlessness which we
have seen on these offshore tax havens, which have resulted in a
loss of literally, we think, of $100 billion a year. I am determined
to stop that. That is the remedy that, one way or another, I am
going to fight to get established: Enforce the tax laws. And if we
want to change them, change them. But do not evade them, do not
avoid them, do not ignore them, do not circumvent them with the
use of these transactions and concocted structures which have as
their purpose getting around the clear intent of our tax laws. This
is where we have got to fight back, and we need the IRS to help
us in that fight.
You have been very helpful in terms of clarifying what the issues
are and then distinguishing between the policy issues and the enforcement issues.
Senator Coleman, do you have anything else?
Senator COLEMAN. No.
Senator LEVIN. Again, let us thank you for all you have done
here.
Mr. AVI-YONAH. Thank you very much.
Senator LEVIN. Now, our second panel of witnesses today are Joseph Manoguewho is the Treasurer of Maverick Capital of Dallas, Texas; Richard Potapchuk, the Director of Treasury and Finance at Highbridge Capital Management of New York; and Gary
Wolf, who is the Managing Director of Angelo, Gordon & Co., of
New York.
If you could come and stand and raise your right hands, please.
Do you swear that the testimony you are about to give before this
Subcommittee will be the truth, the whole truth, and nothing but
the truth, so help you, God?
Mr. MANOGUE. I do.
Mr. WOLF. I do.
Mr. POTAPCHUK. I do.
Senator LEVIN. Thank you so much. Thank you for being here.
I think you heard me describe the timing system before, so I will
not repeat that.
Mr. Manogue, we will have you go first. Am I pronouncing your
name correctly?
Mr. MANOGUE. Yes, you are.
Senator LEVIN. Thank you. And then you will be followed by Mr.
Potapchuk. Am I pronouncing your name correctly?
Mr. POTAPCHUK. Yes, you are, Chairman.
Senator LEVIN. Thank you. And then Mr. Wolf, and then after
hearing from all of you, we will then turn to questions.
So, Mr. Manogue, please.
TESTIMONY OF JOSEPH M. MANOGUE,1 TREASURER,
MAVERICK CAPITAL, LTD., DALLAS, TEXAS
Mr. MANOGUE. Thank you. Members of the Permanent Senate

Subcommittee, my name is Joseph Manogue, and I am the Treasurer of Maverick Capital, Ltd. I submit this statement as Mavericks representative in response to the invitation that we received
1 The
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late last week from the Subcommittee in order to assist the Subcommittee in its review of certain industry practices that have been
commonly referred to as dividend enhancement transactions.
Maverick is an investment advisor that manages client capital
primarily through hedging strategies based on long and short positions in U.S. and foreign equity securities. To that end, Maverick
undertakes typical industry transactions, including the purchase
and sale of stocks, shorting stocks, and borrowing and lending
stocks.
Investors in Maverick managed funds include both U.S. and foreign institutions and individuals, and our funds include both domestic and foreign entities in structures that are typical for our industry. I would like to note in particular that our structures and
policies provide for investment by U.S. taxpayers in domestic partnerships that are subject to full Internal Revenue Service return
and information reporting requirements that typically apply in a
domestic context.
In 1994, Maverick made the decision to register as an investment
adviser under the Investment Advisers Act of 1940, and thereby
voluntarily submitted to periodic review and inspection by the Securities and Exchange Commission. Our company prizes above all
its reputation for client service and the highest ethical standards.
In the course of its operations, Maverick utilizes the services of
a variety of prime brokerage firms that support implementation of
its trading strategy on behalf of Mavericks client funds. These
firms are among the most well-established institutions on Wall
Street. Beginning in the late 1990s and through the subsequent
years, the services offered by these firms included dividend enhancement programs.
The proposal was as follows: U.S. tax laws subjected dividends
paid by U.S. companies to foreign stockholders to a 30-percent
withholding tax. Under the relevant tax regulations, however,
foreign investors who received equivalent payments under total return swaps and foreign stockholders of U.S. companies who received substitute dividend payments from many foreign stock borrowers were not subject to the 30-percent withholding tax.
Mavericks financial institution service providers offered to help
Maverick enter into total return swap transactions that involved
Mavericks Cayman funds selling the U.S. company stock eligible
for an expected dividend to the financial institution for a price and
negotiated fees that would be substantially equivalent to getting
the value of the dividend. Alternatively, they suggested that Mavericks Cayman Island funds should consider lending the U.S. company stock to a Cayman affiliate of the service provider. In consideration for the loan, the financial institutions Cayman affiliate
would pay to the Maverick Cayman fund an amount that was
somewhat less than the dividend but exceeded the amount that it
would have received had it received the dividend net of the tax.
Mavericks tax personnel considered these proposals and examined the tax regulations that applied to these transactions. Taking
into account their compliance with the rules, the number of different blue chip firms offering the services, and their assurances
that the transactions had been thoroughly vetted, there seemed to
be little cause for concern that they were legitimate.
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Of the alternatives presented, however, those requiring that the
Maverick Cayman funds enter into swaps directly presented greater complexity relating to variable transaction terms and operational considerations than those providing for simple stock loans.
Moreover, IRS Notice 9766 appeared to provide express confirmation that substitute dividend payments received with respect to
stock loans to a borrower located in the same jurisdiction as the
lender would not be subject to the withholding tax.
Thus, in 1999, Maverick began engaging in dividend enhancement stock loans in reliance on Notice 9766. On a case-by-case
basis, a Maverick employee would ask one of the financial institutions that had offered to provide dividend enhancement services
whether it wished to borrow a particular security. If the financial
institution did wish to borrow that security, Maverick would negotiate terms with that institution. We did not engage in swaps or
other cross-border transactions for purposes of dividend enhancement, and we did not participate in any subsequent transactions
involving the borrowed shares that may have been undertaken by
the borrowers.
We engaged in these transactions through various financial institutions until 2007. In 2007, however, the business press published
a number of reports about these programs and suggested that the
IRS was taking a close look at their legitimacy. Understandably,
the financial institutions involved suspended the services until any
questions about the industry practices could be resolved. Maverick
estimates that its Cayman funds received approximately $63 million in substitute dividend payments beyond the amount that they
would otherwise have received as a result of participation in dividend enhancement stock loan transactions since 2000.
When the staff of this Subcommittee issued a request for information earlier this year, our counsel promptly complied by producing thousands of pages of documents. We have made our personnel available to assist the staff in understanding industry practices in this area and, on the basis of numerous discussions over
the past several months, believe we have developed a candid and
cooperative relationship. I am hopeful that they have conveyed consistent impressions of Maverick to you.
The regulation and taxation of financial transactions such as
those under discussion today are complex and evolving subjects. As
I have indicated, we believe we have acted in accordance with the
governing legal precedents and existing guidance, but understand
that those precedents may be subject to further interpretation or
revocation on the basis of further policy review such as the one you
are conducting here. Maverick will conform to any new laws and
regulations that result from this review.
Thank you very much.
Senator LEVIN. Thank you. And we also want to acknowledge the
cooperation of your company. You have indeed cooperated with the
Subcommittee. We very much appreciate it, and we are not the
least bit reluctant to thank you for that.
Mr. Potapchuk.
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TESTIMONY OF RICHARD POTAPCHUK,1 DIRECTOR OF TREASURY AND FINANCE, HIGHBRIDGE CAPITAL MANAGEMENT,
LLC, NEW YORK, NEW YORK
Mr. POTAPCHUK. Thank you, Mr. Chairman and Members of the

Subcommittee and staff. I want to thank you first for this opportunity to appear before you at this hearing. My name is Richard
Potapchuk. I am the Director of Treasury and Finance at
Highbridge Capital Management, LLC.
Highbridge is New York-based investment adviser that manages
a group of investment vehicles more commonly known as hedge
funds. We currently have $27 billion under our management.
Over a period of many years reaching back into the 1990s,
Highbridge has used financial instruments known as total return
swaps for a variety of different investment purposes. One such
purpose, which is the subject of todays hearing, is to gain financial
exposure to U.S. dividend-paying securities on behalf of non-U.S.
investors in a manner that does not subject certain of those distributions to these non-U.S. investors to a dividend withholding tax
of 30 percent. Highbridges position on this subject is set out in
more detail in my written testimony which has been submitted to
you earlier.
In these opening remarks, I would like to highlight three points.
First, Highbridge does not design investment strategies solely to
profit from the tax status of payments received under total return
swap agreements. Our investment decisions were and continue to
be guided by our analysis of the securities to which we want to
gain economic exposure. Once these investment decisions are made,
like any other prudent investment manager or investor, we choose
a form of investment, among other things, that is both lawful and
minimizes our costs.
Second, we believe the transactions in which we engaged are
lawful. In entering into these transactions, we have prudently
sought tax advice, legal advice, and we are mindful of the legal consensus about the transactions. In light of this consensus, total return swap transactions have been widely used in the financial industry for many years, as you well know.
Third is the question of whether changes in the tax treatment of
certain total return swap payments are appropriate and/or desirable? This question is a very complicated one and has no simple
or easy answer. And, of course, it is a decision really for you, the
lawmakers and the authors of the tax code. Highbridge will be
happy to provide any information or insight that it can to help address this question.
I am pleased, of course, to answer any questions you may have
on any of these subjects. And, again, I thank you very much.
Senator LEVIN. Thank you very much, Mr. Potapchuk, and we
want to also acknowledge the cooperation of your company. We appreciate that very much.
Mr. Wolf.
1 The
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TESTIMONY OF GARY I. WOLF,1 MANAGING DIRECTOR,
ANGELO, GORDON & CO., NEW YORK, NEW YORK
Mr. WOLF. Thank you, Mr. Chairman. My name is Gary Wolf. I

