          
          
          
          USE AN OFFSHORE CORPORATION
          OR TRUST TO HOLD SWISS INVESTMENTS
          
          
               It is important to remember that Switzerland is a
          money management center, not a tax haven.  Swiss
          residents, including corporations, do pay fairly
          substantial income taxes.  For this reason, many
          investors seeking to have an investment portfolio
          actively managed from Switzerland prefer to have that
          portfolio owned by a trust or corporation based in a
          tax haven.
               The most popular investments for U.S. investors in
          recent years have been mutual funds and insurance
          products.  For the internationally minded investor,
          there are offshore versions of these products
          available.  In many cases, they offer even more
          benefits to U.S. investors than do their domestic
          counterparts.  The IRS and other elements of the U.S.
          government apparently do not believe in offering
          international opportunities to U.S. citizens, however,
          so in some cases these investments are less attractive
          to U.S. investors than to residents of other countries.
               The main obstacle standing in the way of many
          foreign opportunities is the U.S. securities laws.  Any
          "investment contract" sold in the United States must be
          registered with the Securities and Exchange Commission
          and with its counterpart in each of the states.  This
          is a very expensive process.  U.S. securities laws
          require far more disclosure than do those of most
          foreign countries and also require different accounting
          practices.  Therefore, many offshore mutual fund
          companies decide that whatever income they might
          eventually earn would be inadequate compensation for
          the time and expense involved in attempting to comply
          with U.S. securities laws.  In fact, several of the
          mutual funds and hedge funds with the top performance
          records are run from the United States by U.S.
          residents but do not accept investments from U.S.
          residents.  To reduce registration costs and avoid
          other restrictions, the funds are made available only
          to foreigners. 
               That doesn't mean that there is something dirty or
          illegal about it -- it merely means that the fund is
          not registered for sale in the U.S.
               Successful foreign funds don't need the American
          market and see little reason to pay the outrageous fees
          of our litigious society.  (Some of the best foreign
          cars cannot be purchased in the U.S. for a similar
          reason -- the makers of $100,000 custom cars are not
          about to give the federal government ten free cars per
          year for destruction testing.)  Some of the funds
          cannot meet U.S. legal requirements because they charge
          investors a performance fee rather than a management
          fee based on a percentage of assets.  But many
          investors would actually prefer a fund manager whose
          only compensation is a share of the profits instead of
          a fee based on the total investments in the fund.  The
          manager's goals are different.
               Fortunately, U.S. citizens can get around the
          obstacles through bank accounts or trusts.  Basically,
          you can travel overseas to buy the shares in person,
          you open a foreign bank account and invest through the
          account, or you can establish a foreign trust.  Only
          then will these opportunities be open to you.
               It is not illegal for Americans to buy offshore
          mutual funds (called unit trusts in some countries) or
          any other security that is not registered for sale in
          the United States.
               Creating a foreign irrevocable trust which in turn
          owns a foreign corporation has proven a viable solution
          in some circumstances.  Recently revised Securities &
          Exchange Commission regulations also make it legal for
          such a corporation to purchase foreign shares and funds
          which could not be purchased by an American directly. 
          Regulation S now defines circumstances in which such
          purchases may be made by a corporation indirectly
          controlled by an American shareholder (such as control
          through an asset protection trust).  In many cases such
          a trust and corporation structure can be created in a
          way that provides both asset protection and fully-legal
          income-tax exemption for the trust or corporation.
               One of the best sources of help in setting up
          offshore trusts and corporations is an American
          certified accountant who has a large practice in
          Panama.  Marc Harris holds a master's degree in
          business administration from Columbia University in New
          York, and completed the certified public accountancy
          examination at the age of 18.  He is believed to be the
          youngest person in the U.S. to pass the examination.
               He opened his Panamanian firm in 1985, after being
          a consultant with the accounting firm of Ernst &
          Whinney.  His services are highly recommended because
          he is able to create and administer offshore
          corporations and trusts with complete compliance with
          U.S. laws.  Often an American client uses a tax-haven
          based advisor who knows the local laws but is not
          familiar with American tax law requirements and
          technicalities, and the client eventually gets into
          trouble, so Marc Harris has a unique ability to bridge
          the two worlds for his clients.  Although based in
          Panama, he can create and administer corporations and
          trusts that are registered in all of the popular tax
          havens.
               For more information, please write to: 
                    The Harris Organization
                    Attn: Traditional Client Services
                    Estafeta El Dorado
                    Apartado Postal 6-1097
                    Panama 6, Panama.
          
               The Harris Organization is the Panamanian
          representative for Charles Schwab Discount Brokerage,
          the Jardine Fleming Offshore Funds, JML Swiss
          Investment Counsellors, and other offshore products.
               Purchasing a Swiss annuity or opening a SwissGold
          account can very safely be a do-it-yourself project,
          but if you decide on more active investing that
          requires a trust or corporation, the only way to do
          these things properly is with the proper professional
          advice.  Only a detailed inspection of the specific
          situation, with the aid of competent professional
          advice, can determine what precise approach should be
          followed. 
          
          
          
          
