by Peter Macfarlane for the Q Wealth Report

Do Panamanian banks open multi-currency accounts? The answer is yes, but only in very special circumstances. See below for an explanation.

First, however, I owe an apology to regular readers for our failure to update the blog in a long time. Frankly, things have been very hectic over the summer. What with my research into Montenegro’s new economic citizenship (second passport) program, our upcoming event in Ireland and keeping on top of numerous requests from consulting clients concerned about capital preservation and international asset protection, I simply haven’t found the time to blog. From now on, things should be a little more back to normal – as far as is possible in this financially topsy-turvy world!

Anyway, readers know we are still keen on Panama as an offshore financial centre. Panama’s Private Interest Foundations offer some of the best asset protection there is. But a recurring concern of readers is Panama’s dependence on the US dollar. Whilst in theory Panama has its own national currency, the Balboa (currency code PAB) this has not had much financial significance for years.

Panama used to mint real silver and gold balboa coins, but the Balboa has always been at parity (one to one) with the US dollar, and balboa coins today only exist in the form of small change. Up until recently, dollarization was seen as a sign of the stability of Panama. No doubt the stability and low interest rates afforded by the dollar have contributed a lot to Panama’s success in the past. Today, however, it is seen as a threat by those who are going offshore for capital preservation.

Many clients have asked me how I can recommend Panama, considering its economy is based on the dollar, that is losing its value so fast. The answer is that I recommend the country, not the currency. Panama has a productive and diversified economy, and a good legal system. Panama corporation laws have stood the test of time since the 1920s and still provide great privacy and protection today.

But what about multi currency bank accounts in Panama? Up until recently, the dollar was king on the entire American continent. Banks simply did not have much demand for accounts in other currencies. Even currency exchange businesses like casas de cambio are rather thin on the ground in Panama.

In recent years, demand for banking services in other currencies in Panama has soared. Some of the larger retail banks, particularly Multibank and HSBC, are now routinely offering accounts in major world currencies like the euro, the yen, the pound sterling and the Swiss franc.

Unfortunately, foreign currency bank accounts are still far from the standard of sophistication you might expect if you are used to banking in Europe. Each account has a separate number, and in the case of HSBC, I was shocked to learn that the accounts can’t even be linked! That is, if you have a dollar account and want to open a euro account, you have to submit a whole sheaf of paperwork again – passport copies, bank references and the lot, just as if you were a new client walking through the door for the first time. If their IT system really can’t link accounts, it sounds like a criminal money launderer’s dream to me!

But things are changing. In the past year I’ve found three Panamanian banks that will open real multi-currency bank accounts. By this, I mean one account number you can log in to via internet banking, and in which you can keep different balances in different currencies. Switching currency or adding a new one to your portfolio is a matter of a simple mouse-click or two.

All three are Panamanian subsidiaries of established European banks. They will even open accounts where the beneficial owners are US citizens – something undoubtedly of value to our American cousins who are being turned away more and more from banks around the world – always provided that a Panamanian corporation or foundation is the legal owner.

The downside is that none of these three institutions are interested in small accounts. These are not accounts you can open with a small balance ‘in case you need them.’ You’re expected to put at least six figures on deposit, possibly more. If you are looking for an offshore safe haven, however, you couldn’t do much better.

Whether you are looking for a private banking experience such as these financial institutions offer, or a more run-of-the-mill offshore bank account, remember that your Q Wealth membership (click here to see the benefits and costs of joining) comes with a copy of the Practical Offshore Banking Guide 2010. At the back of that guide you’ll discover how you can take advantage of our free personalized banking referral service.

Offshore hedge funds, mutual funds and so-called high yield investment programs could be next on the IRS hitlist. That’s the conclusion of a recent Wall Street Journal article. After the recent events with Swiss banking behemoth UBS, other large offshore banks and financial institutions are ‘low hanging fruit.’ What does this mean for you as an offshore investor? Peter Macfarlane explains below.