am a Managing Director at Angelo, Gordon & Co., a Delaware limited partnership and an SEC-registered investment adviser.
Angelo, Gordon & Co. was founded in 1988 and currently manages with its affiliates in excess of $19 billion. We seek to achieve
attractive risk-adjusted returns while preserving capital primarily
through investments in non-traditional strategies. Angelo, Gordon
& Co. manages capital across four principal lines: Distressed debt
and par loans; real estate; private equity; and hedged strategies.
Our client base is global and is comprised of institutions including
corporations, public funds, endowments, foundations, and high-networth individuals. We have associated offices in London, Amsterdam, Hong Kong, Seoul, Tokyo, Singapore, and Mumbai.
I joined the firm in 1993 and have been a convertible securities
research analyst and portfolio manager during the past 15 years.
Since 1995, I have been the head of the firms convertible securities
department.
The Subcommittee has asked me to testify about one investment
product which has been offered by investment banks for many
years. The use of this product, often referred to as a swap or a
CFD, has been common practice in the financial world and was
marketed to Angelo, Gordon & Co. by many of the largest, most sophisticated investment banks in the world. The investment banks
offering these products represented to Angelo, Gordon & Co. that
the structure of these transactions, including the tax implications,
had been cleared by their legal advisers, a position which was confirmed by our own legal advisers. Angelo, Gordon & Co. did not
construct or market these swap products but, rather, these products were created and marketed by the investment banks.
While the specific products offered by different investment banks
varied in particular aspects, this product in general is one in which
the investor is not the actual owner of the security but, rather, enters into a contract with the investment bank to receive or to make
payments which mirror the performance of the referenced security.
The investment banks, which is the counterparty to the contract,
may or may not actually hold or own the security. If the price of
the security rises, the investment bank is obligated under the contract to pay an amount equal to that increase. If the price of the
security falls, the investor must pay the bank an amount equal to
the decline. Under the contract, an amount equal to some or all of
the value of any dividend paid to stockholders during the contract
period is paid to the investor by the investment bank.
Depending on the specific circumstances of a given transaction,
sometimes the best way to maximize returns for our investors was
to engage in a swap transaction. While I am not a tax expert, it
is my understanding that while the person or entity actually owning the security and receiving the actual dividend payment may be
subject to the Federal tax on dividends, the tax treatment of a payment received under a contract is determined by other provisions
of the tax code. At times, this tax treatment of swaps will provide
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a tax benefit resulting in a higher total yield on the investment for
a foreign investor. This benefit was a central aspect of the marketing pitches that were made to us by the investment banks.
While the tax consequences were a significant factor considered
in deciding whether to enter into a swap transaction, this was far
from the only consideration. In fact, there were other significant
economic realities that factored into the decision to enter into a
swap transaction, including increased leverage and competitive
transparency benefits. While swap transactions do have a significant number of positive benefits, including those related to leverage, transparency, and tax, there are a number of potential negative consequences or risks associated with such transactions. There
was the economic reality that since we would not be the actual
owner of the security, we would not have the normal stockholders
role in the control of the company. Also, there were often significant transaction costs associated with swap transactions, including
the fees for leverage. In addition, unlike those situations where we
held the actual security under a swap contract, we were exposed
to the risk that our counterparty would not make the payments
called for by the contract. Recent events have demonstrated that
counterparty risk is real.
We were told by the investment banks, as well as by our own
legal advisers, that this form of investment offered a legal way for
us to enhance or maximize our total return since we would be receiving contract payments and not actual dividend payments. The
investment strategies we pursue are not designed around dividends
but, rather, focus on movement in the price of the equity. While the
value of any dividends paid during the time we held a position in
a company would be, we hoped, minor compared to what we would
realize from the movement of the price of the security, we were attracted to a form of investment that resulted in lower rather than
higher taxes for our investors. Just as an individual deciding between renting and homeownership is well advised to consider the
tax consequences of each approach, it is incumbent on financial
firms and institutions to also consider the tax consequences, among
many other factors, inherent in a given transaction.
The tax advantage of these products was certainly one of the primary considerations that made them attractive when they were
marketed to us by the investment banks. But the tax advantage
was not the only substantive aspect of these contracts. During the
time period when Angelo, Gordon & Co. was active in swap transactions, leverage was also a considerable factor driving such decisions. In fact, often one of the most important negotiation points
when entering into a swap transaction was the amount of leverage
that could be obtained. Leverage was deemed to be so critical to investment decisions that the prime brokerage arms of investment
banks would compete for business on the basis of the amount of leverage that could be offered.
Another significant benefit associated with swap transactions relates to competitive transparency. When Angelo, Gordon & Co.
holds a security in swap, it prevents other competing investors
from tracking and either mirroring or undermining our positions.
Given the myriad of benefits and positive economic results that
can be realized through swap transactions, Angelo, Gordon & Co.
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engaged in such transactions on a global level, and this activity
was not simply limited to U.S. dividend-paying securities. In fact,
Angelo, Gordon & Co. has entered into swap transactions for securities ranging from U.S. convertible bonds to bank debt to foreign
securitiesnone of which would be subject to the U.S. withholding
tax even if owned directly. And this has been the case with both
our domestic and foreign funds.
My understanding is that some of the recent media discussion regarding swap transactions has centered on the practice of acquiring
a position in a security shortly before dividend date and then
exiting that position shortly after the dividend date, often referred
to as bracketing a dividend. Not only did Angelo, Gordon & Co.
not engage in bracketing dividends, but such a practice runs
counter to Angelo, Gordon & Co.s core investment philosophy of focusing on well-researched, longer-term investments. Almost always,
Angelo, Gordon & Co. would hold the security in swap for at least
9 months, and sometimes as long as 2 years. In only a handful of
instances did Angelo, Gordon & Co. hold a security in swap for less
than 30 days.
Finally, due to economic and business realities in the marketplace, and at Angelo, Gordon, and Co. the firm currently engages
in very few swap transactions, and the number of swap transactions engaged in has decreased significantly over time. Given the
decrease in opportunities in the marketplace, Angelo, Gordon &
Co.s dedicated convertible securities funds, which used to engage
in such swap transactions, closed in late 2006. Angelo, Gordon &
Co.s real estate securities funds, which also used to engage in such
swap transactions, closed in late 2007. Notably, the significant decrease in swap transactions has had no relationship to any change
in the tax treatment of dividend-based payments but, rather, is
based on other economic and business realities.
I hope my testimony has aided the Subcommittee in understanding these issues, and I will do my best to answer any questions you might have.
Senator LEVIN. Thank you very much, Mr. Wolf, and thank you
and your company for your cooperation also with the Subcommittee.
Mr. Manogue, let me start with some questions to you. You have
engaged in the stock loan transactions with financial institutions
to enhance dividends for some time. Is that correct?
Mr. MANOGUE. That is correct.
Senator LEVIN. What was the purpose of those transactions?
Mr. MANOGUE. The purpose of the transactions was to enhance
dividends.
Senator LEVIN. And how long would a typical transaction last?
Mr. MANOGUE. Over the years, that has been negotiated, so it
has been different time periods. But it ranged from 30 days down
to 15 days.
Senator LEVIN. And then after the 15 days or 30 days, or whatever the period was, the stock would be returned?
Senator LEVIN. Now, when you say that the purpose of these
transactions, loan transactions, was for dividend enhancement
and we appreciate your candor on thatthe dividend itself was not
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enhanced, as I understand it, but rather the amount of the dividend was not enhanced. The enhancement came through the tax
not being paid. Is that correct?
Mr. MANOGUE. Through the substitute dividend payment, yes,
correct.
Senator LEVIN. And that not being taxable.
Mr. MANOGUE. Correct.
Senator LEVIN. Is that why that particular technique was pitched
to you by the financial institution, in order to enhance the dividend
through its not being taxable? Was that the basis of the pitch to
you from whatever financial institution was
Mr. MANOGUE. Correct. That was the premise. And I just want
to clarify one point. I am not a tax expert, so I am not sure that
a substitute dividend is not necessarily taxable.
Senator LEVIN. All right. But the payment that you received was
not taxable.
Senator LEVIN. OK. Now, Mr. Wolf, I wonder if you would take
a look at Exhibit 16 in the book that is in front of you.1 If you look
at page 2 of that exhibit where it says that Gary Wolf called regarding the swap that was discussed?
Mr. WOLF. Yes, sir.
Senator LEVIN. And he said that heGary Wolf called regarding
the swap that was discussed on his prefs.
Mr. WOLF. Yes.
Senator LEVIN. Prefs, what is that?
Mr. WOLF. Preferred securities.
Senator LEVIN. And he said that he is being quoted by other
brokers on the street 100-percent dividend doing it via a total return swap as opposed to the 92 percent that we offer. He said he
would be looking to do this on a more long-term position as opposed
to ones that he knows they will be getting out of. Is that accurate?
Do you remember that phone call?
Mr. WOLF. Vaguely.
Senator LEVIN. All right. And to the extent that you remember
it, was the return on that swap important to you?
Mr. WOLF. Sure.
Senator LEVIN. The transactions that you engaged in there were
aimed at enhancing your dividend. Is that correct?
Mr. WOLF. That was one of the significant factors in entering
into a total return swap or a CFD.
Senator LEVIN. Was that, would you say, a significant factor? Is
that the way you would phrase it?
Mr. WOLF. Well, I would say it is a very significant factorin
fact, a primary factor; but not the only economic substance to the
transaction.
Senator LEVIN. All right. And, Mr. Potapchuk, let me ask you the
question. Did you engage in the transactions that we are discussing
here to enhance the dividend?
Mr. POTAPCHUK. We do engage and have engaged for quite some
time, back into the 1990s, in transactions involving taking exposure to securities in the form of total return swap, yes. With re1 See
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spect to the stock lending transactions that were referred to, the
answer to that is no.
Senator LEVIN. In terms of the swaps?
Mr. POTAPCHUK. In terms of stock loan transactions, no.
Senator LEVIN. What about swaps? Did you engage
Mr. POTAPCHUK. Swaps, yes. We engaged, have engaged, and
continue to engage in transactions that involve taking exposure to
securities in the form of total return swaps.
Senator LEVIN. All right. And the principal purpose there
was
Mr. POTAPCHUK. Well, the principal purpose
Senator LEVIN. The principal reason, I think your testimony is,
although not necessarily the only reason, of these total return
swaps was to reduce the tax burden on the non-U.S. investors. Is
that your testimony I am reading from?
Mr. POTAPCHUK. Yes. There are other economic reasons for entering into a swap, but quite frankly, the most compelling one by far
is the tax savings. And without that tax savings, a lot of those
swaps, I would say, at Highbridge would not have occurred.
Senator LEVIN. Thank you.
Mr. POTAPCHUK. Some would and some would not.
Senator LEVIN. But many of them would not have occurred?
Mr. POTAPCHUK. That is true.
Senator LEVIN. Mr. Manogue, you said that in 2007 a number of
financial institutions suspended offering dividend enhancement
services.
Senator LEVIN. And how many stopped, and who were they?
Mr. MANOGUE. To the best of my knowledge, all of them stopped.
Senator LEVIN. Let me ask each of you, how did your firm learn
about these types of transactions in the first place? Did this come
from a financial institution of some kind?
Mr. MANOGUE. Yes, financial institutions would market us for
this product.
Senator LEVIN. Mark you? What does that mean?
Mr. MANOGUE. Market.
Senator LEVIN. Oh, market.
Mr. MANOGUE. They would come up and try to convince us to buy
their product.
Senator LEVIN. Who are some of those institutions; do you remember?
Mr. MANOGUE. Over the years they have ranged from every
major financial institutions, but, in particular, for us it was UBS,
Merrill Lynch, Morgan Stanley, Lehman Brothers, Nomura, and
ING.
Senator LEVIN. OK, so they initiated it, came to your company
to try to persuade you to use the type of transaction?
Mr. MANOGUE. Yes, they did.
Senator LEVIN. Mr. Potapchuk, did you initiate this or was this
a financial institution which marketed this to you?
Mr. POTAPCHUK. Well, as I explained, what we do at Highbridge
is enter into total return swap transactions and not the other stock
lending type transactions. We enter into total return swaps for,
again, many other reasons in many other markets. We are very
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aware that under current tax law, payments under total return
swaps are not subject to dividend withholding, so
Senator LEVIN. There was not a financial institution which came
to you to market it?
Mr. POTAPCHUK. They all come to us to market it in the sense
that we may be doing it with someone, with a UBS company, and
they would like us to do it with them instead just to gain some
market share of our business. But once approached by any of these
firms, we have a practice whereby internally we vet any of the
issues that they bring up. We confer with our own in-house counsel, our own in-house tax advisers. We go outside to the extent we
need to with our tax professionals. And we basically came to the
same conclusion as they did with respect to the appropriate tax
treatment of these payments under the swap contracts.
Senator LEVIN. But these total swaps are marketed to you?
Mr. POTAPCHUK. They are marketed to us, just like a normal
prime brokerage is marketed to us, yes.
Senator LEVIN. And when they are marketed to you as the principalI will leave it there.
Mr. Wolf, how did your company get involved in the swaps? Was
this something internal, or was this marketed to you by financial
institutions?
Mr. WOLF. It was marketed to us by a number of major financial
institutions.
Senator LEVIN. And who are they?
Mr. WOLF. Several on this list that areLehman Brothers, Deutsche Bank, Morgan Stanley, Goldman Sachs, Merrill Lynch, and
others.
Senator LEVIN. OK. Mr. Manogue, is Maverick LDC a U.S. company?
Mr. MANOGUE. No. It is a Cayman Island entity.
Senator LEVIN. And how many people does Maverick have in the
Caymans?
Mr. MANOGUE. We do not have any.
Senator LEVIN. So this is a company that you own that is in the
Caymans or listed in the Caymans, but you do not have any people
there?
Mr. MANOGUE. Correct. It is registered in the Caymans.1
Senator LEVIN. Registered. Thanks. So you do not have an office
there?
Senator LEVIN. And how many people do you have in the United
States?
Mr. MANOGUE. Close to 200 people.
Senator LEVIN. And where are the investment specialists who
make all the investment decisions, perform all the investment decisions, and perform all the research located?
Mr. MANOGUE. We have several offices here in the United States.
The primary office would be Dallas as well as New York City.
Senator LEVIN. But all the 200 or so are in the United States?
1 See Exhibit No. 35 which appears in the Appendix on page 300 for clarification of these remarks.
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Mr. MANOGUE. Almost all of them. We do have some folks in
London, Taipei, and Shanghai.
Senator LEVIN. All right. Now, when you performed the stock
loan transactions with UBS, the record indicates that the transactions were with UBS Cayman Island facility. If you would take
a look at Exhibit 10,2 and this is the way UBS described its Cayman Island facility. It said, UBSCL is not licensed, registered, or
regulated, e.g., by reason of capital adequacy requirements, as a
broker-dealer or similar entity in any jurisdiction, cannot access
the capital markets except through a broker-dealer, and does not
hold itself out as a broker-dealer. UBSCLthat is their Cayman
operationis not and does not hold itself out as being capable of
servicing customers, e.g., it does not possess adequate systems or
personnel. UBSCLs counterparties do not view themselves as
UBSCLs customer. And UBSCL does not have any fiduciary duties
to its counterparties. UBSCL does not make markets, possess inventory, or have an established place of business. UBS does not
hold itself out as a merchant or as willing to enter into either side
of securities or derivative trades.
I cannot think of a better definition of a shell than that one.
Now, your operation in the Caymans, as you just indicated, was
a shell operation, and over the years the stock loan transactions between the two Cayman Islands shells cost the U.S. Government
about $90 million in dividends that were not withheld. And that
loss came because the transactions supposedly took place between
the two Cayman entities. So far are you with me?
Mr. MANOGUE. I am with you, Senator.
Senator LEVIN. OK. Do you disagree with anything I have said
so far on this question?
Mr. MANOGUE. Well, I am not sure what the question is, but
Senator LEVIN. Well, what I have said so far, that there were two
entitiesthere was a loan transaction betweenone of them was
your entity, which you have described as not having any people
there and being registered there; the other one, UBS described just
the way I have just read it.
Mr. MANOGUE. Yes.
Senator LEVIN. Were you aware that UBS Cayman
Mr. MANOGUE. We knew of the entity, yes.
Senator LEVIN. All right. Now, do the financial institutions that
Maverick has dealt with more recently also run these trades
through these kind of registered offices in offshore jurisdictions?
Mr. MANOGUE. Yes.
Senator LEVIN. And, again, I think you have been clear that the
trades are structured through these jurisdictions as a way of enhancing your dividend, as you put it. So I think you have been
clear on that.
Now, Mr. Wolf, does Angelo, Gordon & Co. have a Cayman Island hedge fund?
Mr. WOLF. We haveyes.
Senator LEVIN. And how many people do you have in the Caymans?
Mr. WOLF. We do not have any employees in the Caymans.
2 See
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Senator LEVIN. Do you have an office in the Caymans?
Mr. WOLF. No. We have an administrator.
Senator LEVIN. No employees?
Mr. WOLF. That is correct.
Senator LEVIN. And about how many people work for Angelo,
Gordon & Co.?
Mr. WOLF. About 250.
Senator LEVIN. And none of them are in the Caymans. Where are
they?
Mr. WOLF. They are in New York, offices in London, Amsterdam,
several in Asia, Chicago, and Los Angeles.
Senator LEVIN. OK. Thank you.
Mr. Potapchuk, what about Highbridge? Does Highbridge have a
Cayman hedge fund?
Mr. POTAPCHUK. The funds that Highbridge manages are generally registered in the Cayman Islands, yes.
Senator LEVIN. And how many folks do you have in the Caymans?
Mr. POTAPCHUK. We have none. We have an administrator, some
legal experts, etc.
Senator LEVIN. But no employees there?
Mr. POTAPCHUK. No employees.
Senator LEVIN. And do you have an office there?
Mr. POTAPCHUK. We do not have an office there.
Senator LEVIN. Mr. Manogue, would you take a look at Exhibit
7, please?1 Leading up to my question, Mr. Manogue, about Exhibit
7, let me see if you would agree with this. According to the materials that you have provided to the Subcommitteeand, again, we
appreciate that cooperationyour firm received about $63 million
in dividend enhancements. Now, those are portions of dividends
that would normally be withheld but are not under the transactions that you engaged in, and the financial institutions that you
were trading with received about $31 million, the portion of Mavericks enhancement that was paid to them. That would be money,
obviously, which would have otherwise been withheld and turned
over to the U.S. Government.
Now, I want to ask you about Exhibit 7. What I have said so far
is based on your documents, and so I will proceed from there unless
you disagree with those figures that I just gave.
Mr. MANOGUE. I do not disagree.
Senator LEVIN. All right. Thanks.
Now, Exhibit 7, this is a communication between Mr. Chisholm
of Maverick and a representative from Ernst & Young. In the
memo, Mr. Chisholm raises the question of whether money from
dividend enhancement transactions should be reserved or paid to
the government as part of Mavericks tax return. And this is what
he says: Now that June 15th is approaching, we are consideringagain, I am reading from Exhibit 7whether we need to
go ahead and remit the 2006 income tax withholding that we accrued for FIN 48 purposes in connection with the stock loan fee income earned during 2006. We determined in December that we
should probably accrue these taxes even though nothing is actually
1 See
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withheld by our other brokers. We will need to address whether or
not to pay these taxes for pre-2006 years whenever we file protective returns for those years.
Has Maverick paid any money to the government as part of a tax
payment related to these dividend enhancement transactions?
Mr. MANOGUE. I am not aware of that. I would have to talk to
our tax advisers and service folks.
Senator LEVIN. All right. Let us know then. Would you do that
for the record?2
Mr. MANOGUE. We will.
I believe this memo also is driven by a discussion on compliance
with FIN 48. There is a reserve that has been determined that we
should take related to fees that we earn for lending our stocks out.
So I believe there are two issues being discussed in this memo.
Senator LEVIN. All right. Now, that same exhibit, I think it is
page 5, but at the bottom it is MAV0001119. Do you see that page?
It is in the lower right-hand corner.
Mr. MANOGUE. Yes.
Senator LEVIN. OK. Now, if you look at the top paragraph there,
this is addressed to Joe Bianco, who is a Maverick employee. Is
that correct?
Mr. MANOGUE. No. He works for Ernst & Young, I believe.
Senator LEVIN. Matt Blum at the bottom. Do you see he works
for Ernst & Young?
Mr. MANOGUE. As well, yes.
Senator LEVIN. So they both work for Ernst & Young?
Mr. MANOGUE. I believe so, yes.
Senator LEVIN. All right. As you read the first paragraph, if the
prime broker does not withhold and the IRS catches the prime
broker, then perhaps the prime broker can go after Maverick for
contribution or indemnification, complex point if the contract is silent, but if the IRS figures out what is going on, the IRS can bypass the prime broker and go straight after Maverick for failure to
pay tax imposed under Section 881. The only limit is that the IRS
may not collect the tax twice.
So if the IRS figures out what is going on, the IRS can go
straight after Maverick. Were you aware that was the Ernst &
Young opinion?
Mr. MANOGUE. I was not until preparing for this testimony.
Senator LEVIN. OK. Mr. Wolf, how much withholding did Angelo,
Gordon & Co. get back from these dividend enhancement transactions over the years? Do you have that figure for us?
Mr. WOLF. For the years 2000 to 2007, the total amount of U.S.
dividends that Angelo, Gordon & Co. received in offshore funds was
$137 million. So we would have gotten contract payments of $137
million.
Senator LEVIN. All right.
Mr. WOLF. Therefore, what you were calling dividend30 percent of that number is the number.
Senator LEVIN. Thirty percent of that $137 million.
Mr. WOLF. Correct.
2 See
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Senator LEVIN. And, Mr. Potapchuk, how much withholding did
Highbridge get back from the dividend enhancement transactions
over the years?
Mr. POTAPCHUK. The analysis that we have done and submitted
to the staff previously covered the 6-year period from 2002 through
2007, where it is indicated that if during that time there was a 30percent withholding requirement on payments received on swap
transactions, the likely amount of withholding amounts that would
have occurred at Highbridge would have been approximately $100
million. And I can walk you through that number a bit. It works
like this.
We received during that period about $425 million in payments
under total return swap contracts. These were received by our master fund. Our master fund has a combination of U.S. and non-U.S.
investors. The U.S. portion ranges from 10 to 20 percent. So lets
say that 15 percent of that number, or about $60 million, would not
be subject to withholding because they would be directly received
bythey would be indirectly effectively received by U.S. persons.
That would bring us down to about $360 million.
Additionally, there are several amounts included in those payments received that would otherwise not be taxable. For instance,
in many cases, in particular with respect to large dividends that
are paid, many of the dividends are treated as returns of capital
for U.S. tax purposes. They are not paid out of current earnings
and profits of the corporations.
Conservatively, we estimate that about $20 million of that total
would have been made up of something classified as return of capital by the corporations, which would bring us to $340 million, and
about 30 percent of that number gets me to the $100 million over
the 6-year period ending in 2007.
Senator LEVIN. I have got it. And I can ask both of you, Mr. Wolf
first, was any of that $137 million ever paid back to the government as part of a tax payment?
Mr. WOLF. Well, again, it was not the $137 million. That was
the
Senator LEVIN. The 30 percent of that, was any of that ever paid
to the government?
Mr. WOLF. Not to my knowledge.
Senator LEVIN. All right. And do you know, Mr. Potapchuk, if
any of that approximately $100 million you talked about was ever
paid to the government?
Mr. POTAPCHUK. No, it was not paid to the government at all.
Mr. MANOGUE. Senator, if I may, I would like to clarify one other
point.
Senator LEVIN. Sure.
Mr. MANOGUE. We discussed ExhibitI believe it is Exhibit 7,
page MAV0001119.
Senator LEVIN. Yes.
Mr. MANOGUE. The memo from Matt Blum to Joe Bianco of
Ernst & Young. I believe after having a chance to look at this, the
first two paragraphs refer to a discussion about the reserve for
stock loan fees that have been paid in our tax return. The last
paragraph in that email exchange refers to dividend enhancement,
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where they conclude that there is a need to come up with a better
than 50-percent chance of succeeding under FIN 48 analysis. So I
believe the top two paragraphs are referring to something different,
not dividend enhancement.
Senator LEVIN. The one I read you do not think referred to
Mr. MANOGUE. I do not.
Senator LEVIN. But you are confident that this memo was an internal memo at Ernst & Young?
Mr. MANOGUE. Yes.
Senator LEVIN. And that the Joe referred to is an Ernst &
Young employee?
Mr. MANOGUE. Joe Bianco, yes.
Senator LEVIN. And that these points in this memo were not
shared with you?
Mr. MANOGUE. They were not shared with me, no.
Senator LEVIN. I mean with your company.
Mr. MANOGUE. I believe they were shared and through the email
chain would have gotten to our tax department.
Senator LEVIN. Who in your tax department? Who in that email
chain
Mr. MANOGUE. Keith Hennington and Chad Chisholm.
Senator LEVIN. So your tax department was aware of this document, then?
Mr. MANOGUE. Yes.
Senator LEVIN. OK. Let me again thank our witnesses, and I
would note that these hedge funds are not the only hedge funds
that engage in these activities. These are representative of these
actions and activities that go on, and we selected three because we
needed to have representative witnesses here, and you have been
helpful. We appreciate it and you are excused.
Mr. MANOGUE. Thank you.
Mr. POTAPCHUK. Thank you.
Mr. WOLF. Thank you.
Senator LEVIN. Let me now welcome our third panel of witnesses:
John DeRosa, the Managing Director and Global Tax Director of
Lehman Brothers, New York; Matthew Berke, the Managing Director and Global Head of Equity Risk Management of Morgan Stanley of New York; and Andrea Leung, the Global Head of Synthetic
Equity Finance of Deutsche Bank of New York.
Let me thank each of you again for being here today, and pursuant to Rule VI, all witnesses who testify before the Subcommittee
are required to be sworn. So I would ask that you please stand and
raise your right hand. Do you solemnly swear that the testimony
that you will give to this Subcommittee today will be the truth, the
whole truth, and nothing but the truth, so help you, God?
Mr. DEROSA. I do.
Mr. BERKE. I do.
Ms. LEUNG. I do.
I think you were all here when we described the timing system,
so I will not repeat that. Mr. DeRosa, we will have you go first, followed by Mr. Berke, and then Ms. Leung. And then we will turn
to questions.
So, Mr. DeRosa, you may proceed.
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TESTIMONY OF JOHN DeROSA,1 MANAGING DIRECTOR AND
GLOBAL TAX DIRECTOR, LEHMAN BROTHERS INC., NEW
YORK, NEW YORK
Mr. DEROSA. I am John DeRosa, Managing Director and Global

Tax Director at Lehman Brothers. I appreciate the opportunity to
appear before the Subcommittee today on behalf of Lehman Brothers.
Lehman Brothers, an innovator of global finance, serves the financial needs of corporations, governments, municipalities, and
high-net-worth individuals worldwide. Founded in 1850, Lehman
Brothers maintains leadership positions in equity and fixed-income
sales, trading and research, investment banking, private investment management, asset management, and private equity. The
firm is headquartered in New York, with regional headquarters in
London and Tokyo, and operates offices worldwide.
As global tax director, I can state with confidenceand I want
to emphasizethat Lehman Brothers takes its obligations under
the U.S. tax code very seriously. Lehman Brothers has worked diligently to follow the letter and spirit of the law governing both equity swaps and stock loan agreements. The rules governing the applicability of U.S. withholding tax for payments made to non-U.S.
counterparties on swap and stock loan transactions referencing
U.S. equities are clear.
Under Treasury Regulation Sec. 18637(b)(1), the source of notional principal contract incomei.e., swap paymentsis determined by reference to the residence of the taxpayer receiving the
payment, not the residence of the payor on the underlying referenced asset. Thus, when Lehman Brothers makes a payment on
an equity swap referencing a U.S. asset to a non-U.S. counterparty,
the payment is sourced to the residence of the swap counterparty
and does not attract U.S. withholding tax.
With respect to stock loans, IRS administrative Notice 9766 exempts from U.S. withholding tax in-lieu payments made to a foreign counterparty when the criteria articulated in that notice are
met. Thus, under these rules, the transactions that the Subcommittee is reviewing do not attract U.S. withholding tax. When
Lehman Brothers makes payments, whether pursuant to an equity
swap or a stock loan, to foreign counterparties referencing U.S. equities, Lehman Brothers complies with these rules. We understand
that Treasury and the IRS may now be considering whether these
rules should be changed going forward, including possibly advancing a new rule that would recharacterize some, but not all, of these
transactions. I can assure you that, to the extent that Treasury or
the IRS now changes these rules, Lehman Brothers will comply
with those new rules.
Equity swaps and stock loan agreements are basic financial instruments that have been in existence for decades and are critical
to the proper functioning of todays global capital markets. There
are many reasonstotally unrelated to withholding taxwhy clients use these instruments. Fundamentally, clients employ these
instruments to gain economic exposure to underlying assets with1 The
prepared statement of Mr. DeRosa with an attachment appears in the Appendix on page
80.
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out beneficially owning those assets. These instruments can provide clients with leverage, operational and administrative efficiency, and other balance sheet and regulatory capital benefits. In
return, Lehman Brothers receives financing spreads and commissions as appropriate. These financial instruments, like many others
such as municipal bonds, offer tax efficiency in certain circumstancesa result fully recognized by Treasury and the IRS.
In fact, however, most of Lehman Brothers equity swaps and
stock loans have nothing to do with U.S withholding tax efficiency.
The overwhelming majority of Lehman Brothers equity swaps and
stock loans simply do not implicate U.S. withholding taxes at all
because they have one or more of the following characteristics:
One, the counterparty takes a short, rather than a long, position;
two, there is no distribution payment on the underlying referenced
security; three, the swap or stock loan is not held by the
counterparty over a dividend record date; four, the underlying referenced security makes a payment characterized for tax purposes
as interest, which is generally not subject to U.S. withholding tax;
five, the underlying security is foreign, rather than United States;
or, six, the counterparty is a resident in the United States.
It has been well understood for years that even when these basic
financial instruments do reference underlying U.S. dividend-paying
securities and are entered into as long positions by non-U.S.
counterparties over a dividend record datea relatively small universe of the transactions at Lehman Brothersthey do not attract
withholding tax under U.S. tax laws. As I stated earlier, the basic
rule for equity swaps, established by Treasury in 1991, is that payments made to non-U.S. counterparties pursuant to these basic financial instruments must be sourced based on the residence of the
counterparty and, therefore, do not implicate U.S. withholding
taxes. In addition, an IRS administrative notice specifically exempts from U.S. withholding taxes in-lieu payments on stock loan
transactions like the ones in which Lehman Brothers participated.
These fundamental rulesand the resulting tax treatment for certain counterpartieshave long been understood by market participants and, notably, the Department of Treasury and the IRS.
Indeed, most, if not all, of the major Wall Street investment
banks and commercial banks engage in equity swap and stock loan
transactions referencing U.S. underlying equities with non-U.S.
counterparties. Over the last 15 years, numerous commentators in
widely respected taxation journals have addressed the withholding
tax consequences of equity swaps similar to those offered throughout Wall Street, including articles by the current chief of staff for
the Joint Committee on Taxation and his former law firm. In 1998,
a Notice of Proposed Rulemaking was published in the Federal
Register that expressly addressed the same issue. It said, Treasury
and the IRS are aware that in order to avoid the tax imposed on
U.S. source dividends . . . some foreign investors use notional principal contract transactions based on U.S. equities. . . . Accordingly,
Treasury and the IRS are considering whether rules should be developed to preserve the withholding tax with respect to such transactions.
In May 2007, the Practicing Law Institute hosted a panel focused
specifically on the U.S. withholding tax aspects of equity swaps and
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stock loan transactions. The panel included well-recognized practitioners in the tax field including, most notably, a representative
from the IRS. Lehman Brothers has provided the Subcommittee
with a copy of that panels presentation.
Despite the IRS clear recognition for at least a decade that these
financial instruments, in certain circumstances, may have U.S.
withholding tax implications, to date, no new rules governing equity swaps or stock loan arrangements have been promulgated.
This is not surprising when one considers what a fundamental
change any such new rules would present, particularly if those new
rules were to articulate circumstances warranting recharacterization of certain transactions.
I should note, however, that even under existing law, Lehman
Brothers exercised appropriate care when entering into financial
instruments. Lehman Brothers consulted extensively with tax experts both internally and at major Wall Street law firms, receiving
both oral and written advice. Based on the advice of its legal counsel, Lehman Brothers put in place guidelines and parameters governing the use of these instruments. For example, Lehman Brothers instituted a minimum duration requirement and established requirements governing the size of underlying baskets. Under the
prevailing rules applicable to equity swaps and stock loans, transactions meeting these guidelines should not be recharacterized for
tax purposes. In other words, according to the U.S. tax laws as currently written, the payments made to non-U.S. counterparties pursuant to equity swaps must be sourced to the residence of the
counterparty and, therefore, do not trigger U.S. withholding taxes.
Likewise, the type of in-lieu payments made by Lehman Brothers
on stock loans are specifically exempt from withholding tax pursuant to the IRS administrative notice mentioned earlier.
Lehman Brothers made every effort to ensure that its equity
swaps and stock loans complied with these guidelines. Indeed, we
know that in some situations clients approached Lehman Brothers
in an effort to transact in instruments in a way that did not align
with our product parametersfor example, by seeking to hold a position for a very short period of time around a dividend record
dateand that Lehman Brothers refused to engage in those transactions.
But Lehman Brothers did even more than that. In October 2007,
when David Shapiro, Senior Counsel in the Treasury Departments
Office of Tax Policy, stated publicly that Treasury would welcome
input from the industry on the proper tax treatment, Lehman
Brothers responded. First, Lehman Brothers participated with the
Securities Industry and Financial Markets Association to help develop a framework on behalf of the industry. This analytical framework was shared with Treasury and the IRS. Second, Lehman
Brothers proactively and independently engaged the Treasury Department in constructive discussions explaining the equity swap
business and a possible new framework. These discussions culminated with Lehman Brothers submission earlier this year of a
request to the IRS, pursuant to the Industry Issue Resolution Program, for official guidance. I have attached a copy of that submission to my written testimony.
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As I said at the outset, if new rules governing the tax treatment
of equity swaps and stock lending transactions are promulgated,
Lehman Brothers will comply with those new rules. In the meantime, Lehman Brothers has made a concerted and good-faith effort
to comply with current tax law. We will continue to do so.
Thank you again for the opportunity to appear here today. I
would be happy to answer any questions you may have.
Senator LEVIN. Thank you, Mr. DeRosa. Mr. Berke.
TESTIMONY OF MATTHEW BERKE,1 MANAGING DIRECTOR
AND GLOBAL HEAD OF EQUITY RISK MANAGEMENT, MORGAN STANLEY & CO., NEW YORK, NEW YORK
Mr. BERKE. Thank you, Senator. My name is Matt Berke, and I