Alex Raskolnikov, a professor and offshore tax expert at Columbia University Law School quoted by the Journal, believes that the IRS and US Justice Department will try to identify tax evaders who invest with offshore hedge funds managed by offshore banks. This will play out as as part of the US government’s ongoing effort to have big foreign financial institutions, which are incorrectly regarded by many as the best offshore banks, to provide them with confidential information about Americans who open offshore bank accounts.

Legislation recently introduced in the US Senate by Finance Committee Chairman Max Baucus would go beyond the existing FBAR (Foreign Bank Account Reporting) requirements, which are filed by taxpayers only on annual basis. It would require U.S. financial institutions to report to the IRS transfers of money into any foreign financial account in real time. The IRS would therefore automatically receive electronic information on new offshore bank accounts as soon as they were opened. Scary stuff, for sure! But that is exactly the purpose of it.

Until recently, US tax attorneys  understood that FBAR requirements did not apply to interests in off-shore hedge funds. However in June of this year, according to the article,  an IRS official stated that the term “financial interest” would include hedge funds that “function as mutual funds.”

Ironically, anecdotal evidence suggests that the majority of investors in offshore hedge funds are in turn US tax-exempt hedge funds such as charitable organizations and pension funds. However, while hedge funds were once the domain of sophisticated investors playing with millions, there is no doubt that many are now operating more like regular mutual funds.

Of course, it is by no means clear how this information on transfers of money into foreign bank accounts would help the IRS. Millions of international transactions clear in New York every day and surely few investors seeking confidentiality offshore would directly transfer money between accounts held in their own names.

How could investors avoid popping up on the IRS radar? Simple. By transacting business in currencies other than the US dollar. This will surely be an advantage rather than an inconvenience for most American offshore investors. The major motivation for going offshore these days is not tax at all, but rather protecting the value of assets against the terminal decline of the dollar and the collapse of the US financial system.

Many of the more private European banks are now actively trying to dissuade clients from transacting business in US dollars at all, preferring that their customer data doesn’t have to be sent to New York. For example, one private banker recently told me that when a client wants to transfer dollars to another bank, they typically fix a EUR-USD rate in advance with the other bank. The transaction settles in Euros, and then is converted back to dollars on arrival in the internal books of the beneficiary/receiving bank. Importantly, my banker prefers to absorb the additional costs of the spread, rather than expose clients to dollar transaction clearance in the US.

Gold is also emerging as a settlement currency for interbank transactions in the mainstream banking system. This is a pleasing novelty that I hadn’t expected to see. Whilst regular readers know I’m a big fan of holding physical gold bullion as opposed to paper or electronic gold liabilities, such liabilities are certainly useful for short term transactions.

Raiffeisen Zentralbank Austria, which with its Eastern European and Asian clients has one of the highest volumes of US dollar clearing outside the USA, has been pioneering this. Since earlier this year they have been offering regular bank accounts denominated in gold ounces, which have prompted a number of offshore banks to offer such services to their clients, using RZB as the correspondent and clearer. A number of banks are now offering gold as a regular currency option in the currency portfolio of their multi-currency bank accounts. Yes, that means you can actually send and receive SWIFT transfers denominated in gold, provided both the sending and receiving banks have appropriate correspondent accounts.

Of course, for many Americans – those most affected by this clampdown – opening bank accounts denominated in other major world currencies appears to be  just a pipe dream. Very few American banks even offer Euro accounts. That’s a far cry from some of the banks we routinely refer clients to, which allow you to hold balances in more than thirty currencies conveniently managed under one account number. And then, there is the problem that many foreign banks simply refuse to work with US clients.

The fact is, however, that despite the government propoganda, opening an offshore bank account is a lot easier than you might think.

It is perfectly legal for Americans to hold as many offshore bank accounts as they wish. And there are still distinguished private banks in reputable tax havens that welcome American clients – especially those who don’t wish to do business in dollars. You will a special note for US Citizens (together with another special note for European Union Citizens) in Q Wealth’s Practical Offshore Banking Guide 2009. Best of all, it includes specific contact details of various banks and brokerage houses. In many cases you can use this information to open your account with no need for hiring an intermediary, and to open an account without even leaving home! You can download this 40-page manual absolutely free with your membership of Q Wealth.

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