am a Managing Director and Global Head of Equity Risk Management for Morgan Stanley. Thank you for inviting Morgan Stanley
to participate in todays hearings. We have been pleased to assist
the Subcommittees staff as it examined these issues, and I hope
that I have been a useful resource and will continue to be today.
I understand that the Subcommittee is focused on two issues:
Whether industry participants are complying with applicable laws
regarding dividend withholding obligations, and whether new laws
and policies may be appropriate. I cannot speak for others, but
Morgan Stanley believes that its practices in these areas are in
compliance with relevant tax laws and regulations, and on the conservative end of the spectrum. We have submitted a longer written
statement for the record, but I want to summarize a few key points
now about our equity derivatives and stock lending businesses.
Swap trading is widespread and commonly accepted in todays financial markets, and Morgan Stanley is a leader in the equity
swap market. I understand that the Subcommittee is particularly
interested in a subset of the equity swap business, namely, total return swaps with non-U.S. counterparties obtaining long exposure to
dividend-paying U.S. stocks. I will refer generally to these as
swaps or total return swaps in my comments and in response
to your questions. But I should be clear that the swaps I am referring to constitute a small subset of Morgan Stanleys overall global
swaps business.
There are a variety of reasons why an investor may choose to
transact via swap, including leverage, operational efficiency, and in
some instances, tax benefits. I know from talking with the Subcommittee staff members and from reading the staff report that
there is a great deal of focus on business purpose and client motivation for these trades. Let me start by saying our clients are, first
and foremost, investors. Their business purpose, their motivation
when they transact, is to put capital at risk in hopes of obtaining
a positive investment return. Only after making their threshold investment decision of what to buy and what to sell do they begin
to confront the issue of the best means by which to put their capital at risk, and tax can be an important part of that decision.
Non-U.S. counterparties can choose to transact in swap in part
to reduce their tax obligations. This is a legitimate choice and permissible under applicable tax laws, provided the swaps are exe1 The
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prepared statement of Mr. Berke appears in the Appendix on page 88.
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cuted properly. We believe our swaps are properly executed in compliance with relevant tax laws and regulations.
The relevant laws, as I understand them, provide that payments
made under swap contracts are treated differently than dividends
paid to owners of physical shares. That is the law, and it reflects
a decision made by policymakers. At Morgan Stanley, our focus is
on ensuring that what we offer to clients as swaps are, in fact,
swaps. And we do not enter into swaps that could be recharacterized as repurchase agreements or agency arrangements, which are
subject to different U.S. tax treatment.
To take a conservative position, Morgan Stanley has always prohibited two-sided crosses to reestablish a physical long position and
currently prohibits swaps with crosses on either end. We also do
not allow our swap counterparties to direct our hedge or tell us
how or whether to vote any shares that we may choose to purchase
as part of a hedge.
I understand the Subcommittee is also interested in the tax
treatment of certain stock lending transactions. As one of the
worlds leaders in equity financing services, Morgan Stanley is active in borrowing and lending stocks both inside and outside the
United States.
One aspect of our stock loan business is an intermediation business with Morgan Stanley standing between custodial lenders and
borrowers of U.S. dividend-paying stocks and earning a spread between the cost of borrowing and the fees generated by our on-lending activities. At Morgan Stanley, the stock loan activity you have
focused on is conducted by a desk in our London office, focused
largely on non-U.S. stocks but involving some U.S. stocks as well.
We believe we conduct this business in compliance with IRS Notice
9766, as we understand it, and that our practices are on the conservative end of the spectrum.
Finally, I would like to say a word about tax policy in general.
The tax treatment of dividends generally differs from the tax treatment of derivatives. Some have suggested a comprehensive rethinking of how we tax capital investment returns, regardless of
whether the return is classified as a dividend or not, and regardless of whether the investor is U.S. or non-U.S. In light of todays
hearings, additional guidance on which investment structures the
IRS would critique or respect would be helpful, particularly for organizations like Morgan Stanley, where we try to conduct our business on the conservative end of the spectrum.
Thank you for the opportunity to testify, and I look forward to
your questions.
Senator LEVIN. Thank you, Mr. Berke. Ms. Leung.
TESTIMONY OF ANDREA LEUNG, GLOBAL HEAD OF SYNTHETIC EQUITY FINANCE, DEUTSCHE BANK AG, NEW YORK,
NEW YORK
Ms. LEUNG. Good morning, Chairman Levin and Members of the

Subcommittee. My name is Andrea Leung. I am the Global Head
of Synthetic Equity Finance for Deutsche Bank AG. I am based in
New York and have worked at Deutsche Bank since 2002.
Among my responsibilities is the management of the synthetic
equity desk in Deutsche Banks New York office. Our clients can
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use synthetic equity to replicate the economics of a long or a short
position in any particular equity security or in a basket of securities. Specifically, we enter into derivative or swap transactions
with clients who want the economics of purchasing or selling a single stock, a basket of stocks, or an index of stocks without actually
acquiring the underlying securities.
Synthetic equity is a well-recognized, well-developed financial
product that has business purposes unrelated to taxation in general or withholding taxes on dividends in particular. Indeed, many
of our clients manage ongoing portfolios and execute trading strategies without owning any of the underlying securities. All of their
investments are held in synthetic equity. Furthermore, we do
transactions every day with domestic U.S.-based entities. We use
synthetic equity to replicate short positions and to replicate positions in stocks that do not pay dividends. This product was not devised and is not held out by Deutsche Bank as a vehicle to avoid
dividend withholding taxes.
As my title Global Head of Synthetic Equity Finance suggests,
this New York business is a financing business. As with any bank
engaged in a financing business, we hope to profit from spreads
here the difference between our own cost of funds and that which
we charge to the client. All clients, whether they are large or small,
long or short, onshore or offshore, trading in dividend-paying securities or not, are charged a fee based on Deutsche Banks cost of
funds plus our cost of balance sheet usage, stock execution, and
any risks associated with the transaction, including the credit risk
of the counterparty.
We enter into swaps on all types of securities, including convertible bonds. Our swaps business based on U.S. stocks covers both
dividend and non-paying dividend stocks. Approximately 60 percent
of our clients have long positions with us, while the remaining 40
percent have short positions. About one-third of our clients are
based onshore, while the remainder are based offshore. Our swap
product allows clients to execute trading strategies and take positions on U.S. equities and equity markets without holding the underlying physical securities.
Clients establish synthetic versus actual equity positions for
many reasons. Synthetic equity exposure, whether long or short, is
advantageous to clients as a financing technique. Swaps provide
clients with leverage, allowing them to gain the economic benefit
of purchasing and selling securities without expending their own
capital or having to pay the full cost of trading such securities.
Clients are relieved of having to pay settlement costs and other
back-office expenses. Also, because swaps involve synthetic and not
actual trading positions, swaps shift from clients to the brokerdealers the obligation of certain market trading rules, such as locates for short sales.
Synthetic position also allow clients to protect their proprietary
trading strategies from market competitors. Because our synthetic
equity product is intended to replicate the economics of a position
in the underlying security, we make or receive payments under our
swap agreements to give our clients the financial equivalent of dividend payments. The same economics could be replicated through a
futures or option transaction. I and my colleagues across Wall
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Street always have understood that, as a matter of tax law, swap
payments are not subject to withholding tax, and the institution
that makes them is not a withholding agent. That remains my understanding.
Further, I have always understood that Deutsche Bank could not
be deemed a withholding agent unless its transactions with customers were susceptible of being recharacterized as repo transactions or stock loans.
We have taken a series of steps to eliminate any possibility that
our transactions could be recharacterized in a manner that would
violate tax laws or turn Deutsche Bank into a withholding agent.
We have done this in part by establishing policies designed to prevent clients from entering swap transactions close to a dividend
event. Thus, our policies are designed to encourage clients to hold
for a minimum of 30 and preferably 45 days.
In addition, we do not hedge our synthetic positions by both buying and selling the underlying stock with our client. We expect leverage to be a primary driver for entering into synthetic positions,
so we do not permit clients fully to collateralize their positions. We
also employ volume limits and pricing policies to ensure that our
hedging involves market activity.
We believe our policy has worked and that our synthetic equity
business is not a tax dodge. The information we have provided to
the Subcommittee demonstrates that two-thirds of all of our New
York swap clients hold their swap positions at least 60 days before
dividend record dates, and two-thirds of them hold their positions
at least 60 days after dividend record dates. Typically, our clients
unwind their swap positions not because dividends have just been
paid, but because their trading strategy dictates a change in investment position. Further, we successfully market our synthetic equity
product to customers who want short positions and to customers
who want to enter into swaps on non-dividend-paying stocks.
The entirety of the business clearly supports our understanding
that our clients are entering into swaps for sound business reasons
and our transactions are entirely legal under existing law.
Thank you for your time. I will do my best to answer any questions that you may have. In the interest of time, I have left out portions of my prepared statement, including those addressed to the
business conducted by my colleagues in London and Jersey. With
your permission, I will submit those portions together with my
written remarks for the record.
Senator LEVIN. Ms. Leung, you are reading a statement. You
have asked that the parts that you did not read be submitted to
the record. We asked you to provide a copy of that written statement in advance, and you failed to do so. Why?
Ms. LEUNG. We were certainly trying to comply with everything
that you had requested and just as a matter of time, did not have
the chance to get that to you.
Senator LEVIN. You could not have gotten it to us this morning?
You could not have given it to us last night? Everyone else gave
us a copy of the written statements that they read from.
Ms. LEUNG. I am sorry we did not do that.
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Senator LEVIN. Mr. Berke, did Morgan Stanley market or engage
in swap or stock loan transactions principally for the purpose of
avoiding U.S. dividend withholding tax?
Mr. BERKE. Senator, as I said in my opening remarks, we believe
the primary purpose of clients engaging in equity swaps is to gain
exposure to the underlying equity. Choosing swaps as a means of
gaining that exposure or choosing entering into a stock loan is a
secondary decision on their part on how to potentially deal with
issues, including taxes.
Senator LEVIN. Did you ever market your swap transactions or
stock loan transactions so your client could avoid U.S. dividend
withholding taxes?
Mr. BERKE. We market the products generally and include disclosure about all the relevant aspects of it, including any tax implications or considerations that clients should have when considering
those investment opportunities.
Senator LEVIN. But did you ever market it focusing on enhancing
the dividend payout by not having to pay withholding?
Mr. BERKE. Our marketing materials include a discussion about
taxes.
Senator LEVIN. Did this discussion ever tell your recipient of
your proposals that they would enhance the dividend payout?
Mr. BERKE. Specific marketing materials may have, but generally we do include
Senator LEVIN. Take a look at Exhibit 26,1 would you?
Mr. BERKE. I am familiar with this from preparation for todays
testimony.
Senator LEVIN. All right. This says, Here are the main points
regarding total return equity swaps on Microsoft why offshore
funds are subject to withholding tax of up to 30 percent on cash
dividends from U.S. stocks. Morgan Stanley can enhance the dividend payout from 70 percent to 100 percent through a total return
equity swap. This is a great opportunity to highlight an application
that is relevant to all dividend-paying securities, not just Microsoft.
Is that a Morgan Stanley document?
Mr. BERKE. It is an internal distribution Morgan Stanley document, so it is marketing to our internal sales people and traders.
Senator LEVIN. And did those folks that were marketing this particular type of a product use this argument?
Mr. BERKE. They may very well have discussed these issues as
opposed to using this piece as a marketing piece, yes.
Senator LEVIN. But whether or not this particular piece was used
in marketing, is it fair to say that they would have used this argument, this point in marketing for Morgan Stanley?
Mr. BERKE. Yes, it is fair to say that.
Senator LEVIN. And so, therefore, is it not fair to say that Morgan Stanley, when it was offering and suggesting total return equity swaps to potential customers, used as an argument that Morgan Stanley can enhance the dividend payout from 70 percent to
100 percent through a total return equity swap?
1 See
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Mr. BERKE. It is certainly the case in respect to the Microsoft
dividend, yes.
Senator LEVIN. Well, doesnt it say here not just Microsoft?
Mr. BERKE. Yes, it does.
Senator LEVIN. Mr. DeRosa, did Lehman Brothers market or engage in swap or stock loan transactions with the presentation of
the argument that your customer could avoid U.S. dividend withholding tax?
Mr. DEROSA. Similar to Mr. Berkes answer
Senator LEVIN. Give me your answer, if you would.
Mr. DEROSA. Fine. We included among the benefits from entering into equity swaps the tax features.
Senator LEVIN. The tax features being?
Mr. DEROSA. Meaning the reduction of taxes payable.
Senator LEVIN. OK. Now, if you will look at Exhibit 22? 1 This
is a letter from you to Maverick Capital. Do you see on page 2 it
says, We have a variety of solutions using swap and securities
lending vehicles for achieving yield enhancement?
Mr. DEROSA. I see that.
Senator LEVIN. Was that not clearly marketing to Maverick a vehicle for increasing dividend yield, enhancing a dividend yield? Is
that not clearly what you were marketing there?
Mr. DEROSA. Among the other items listed in this letter, yes,
that was featured.
Senator LEVIN. And where are those other items?
Mr. DEROSA. In just looking down the list of starting at the first
page, it goes through several different aspects of synthetic financing, I believe.
Senator LEVIN. Were any of those applying to your swap product
or your securities lending product?
Mr. DEROSA. I have not seen this document before this morning,
so I am just skimming it now. But I presume it is with respect to
all of the products that we offer.
Senator LEVIN. Well, why dont you read it now and tell me
whether any of those items on page 1 refer to your swap and securities lending vehicle and whether you say anything about your
swaps and security lending vehicle except that it will achieve yield
enhancement. And then you propose that Maverick provide Lehman Brothers with an interest list on a weekly basis for possible
enhancement trades. If that is not marketing a vehicle to increase
your dividend yield, I do not know what is.
Mr. DEROSA. Again, just looking at it for the first time, at the
bottom of the first page it is discussing our prime-plus product;
prime-plus provides U.S.-based hedge fund risk-based margin lending.
Senator LEVIN. Right.
Mr. DEROSA. With all the benefits of traditional prime brokerage,
including insurance wrapper.
Senator LEVIN. Is that your swap lending to achieve yield enhancement?
Mr. DEROSA. I am not sure exactly which product that is. I
apologize. But, again, what I am suggesting is that the letter deals
1 See
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with other aspects that are advantageous to the client in addition
to the dividend enhancement.
Senator LEVIN. Well, you are selling a lot of things in this letter.
You are promoting a lot of things. One of the things you are promoting is a swap and security lending vehicle for achieving yield
enhancement. Are you promoting it for anything else other than
achieving yield enhancement? Just take a look at the paragraph.
It says Dividend Enhancement Solutions. We have a variety of solutions using swap and securities lending vehicles for achieving
yield enhancement. Do you list anything else there that you are
using swap and securities lending vehicles other than for that?
Mr. DEROSA. That paragraph does not. It references the dividend
enhancement feature associated with swaps and security lending
transactions.
Senator LEVIN. All right. Ms. Leung, did Deutsche Bank engage
in swap or stock loans transactions for the principal purpose of
avoiding U.S. dividend withholding tax?
Ms. LEUNG. We did not.
Senator LEVIN. All right. Now, take a look at Exhibit 31.1 On Exhibit 31, where it says, We are in the process of determining
hedge fund demand for All In enhancement to clients for our proprietary trades, does that relate to dividend enhancement?
Ms. LEUNG. This would relate to dividend enhancement. However, I will note that we did not actually, to the best of my knowledge, engage in any activity that came off of this memo.
Senator LEVIN. So you determined there was no demand?
Ms. LEUNG. We determined that this was not something that we
wanted to market to our clients and actually discouraged any marketing documents with regards to the Microsoft dividend.
Senator LEVIN. Did you hear Mr. Wolf on the prior panel testify
that Deutsche Bank marketed dividend enhancement swaps to
them? Did you hear him say that?
Ms. LEUNG. Yes, I did hear that.
Senator LEVIN. He was under oath.
Ms. LEUNG. Yes.
Senator LEVIN. You are under oath.
Ms. LEUNG. I understand.
Senator LEVIN. Do you disagree with him?
Ms. LEUNG. We market swaps to clients for a variety of reasons
Senator LEVIN. No. I am saying for dividend enhancement.
Ms. LEUNG. Dividend
Senator LEVIN. That is what he testified to. Did you market dividend enhancement swaps to them?
Ms. LEUNG. Sure, well, to
Senator LEVIN. Pardon? The answer is sure, or your answer
is
Ms. LEUNG. No. To address both of your questions separately,
first regarding this document, this is regarding Microsoft, and in
the case of Microsoft, we did not market the Microsoft transaction.
In fact, under our New York swaps desk, we did a total of 500,000
shares worth of swaps during the time of Microsoft, which is a very
1 See
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de minimis amount in the context of our business, as well as had
trading parameters around making sure that there was investment
intent with those trades.
With regards to selling our product and Mr. Wolfs comments before, our swaps are marketed for a variety of reasons, for
counterparties who want long exposure and who want short exposure, for those who have onshore and offshore entities, and a variety of reasons including and most primarily leverage, as well as
protecting clients market strategies and global market access.
Senator LEVIN. Now, did Deutsche Bank market dividend enhancement swaps
Ms. LEUNG. We marketed
Senator LEVIN [continuing]. Forall those other purposes you
just listed. But did you ever market swaps for dividend enhancement?
Ms. LEUNG. We did market swaps with dividend enhancement as
part of one of the many other factors for doing swaps.
Senator LEVIN. Did you ever market swaps primarily for dividend enhancement?
Ms. LEUNG. No, we did not.
Senator LEVIN. And so when Mr. Wolf said that Deutsche Bank
marketed dividend enhancement swaps to them, you are saying
that that was never the primary purpose that you marketed them
for?
Ms. LEUNG. To the best of my knowledge, yes.
Senator LEVIN. Would you have knowledge if you had done that,
if your firm had done that, if the bank had done that? Would you
be aware of it if Deutsche Bank did that?
Ms. LEUNG. Yes, I would be, and to the best of my knowledge,
we market swaps for many reasons, and
Senator LEVIN. But never primarily for dividend enhancement. Is
that what you are telling us, under oath, that your bank never
marketed swaps primarily for dividend enhancement. Is that what
your testimony is?
Ms. LEUNG. We do not market swaps primarily for dividend enhancement.
Senator LEVIN. And never have?
Ms. LEUNG. I cant speak to the lifetime of my firm.
Senator LEVIN. While you were there?
Ms. LEUNG. While I was there, correct.
Senator LEVIN. You never did that?
Ms. LEUNG. We did notwe did not market swaps primarily for
dividend enhancement.
Senator LEVIN. OK, good. And how long have you been there?
Ms. LEUNG. Since 2002.
Mr. DeRosa, could you take a look at Exhibit 19? 1
[Pause.]
Senator LEVIN. Are you familiar with this document?
Mr. DEROSA. Yes, I am.
Senator LEVIN. OK. Now, this is an internal review document, as
I understand it, a briefing paper that was devoted to dividend en1 See
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hancement and what the exposure would be of that enhancement.
Is that fair?
Mr. DEROSA. That is fair.
Senator LEVIN. And it lists Lehman Brothers yield enhancement
product and has a chart estimating the amount of dividends affected by each product, the amount of withholding tax risk that
the company thinks it might face if the IRS rules against these
products. It even has a description and diagram of a stock loan
transaction used for yield enhancement.
Now, is it fair to say that the reason that Lehman Brothers prepared this document is in order to market yield enhancement products and to look at what the potential risks would be of that use
in that market? Is that correct?
Mr. DEROSA. No. This document did not have to do with marketing. This, as you indicated initially, was an internally prepared
document, shared internally, designed to assess the different potential risks on the transactions.
Senator LEVIN. Of engaging in those transactions?
Mr. DEROSA. Correct.
Senator LEVIN. OK. So you were looking in some detail at the exposure to you of these transactions. Is that correct?
Mr. DEROSA. The person who prepared this document, who was
not familiar in detail with all these businesses, waswith all these
products, rather, was trying to craft a high-level assessment.
Senator LEVIN. Do you know who prepared this document?
Mr. DEROSA. Yes.
Senator LEVIN. Who was that?
Mr. DEROSA. Ian Maynard.
Senator LEVIN. OK. Why would you do this kind of an analysis
if you were not marketing these products?
Mr. DEROSA. What I think he was trying to give information on
was around Lehman Brothers risk profile. Maybe I am missing
your use of the word marketing, but
Senator LEVIN. You were engaged in these products, you were involved in these products.
Senator LEVIN. And your involvement was in products which enhanced the yield of dividends. Is that correct?
Senator LEVIN. Through the use of swaps.
Mr. DEROSA. And stock loans?
Senator LEVIN. And loans.
Senator LEVIN. And so this was looking at what the risks were
of doing that?
Senator LEVIN. But you were doing that despite these risks?
Mr. DEROSA. The risk was created due to the vacuum in which
we were operating as far as guidance is concerned, so at Lehman
Brothers, we measure the risk across all of our transactions, and
these are no exception. So what this document was appreciative of
is the fact that the IRS had indicated that they might have a concern with the characterization of these transactions, and, therefore,
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what we were trying to do here was to create an indication of what
the total maximum possible could be, much like
Senator LEVIN. What was that total maximum possible?
Mr. DEROSA. I am not sure what the total maximum was because this document is fundamentally incorrect in assessing the
risk. What I can tell you is that the examination in which we are
involved by the IRS has generated a much smaller number.
Senator LEVIN. What is that number?
Mr. DEROSA. Roughly ten and a half million across the 200405
period.
Senator LEVIN. What period?
Mr. DEROSA. For 2004 and 2005.
Senator LEVIN. And before that?
Mr. DEROSA. We did not measure that pursuant to the IRS
exam. The audit is restricted to those 2 years.
Senator LEVIN. And did you do any subsequent to that?
Mr. DEROSA. Subsequent to 2005, we have not taken the detailed
review, but we have done a fair amount of work around 2006 and
2007, and transactions that remotely, I think, replicate the transaction as described in the Subcommittee report probably generate
several hundred thousand dollars of dividends.
Senator LEVIN. OK. Take a look, if you would, Mr. DeRosa, at
Exhibit No. 12.1 This is an email from Mr. Demonte to Elizabeth
Black. They are both Lehman Brothers employees, as we understand it. And here is what it says, that the spread sheet contains
long positions for Highbridge which we currently buy into a swap
to enhance their yield for dividends. Is that accurate?
Mr. DEROSA. That is what it says.
Senator LEVIN. Are you familiar with this?
Mr. DEROSA. I have seen this document in my preparation.
Senator LEVIN. All right. So this spread sheet, then, looks at
Highbridge stocks which Lehman Brothers currently buys into a
swap to enhance their yield for dividends. That is the stated purpose. Is that correct? There is no other purpose stated for that
swap except to enhance their yield for dividends. Is that correct?
Mr. DEROSA. There is no other purpose stated in this email. That
is correct.
Senator LEVIN. And do you have any other document which
shows there was any other purpose for that particular swap?
Mr. DEROSA. I do not.
Senator LEVIN. OK. Could you take a look, if you would, Mr.
DeRosa, down at the page number at the bottom 33324.
Mr. DEROSA. Which tab?
Senator LEVIN. This is Exhibit 18.2 Now, if you take a look at
this exhibit, in the second paragraphdo you have it in front of
you now?
Mr. DEROSA. I do.
Senator LEVIN. It says that the CFDand that is a swap productis usually used for yield enhancement purposes. And that is
a Lehman Brothers swap product, right?
Mr. DEROSA. CFD, yes.
1 See
2 See
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Senator LEVIN. Is that Lehman Brothers?
Mr. DEROSA. CFD is a general term, not specifically Lehman
Brothers. But, yes, it is a Lehman Brothers product.
Senator LEVIN. But you are referring here to the Lehman Brothers CFD, right?
Mr. DEROSA. I believe that is what he was referring to.
Senator LEVIN. Well, take a look at the previous paragraph. It
says the Lehman Brothers CFD, right?
Senator LEVIN. OK. So we are talking about a Lehman Brothers
CFD and it is usually used for yield enhancement purposes. Is that
an accurate reading of your document?
Mr. DEROSA. That is an accurate reading.
Senator LEVIN. So you have this product, which is usually used
for yield enhancement. None of those other reasons are specified.
Is that correct?
Mr. DEROSA. You have got a salesperson drafting a document
here to one of his clients, and that is the purpose that he is indicating in this document.
Senator LEVIN. Is he using any other purpose beside yield enhancement in this document?
Mr. DEROSA. No, not in this document.
Senator LEVIN. So is that anything other than marketing this
particular product for yield enhancement purposes? What is this
other than marketing for yield enhancement purposes in this situation?
Mr. DEROSA. I am not trying to debate the
Senator LEVIN. Well, I am not trying to debate. I am trying to
get a straight answer from you. What other reason is given in this
document, and is this not a marketing document?
Mr. DEROSA. He gives no other reason in this document to the
person with whom he is communicating for doing the transaction
other than yield enhancement.
Senator LEVIN. And is it a marketing document, would you not
say?
Mr. DEROSA. I wouldnt necessarily call it a marketing document,
but that is fine. I dont object to that.
Senator LEVIN. Mr. Berke, take a look at Exhibit 27,1 if you
would.
This is an August 9, 2004, email from Daniel Brennan to Alan
Thomas, both Morgan Stanley employees. It says, Spoke again
are you with me.
Mr. BERKE. Yes.
Senator LEVIN. Do you see where I am reading from?
Mr. BERKE. Yes.
Senator LEVIN. Spoke again with Bill Scazzero who works on
Moores, which is a hedge fund, trading desk, to ascertain usefulness of the Microsoft total equity swap for Moore Capital. Bill informed me that Morgan Stanley and Moore Capital frequently
transact such swaps to maximize returns given offshore status and
dividend withholding issues.
Now, that is a Morgan Stanley document, right?
1 See
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Mr. BERKE. Yes.
Senator LEVIN. It is a contemporaneous document. Do you have
any reason to say that it is inaccurate, that there were not frequent transactions using such swaps to maximize returns given offshore status and dividend withholding issues? Do you have any
reason to say that is an inaccurate statement in August 2004?
Mr. BERKE. No.
Senator LEVIN. These are Morgan Stanley employees emailing
each other. Is that accurate? Daniel Brennan to Alan Thomas.
Mr. BERKE. Yes, these are Morgan Stanley employees.
Senator LEVIN. All right. Mr. Berke, let me ask you about your
Cayman Islands operation. Do you employ folks in the Caymans?
Mr. BERKE. Not to my knowledge, no.
Senator LEVIN. If you will take a look at Exhibit 29.1
Mr. BERKE. Yes, Senator.
Senator LEVIN. All right. Before I ask you specifically about that
document, in your opening statement, Mr. Berke, you testified that
between 2000 and 2007, Morgan Stanley Cayman and Morgan
Stanley International U.K. paid about $2.4 billion in substitute
dividends as a result of stock loans involving U.S. dividend-paying
securities. The Subcommittee understands that about 49 percent,
or $1.6 billion of that, was from your Cayman Islands entity.
If U.S. withholding taxes on those dividends had been collected
at the 30-percent rate, the amount would total approximately $300
million. However, no withholdings were collected because Morgan
Stanley took advantage of an IRS notice and inserted a Cayman Islands shell company into this transaction, and as a result, Morgan
Stanley did not withhold any of the dividend payments.
So far am I accurate?
Mr. BERKE. Yes, by complying with IRS Notice 9766
Senator LEVIN. No, but is my statement, what I just read, totally
accurate in its total? Do you have any disagreement with what I
just read to you about your opening statement?
Mr. BERKE. No.
Senator LEVIN. OK. Now, you said that you have no folks in the
Caymans, and now you are looking at Exhibit 29, which says that
Caycoand Cayco is your company in the Caymans. Is that correct?
Mr. BERKE. Yes. It has a longer name, but we refer to it as
Cayco.
Senator LEVIN. OK. It is a thinly capitalized company, cannot absorb losses, and it should never hold long stock positions. Is that
correct?
Mr. BERKE. Yes, it is.
Senator LEVIN. It also says that it must not enter into stock lending arrangements directly with MSIL. Who is that?
Mr. BERKE. That is the former name of our U.K.-registered
broker-dealer.
Senator LEVIN. OK. Surplus cash in Cayco must not be lent to
any affiliate or entity in the United States without the approval of
the tax department. If it enters into derivative transactions, dispensation should always be obtained from the law and compliance
1 See
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department. It may not sell stock positions to U.S. institutional investors. It may not enter into stock lending transactions with any
U.S. counterparties. It may not purchase securities from any person in the United States. It may not enter into derivative transactions with any U.S. person. It may not carry out repo transactions with any U.S. person. It may not source collateral from MS
& Company. It may not lend U.S. equities against cash collateral
unless the cash is equal to 200 percent. It may not carry out advisory business. It may not invest in futures.
What can it do?
Mr. BERKE. With respect to the United States, it primarily engages in stock lending activity of U.S. stocks.
Senator LEVIN. All right. That was its purpose?
Mr. BERKE. That is the primary purpose that I am aware of that
the vehicle is used for.
Senator LEVIN. Now, is it fair to say that is a shell corporation,
in common parlance?
Mr. BERKE. That is a fair estimate, yes.
Senator LEVIN. Mr. DeRosa, Lehman Brothers has a Cayman facility that it has used to run two stock loan transactions. Does Lehman Brothers have people working in the Cayman Islands?
Mr. DEROSA. No, we do not. Just to clarify, the Cayman Islands
operation is a branch of our Hong Kong entity.
Senator LEVIN. That is Lehman Brothers Hong Kong entity?
Senator LEVIN. Can I call it Lehman Brothers without any misunderstanding?
Mr. DEROSA. Sure.
Senator LEVIN. OK. Is that location in the Caymans still used to
transact stock loans involving U.S. dividend-paying securities?
Mr. DEROSA. I believe it is.
Senator LEVIN. Ms. Leung, in 2004, Deutsche Bank Limited
began to use a facility in the Isle of Jersey to transact stock loans
using U.S. securities. According to an internal Deutsche Bank application seeking approval for those transactions, the reason for the
proposed transaction and its location was so Deutsche Bank could
insert a non-U.S. treaty entity in its stock loan transactions to
avoid dividend withholding and lower its stock loan pricing to
match its competitors.
Is that the case, that Deutsche Bank set up this program in the
offshore jurisdiction of Jersey to exploit the IRS rule on substitute
payments and avoid the withholding tax on dividends, thereby generating a bigger return on the transactions?
Ms. LEUNG. It is true that we started trading through our Jersey
entity. We did not feel that it was to exploit, but we felt it was
legal, perfectly legal under Notice 9766.
Senator LEVIN. All right. To utilize that rule.
Ms. LEUNG. Yes.
Senator LEVIN. Except for that wordand I will say utilize instead of exploitwas what I read to you accurate?
Ms. LEUNG. Yes, it is accurate.
Senator LEVIN. Part of the desire to be more competitive, to
match its competitors, as I said, in order to match the substitute
dividend payments for stock loans and avoiding the withholding
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tax on those substitute dividends to the extent that your competitors were doing it. Is that correct? You wanted to be competitive
with your competitors in that area.
Ms. LEUNG. What we were trying to be competitive with was on
the ability to bid on pools of stocks available for lending. We did
not enter into any of these transactions with hedge funds. The primary purpose of this in order to be competitive with pricing was
to tap into the pools of stock loan available through institutions
where, when bidding on those securities and paying a fee to those
institutions, a portion of those securities would be U.S. securities.
And under Notice 9766, we felt we could be more competitive in
our pricing in order to win those pools of securities.
Senator LEVIN. In order to be more competitive on your pricing,
you would, like your competitors, need to avoid the withholding on
those dividends. Is that correct?
Ms. LEUNG. We would need to not be subject to the 15-percent
withholding that we would have been subject to.
Senator LEVIN. And you used Notice 9766 to avoid the taxes. Is
that correct?
Ms. LEUNG. We used Notice 9766 because we felt that was within the letter of the law.
Senator LEVIN. Right, and that would help you avoid those
taxes?
Ms. LEUNG. Notice 9766 would keep us from being withheld on
those dividends.
Senator LEVIN. Ms. Leung, Deutsche Bank told the Subcommittee staff that approximately 98 percent of the loans transacted through the Deutsche Bank Jersey entity involve U.S. dividend-paying securities. Are you aware of that?
Ms. LEUNG. I am not intimately familiar with it, but, please, I
will try to answer your question.
Senator LEVIN. Do you disagree with that?
Ms. LEUNG. No, I dont disagree.
Senator LEVIN. It also reported that in 2007 alone, DBIL engaged in stock lending transactions involving U.S. dividend-paying
securities with a notional value of over $30 billion. We have asked
Deutsche Bank to supply us the amount of dividends paid as a result of those $30 billion worth of loans, and when are we going to
get this information from you?
Ms. LEUNG. I have that information for you now. Again, if these
transactions were subject to withholding from the periods 2004 to
2007, that amount would be $27 million.
Senator LEVIN. OK. Would you submit to the Subcommittee the
way in which you reached that result? Not now, but would you for
the record submit to us your computations which led you to the $27
million figure?1
1 Counsel to Deutsche Bank provided the Subcommittee with a letter dated September 29,
2008, explaining that the $27 million figure was derived from an analysis of data reflecting
stock lending transactions and forward contract transactions involving the DBIL entity . . . in
which securities were held for 21 days or less, where such a time period covered a dividend
record date of the securities[.]
The Subcommittee advised Deutsche Bank that the request for the approximate amount of
total withholding taxes avoided through dividend enhancement, yield enhancement, or other
transactions that had the reduction of withholding tax as a primary purpose was not limited
to transactions with a duration of 21 days or less. The Subcommittee asked Deutsche Bank to
Continued
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Ms. LEUNG. Yes, we can do that.
Senator LEVIN. Ms. Leung, why did Deutsche Bank conduct its
stock loan business on U.S. securities with entities in 15-percent
tax jurisdictions from the Isle of Jersey?
Ms. LEUNG. I am not intimately familiar with that business, but
for these pools offor these securities lending pools, these were
bids for international securities, and that was run out of our London office.
Senator LEVIN. Was that to take advantage of Notice 9766?
Ms. LEUNG. I do not believe
Senator LEVIN. Was that utilizing that regulation?
Ms. LEUNG. It utilized the regulation, yes.
Senator LEVIN. All right. Let me ask you, Mr. DeRosa. Lehman
Brothers established tax risk limits for all of the swap and stock
loan transactions that you used for dividend enhancement purposes, the Cayman stock loan transactions had a $25 million annual limit, which was later raised to $50 million. Why did you set
a tax risk limit?
Mr. DEROSA. It goes back to not having clear guidance around
the products.
Senator LEVIN. All right. Was that tax guidance from the IRS,
you mean?
Mr. DEROSA. Yes.
Senator LEVIN. And, Mr. Berke, did Morgan Stanley set any tax
risk limits on any dividend enhancement transactions involving
U.S. dividend-paying securities?
Mr. BERKE. Yes, there is a risk limit on a type of equity swap
done out of London.
Senator LEVIN. That is it?
Mr. BERKE. That is the only tax limit that I am aware of.
Senator LEVIN. And did Deutsche Bank have any tax risk limits,
Ms. Leung?
Ms. LEUNG. We did not have any risk limits.
Senator LEVIN. All right. And what about indemnity agreements?
First of all, Lehman Brothers, Mr. DeRosa, did you have indemnity
agreements?
Mr. DEROSA. My understanding is that there are standard indemnity agreements found both in the ISDA contract governing
swaps and the OSLA contract governing securities lending. In addition to that, when specifically asked by several clients with respect
to our stock lending activities, we did provide further documentation, which basically provided more specificity around the indemnification that is found in the OSLA.
provide the total amount of withholding taxes avoided through transactions conducted through
DBIL.
On October 30, 2008, counsel for Deutsche Bank responded with the following information
encompassing transactions from October 2004, when DBIL commenced operations, through the
end of 2007:
[T]he total hypothetical estimated withholding figure for all DBIL transactions of any
tenor [is] $97,349,757.24. . . . $27,819,148.73 of this total is due to transaction where a position was held for 21 days or less. Another $8,479,821.51 is from transactions of more than
21 days and fewer than 30 days. And the bulk of this total, $61,050,787, is due to transactions where a position was held for 30 days or more. Deutsche Bank does not believe that
a transaction where a counterparty holds a position for a month or longer over a dividend
record date is one that necessarily has as a primary purpose the reduction, minimization,
or elimination of withholding tax liability.
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Senator LEVIN. Further documentation that had greater specificity. Would that say that the customer wanted to be clearer in
terms of indemnity?
Mr. DEROSA. I think it does mean that the client wants more
guidance than the standard language that is found in the OSLA.
That is relatively broad. I think the wording is all encompassing,
but I think in certain instances clients would like a more granular
documentation.
Senator LEVIN. And would that granularity, speaking with greater clarity, mean specific indemnity for substitute payments?
Mr. DEROSA. The indemnity provides that the counterparty
would be not held liable if there were a withholding tax imposed
at a later date.
Senator LEVIN. On those substitute dividends?
Senator LEVIN. Lets see. Did I ask you, Mr. Berke about the indemnity?
Mr. BERKE. Not yet. [Laughter.]
Senator LEVIN. I would not want to leave you out. Did you issue
indemnity agreements?
Mr. BERKE. In connection with our Notice 9766 business, we
have issued a handful of indemnities to order placers acting in a
fiduciary capacity on behalf of investment clients.
Senator LEVIN. Ms. Leung, did your bank issue indemnity agreements?
Ms. LEUNG. We did not.
Senator LEVIN. OK. Finally, let me ask the three of you: UBS has
halted and Merrill Lynch has suspended stock loan programs that
use entities in offshore tax havens for the purpose of utilizing that
IRS notice. Do any of your companies plan to take any similar type
of action? Mr. DeRosa, do you know of any plans by your company?
Mr. DEROSA. Not to the best of my knowledge.
Senator LEVIN. Mr. Berke.
Mr. BERKE. Not to the best of my knowledge.
Senator LEVIN. Ms. Leung.
Ms. LEUNG. Not to the best of my knowledge.
Senator LEVIN. OK. Thank you for your appearance here today,
and I appreciate your testimony.
We are going to take a 5-minute break.
[Recess.]
Senator LEVIN. We will come back to order.
Let me welcome our final witness, Hon. Doug Shulman, Commissioner of the IRS.
Commissioner Shulman, I want to thank you for being here. I
want to welcome you back to the Subcommittee. You have testified
before this Subcommittee before on tax haven banks and U.S. tax
compliance, and we very much appreciate your being with us today.
I know you are familiar with our rule that we have to swear in all
of our witnesses, and so I would ask you to stand and please take
the following oath: Do you solemnly swear that all the testimony
you will give before this Subcommittee will be the truth, the whole
truth, and nothing but the truth, so help you, God?
Mr. SHULMAN. Yes.
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Senator LEVIN. Thank you so much, and I think you know our
rule in terms of timing, and so we will just turn it right over to
you directly for your testimony.
TESTIMONY OF HON. DOUGLAS SHULMAN,1 COMMISSIONER,
INTERNAL REVENUE SERVICE, WASHINGTON, DC
Mr. SHULMAN. Thank you, Chairman Levin, and good morning.

I want to thank you for the opportunity to appear before you today
to discuss an issue of great interest both to the Internal Revenue
Service and this Subcommittee: The practice of using certain financial instruments to reduce or eliminate the U.S. withholding tax
that applies to payments of dividends on U.S. stocks to foreign persons.
Let me reiterate what I told you previously: That I have made
international issues a top priority for the IRS during my 5-year
term as Commissioner. I am only 5 months into that term, but I
am committed to aggressively pursue enforcement actions where
taxpayers use the complexities of international commerce to circumvent their duties under the law.
I also want to tell you that I am personally focused on these
issues and am in the process of shifting more resources to the financial markets in international arenas.
Let me also just reiterate the appreciation that I and everyone
at the IRS have for the support of the Members of this Subcommittee and, commend you and your staff for your excellent
work. You really do great work, and it helps us out quite a bit in
doing our job.
In my limited time this morning, I would like to make a few
points about securities lending and equity swaps, and the extent to
which such transactions are being used as a means of avoiding the
withholding tax on dividends paid to foreign persons.
Before going into my testimony, I must start by saying that, as
you know, taxpayer confidentiality laws preclude me from disclosing information relating to specific taxpayers or specific audits.
Accordingly, I will not be able to comment or respond to questions
on any specific facts that have been reported by the Subcommittee
or other witnesses.
Our statutory and regulatory framework in this area, which includes both legislation and administrative guidance, would objectively be called a patchwork. Dividends in the cash market are
taxed at 30 percent, with a 30-percent withholding tax. By contrast, capital gains earned by foreign persons on these same stocks
are generally exempt from U.S. tax by statute. In addition, most
forms of interest paid to foreign persons are not subject to U.S. tax.
And at the same time, income earned by foreign residents with respect to total return swaps are generally considered to be exempt
from U.S. tax. With that as a background and recognizing this
patchwork, let me connect the dots for the Subcommittee on the
IRSs approach and strategy in this area.
First, the IRS has numerous active investigations of the types of
transactions that we are discussing today. In these types of large
complex audits, our investigations lag behind the tax years. For in1 The
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stance, the current examinations that we have open generally focus
on years 2004 to 2006, but we also have investigations open in
years before that. As you know, we do not receive 2007 corporate
tax returns until later this month. However, if some of the type of
information in your report plays out as we look at current or later
years, we would have serious concerns and investigate the issues
thoroughly.
Examinations in this area are extremely complex, often involving
multiple taxpayers, some of whom are foreign citizens located outside the United States. As we discussed when I was here before,
when we have foreign citizens and entities outside the United
States, it can be harder for us to get there on our investigative resources, and we talked about some potential solutions like extending the statute of limitations.
In the course of our examinations, we have issued numerous information document requests, requesting information related to
suspicious transactions. Depending on the nature of the request,
we look for emails, other documentation, and we also take testimony. As I noted before, these are extremely complex investigations, and they are still ongoing.
And while we are seeing some financial institutions whose swaps
and securities lending business is structured for bona fide business
purposes, we are also seeing some fact patterns that are troubling.
I cannot comment on the specifics of the ongoing investigations, but
I can tell you that where we see transactions that we believe are
abusive, under my tenure at the IRS we will challenge them.
As I said before, the Subcommittee staff has done excellent work
in producing this report. There is one aspect of the report, however,
that is troubling to me. The report may leave the reader with the
impression that the IRS is reluctant to challenge financial institutions on tax matters. The report references the so-called Wall
Street rule.
Let me state very plainly and unequivocally that where the facts
are favorable for the government, we will challenge sham transactions that have no economic purpose other than tax avoidance.
On the policy front, we are aware that some companies believe
there is a loophole in Notice 9766 which allows them to structure
securities lending deals that avoid all withholding on the payment
of dividends. As you know, Notice 9766 is 10 years old. I agree
that Notice 9766 should be reviewed to determine if it can be
modified in such a way as to retain the original intent. I have
asked the IRS staff to work with the Treasury Department on this
analysis.
As the Nations tax administrator, I always welcome dialogue on
better ways to run our system of taxation. As we look at this notice, however, we also have to recognize that it opens broader economic policy issues, and we will need to consider how it fits into
our patchwork of taxation for the capital markets.
Regardless, you should rest assured, Mr. Chairman, that on my
watch, the IRS will aggressively pursue financial institutions who
are using the complexity of the global capital markets to avoid paying the taxes that they owe.
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Thank you for the opportunity to appear today. I appreciate the
support that your Subcommittee has given the IRS over the years,
and I am happy to respond to questions.
Senator LEVIN. Thank you very much, Commissioner.
This has been going on for 10 years. You have only been there,
I guess, half a yearhow many months have you been there?
Mr. SHULMAN. Five months.
Senator LEVIN. Five months. We basically have heard for 10
years, not from you but from other folks at the IRS, that this is
troubling; they are reviewing particularly Notice 9766.
Now, if you are sitting out there and you are a taxpayer in this
country and you are paying your taxes, including taxes on dividends that you are receiving from companies, and then folks overseas who are receiving dividends who are supposed to be paying
taxes on those dividends are using these gimmicks to avoid paying
taxes, and it was clearly not intended that they be able to avoid
paying taxes on dividends because we have a withholding requirementwhich has got teeth in it, but they have avoided it through
these gimmicks which you know about and have heard about again
this morning, why not just end it? I know the policy arguments.
Those policy arguments will rage until someone resolves those policy arguments. And I take it you have participated in policy discussions about this issue. Is that a fair statement?
Mr. SHULMAN. Only very recently.
Senator LEVIN. Only very recently.
Mr. SHULMAN. Yes.
Senator LEVIN. But there are policy discussions which are raging
around this issue, I assume, within the IRS and in the Treasury.
Is that a fair statement?
Mr. SHULMAN. I think everyone is aware there are policy issues.
Senator LEVIN. This hearing is not into the policy issues. We will
let the Finance Committee and others have that debate. This is a
question of enforcing our tax laws. They are not being enforced. It
is very simple. It is very clear. They are not being enforced. We
heard it here very clearly this morning. They are clearly not being
enforced on the stock loans, where everyone acknowledges that
that regulation was not intended to allow for the avoidance of taxes
when it comes to the stock loans which we heard described. But
then you have got these phony stock sales that then are used as
part of a swap transaction to avoid the tax on dividends where
swaps are used.
Now, why cant we just simply modify Notice 9766? You have
acknowledged this morning its purpose is being obviated. I know
there are policy issues involved, but why not change the regulation? It is acknowledged that its purpose is being circumvented, so
why not change it?
Mr. SHULMAN. You brought up a few things there. Let me first
say, if I were a financial institution testifying before you, I would
sit up here and be assertive and claim my view of the tax law. I
think the IRS may have a view that is different from some of the
things you have heard.
Senator LEVIN. Not on Notice 9766.
Mr. SHULMAN. Well, second is we have a number of ongoing investigations. On the spectrum of rules that are easy to enforce or
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not, I would say Notice 9766 happens to be one of the more difficult ones, and that is why I acknowledge and agree with you, and
have asked the staff to start looking to see if there is a way to modify it with the current Treasury. And clearly, we are also going to
have to have this discussion with the next Administration.
But I do not think companies should take comfort, and I do take
issue with the notion that we are not being aggressive and actively
looking at these situations. As I said, we have open investigations,
some of which are in the years you have looked at. All the things
in this report are not things that are going to go unnoticed. We are
going to push on this very hard.
As you noted, I am 5 months into my term, and I think our staff
clearly understands that I think we should be aggressive about this
and make sure people are not circumventing the law.
Senator LEVIN. Well, you heard Professor Avi-Yonah say that he
heard a tax professional call these dividend enhancement transactions an approved loophole. What is your reaction to that?
Mr. SHULMAN. My reaction is for the current transactions that
are under investigation in the future, which are the ones that I can
influence on my watch. If I were a taxpayer, I certainly would not
take comfort that the IRS is not going to challenge them.
Senator LEVIN. And you say that the so-called Wall Street Rule
that says if financial firms do certain transactions for years, claim
they are tax free, and the IRS does not object, that the IRS loses
the authority to challenge that transaction. You challenge that
rule?
Mr. SHULMAN. I do challenge that rule. I think there has been
no private letter rulings on this, which gets you a little further
down the road. Also, as we have talked about in other hearings, I
think you would agree that over the last 6 months the IRS record
of aggressively targeting international transactions, taking a hard
run at the QI program, and using our John Doe summons authority, has shown improvement. These are all things that had not
been done before, and I think the IRS is at least showing, since I
have been here, an aggressive stance. If I were a prudent taxpayer,
I would not take comfort in the notion of the Wall Street rulethat
if we have not looked at something before, we therefore think it is
not within the law, and will not look at it now or in the future.
A prudent taxpayer should not take comfort with that.
Senator LEVIN. Here is the testimony of Mr. DeRosa, which I
think you heard this morning: Most, if not all, of the major Wall
Street investment banks and commercial banks engage in equity
swap and stock loan transactions referencing U.S. underlying equities with non-U.S. counterparties. Over the last 15 years, numerous
commentators in widely respected taxation journals have addressed
the withholding tax consequences of equity swaps similar to those
offered throughout Wall Street, including articles by the current
chief of staff for the Joint Committee on Taxation and his former
law firm. In 1998, a Notice of Proposed Rulemaking was published
in the Federal Register that expressly addressed the same issue. It
said, Treasury and the IRS are aware that in order to avoid the
tax imposed on U.S. source dividends . . . some foreign investors
use notional principal contract transactions based on U.S. equities
. . . Accordingly, Treasury and the IRS are considering whether
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rules should be developed to preserve the withholding tax with respect to such transactions.
Now, according to this testimony, that is 1998so, in other
words, 10 years ago. So now the Treasury and the IRS have been
aware for 10 years because they said they were aware back in
1998.
If you are aware of something for 10 years and do nothing about
it, why would you expect any other reaction on the part of this
business other than to just pile on, keep on using it, keep on costing the Treasury and the IRS billions of dollars over these 10
years? Why would you expect any other reaction except that this
is, in the words of the tax professional, an approved loophole?
Isnt that a kind of normal reaction after 10 years?
Mr. SHULMAN. Well, I cannot speak to peoples reactions. What
I can tell you is clearly, as I said before, some of the testimony you
heard today was people justifying transactions. As you know, the
tax code is four times as long as War and Peace, and they picked
out a nice sentence to give them comfort, which might be false comfort.
We have a number of investigations underway. Some of the stock
lending under Notice 9766 presents to us real questions about the
substance of the underlying corporation. In swaps, we have investigations underway in the broadest terms on some of the kinds of
things you have looked at, crossing in, crossing out only for tax
avoidance purposes.
And so the notion that a lot of experts have opined on this in the
past, again, I would not, if I were a firm, take false comfort in that.
The IRS is looking at these issues and is going to be aggressive.
Senator LEVIN. I am not talking about the number of experts. I
am talking about the Notice of Proposed Rulemaking of the IRS.
That is your own statement. This is an expertsnot yours, the
previous IRS Commissioner. Treasury and IRS are aware that in
order to avoid the tax imposed on U.S. source dividends . . . some
foreign investors use notional principal contract transactions based
on U.S. equities . . . Treasury and the IRS are considering whether rules should be developed to preserve the withholding tax with
respect to such transactions. Are you still considering it?
Mr. SHULMAN. Well, I think this is the swap
Senator LEVIN. Yes. Are you consider it?
Mr. SHULMAN [continuing]. Issue that you are looking at?
Senator LEVIN. Right. Are you considering whether rules should
be developed to preserve the withholding tax with respect to swap
transactions that are used in the way we have defined very specifically to avoid withholding? Is that under consideration?
Mr. SHULMAN. I would tell you what you said earlier, that certainly tax policy is not solely in the purview of the IRS Commissioner. We are, however, actively investigating people who use
swaps potentially in ways that are only meant to avoid the tax law,
and do not really transfer benefits and burdens. I just would not
comment on broader swaps policy.
Senator LEVIN. And what is your policy about dividend enhancement transactions?
Mr. SHULMAN. As you would agree, we do not have broad policies. I think I, like you, find some of these marketing materials dis-
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tasteful. For us, though, as the administrator of the law, we need
to be fair and look at the rules and enforce them.
So our concern is that when we see people exploiting the tax law,
not meeting the spirit and the letter of the law, not meeting their
tax obligations, we will go after them aggressively.
Senator LEVIN. Are you able to put in writing what the IRS position is about dividend enhancement transactions? Could you issue
just a statement as to what your position is?
Mr. SHULMAN. I am not
Senator LEVIN. I think it will have a very salutary effect if you
could do that. First, on swaps, if you could do that, as to when,
from the IRSs perspective, is it appropriate that a swap be used
which involves a sale which is not a sale, which then shifts the
source. I think that it is reasonable for us to know where you stand
on that practice. And so I am going to ask whether you would provide that for the country.
Mr. SHULMAN. Yes, I am not going to agree to write a specific
policy on dividend enhancements. I think we are pretty clear that
there is a current swap rule that has been in place since 1991.
With people who try to circumvent that rule, we are going to be
aggressive. We actually have ongoing investigations that are complex and fact specific that I am not going to jeopardize by going further and changing policy or discussing that here, which is not
clearly purely under my purview. I think I owe it to the current
and future Treasury Secretary to have this discussion with them.
Senator LEVIN. I am not talking about whether the policy should
be changed. I am talking about what the current policy is.
Mr. SHULMAN. Yes, I think the current policy on swaps is
this
Senator LEVIN. Swaps when used in connection with these phony
sales in order to avoid taxes on dividends from non-Americans.
That is the issue.
Mr. SHULMAN. Oh, I think we have been pretty clear on that, and
I am happy to make sure we continue to be clear.
Senator LEVIN. If you could give us the clear statement for the
record, that would be very helpful.
Mr. SHULMAN. Here is what I am going to do. My biggest concern
is to make sure that we administer the law effectively, and so I
need to talk to the people who have ongoing investigations and
make sure anything we give you is not going to endanger the governments position in the ongoing investigation so that I can meet
my promise of being aggressive in this area to you.
Senator LEVIN. I accept that. We do not want to jeopardize an
investigation. But you said that the position of the IRS is clear on
that, and I would just like a copy of that clear statement. OK? Is
that fair enough?
Mr. SHULMAN. That is fair. I will give you as clear a statement
as I can get.1
Senator LEVIN. Good. And then, second, on the Notice 9766 regulation, since it is clear, I think everyone would agree, that the Notice 9766 regulation has been used in a way that it was not intended, can you say that? And can you be that clear?
1 See
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Mr. SHULMAN. I can tell you that certain financial institutions
have interpreted Notice 9766 to mean that they do not need to
pay dividends if they structure a transaction a certain way. I will
also tell you what I said before about the Wall Street rule, that
people should not take comfort in the notion that if we have not
challenged transactions in the past, we will never challenge them
in the future. I can also commit to you what I said before, that I,
as IRS Commissioner who does not have the sole authority to make
broad policy changes, have instructed our staff to start working
with Treasury to review this notice very closely.
Senator LEVIN. And can you state clearly what the intent was of
Notice 9766 and what the intent was not?
Mr. SHULMAN. Well, first of all, I was not there when it happened. But I will tell you what my understanding is. My understanding is that it was intended to prevent cascading of dividends,
where there was a lot of confusion in the market that multiple people were going to be paying tax on the substitute dividends payments.
There was a notion that when the lending happened, it would
stay at the bank and the bank would pay the dividend, so that a
taxpayer would pay the tax on the dividend. I think the market has
gotten much more complex and much more sophisticated in derivatives since then, and we potentially have unintended consequences.
But the original intent was to take care of the cascading problem.
Senator LEVIN. And so it was intended that taxes be paid on dividends.
Mr. SHULMAN. I cannot tell you that. What I can tell you is that
the original intentthe reason this notice was issuedwas to take
care of the cascading problem.
Senator LEVIN. To avoid multiple tax.
Mr. SHULMAN. Yes. And, again, that was 10 years ago. I am sitting here today, and you have my commitment to take a hard look
at this.
Senator LEVIN. And, finally, should we not under current law
treat dividend equivalent payments the same way we treat dividends, as Professor Avi-Yonah recommends, under current law?
Mr. SHULMAN. I think there are a whole bunch of ways to structure synthetic transactions to avoid paying dividends on economic
structures that look pretty similar to a dividend being paid. We
have talked about swaps. We have talked about securities lending.
Equity-linked notes under statute, which have nothing to do with
IRS regulation, can be structured in such a way that you can get
money for dividends and a payment for dividend and not pay the
taxes on that same economics. So what I would tell you is that this
country does not have a consistent approach to cash markets
versus derivatives markets and how to take them. That is a subject
worthy of a broader policy debate, and I think it would be relatively irresponsible of me to lay down a stake on it now, since it
involves a whole bunch of other agencies and, clearly, the Congress.
Senator LEVIN. Thank you, Commissioner. I will just conclude
with this statement, that we are dealing here with major financial
players. They presumably do not want to be on the wrong side of
the law. If the IRS tells them to stop, they would stop. So far, the
IRS will not say Stop. It wont say Go. So the financial commu-
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nity does not really know if it is on the wrong side of the law or
not. Many of them claim everyone is waiting for the IRS to make
up its mind. After 10 years of mixed signals, the IRS failure to say
where it stands, I think it makes a mockery of your mission. And
we need to have your resolution promptly. And if you cannot do it
this year, I hope you can do it by the spring of next year.
Is that a fair request?
Mr. SHULMAN. Yes.
Senator LEVIN. Thank you. We stand adjourned.
[Whereupon, at 12:23 p.m., the Subcommittee was adjourned.]
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Senate Hearing, 110TH Congress - Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends

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Senate Hearing, 110TH Congress - Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends

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DIVIDEND TAX ABUSE: HOW OFFSHORE ENTITIES

PERMANENT SUBCOMMITTEE ON INVESTIGATIONS

ONE HUNDRED TENTH CONGRESS

Available via http://www.gpoaccess.gov/congress/index.html

VerDate Aug 31 2005

08:46 Apr 10, 2009

DIVIDEND TAX ABUSE: HOW OFFSHORE ENTITIES DODGE TAXES

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DIVIDEND TAX ABUSE: HOW OFFSHORE ENTITIES

PERMANENT SUBCOMMITTEE ON INVESTIGATIONS

ONE HUNDRED TENTH CONGRESS

Available via http://www.gpoaccess.gov/congress/index.html

For sale by the Superintendent of Documents, U.S. Government Printing Office

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08:46 Apr 10, 2009

COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS

PERMANENT SUBCOMMITTEE ON INVESTIGATIONS

ELISE J. BEAN, Staff Director and Chief Counsel

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Avi-Yonah, Reuven S.:

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7679, See Hearing Exhibit No. 12 (above) ..............................

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DIVIDEND TAX ABUSE: HOW OFFSHORE

Senator LEVIN. Good morning everybody. The Subcommittee will

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Exhibit No. 1, which appears in the Appendix on page 189.

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Senator COLEMAN. Thank you, Senator Levin.

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Mr. AVI-YONAH. Thank you very much, Chairman Levin and

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prepared statement of Mr. Avi-Yonah appears in the Appendix on page 59.