Global Prosperity in Canada

[jcolvin2]

The activities of Global Prosperity, and those associated with it, were not confined to the United States. The following are the Canadian government's allegations in a Canadian tax case:

Global Prosperity

b) Global Prosperity is one of the names given by a group of individuals to a program which promoted taxpayers' "opting out" of the Canadian and American tax systems by means of:

i) getting refunds for taxes paid in the current and past taxation years and obtaining access to registered retirement funds on a tax free basis;

ii) removing assets from the jurisdiction such that tax cannot be collected; and

iii) moving assets to low or no tax jurisdictions;

c) Global Prosperity offered a number of schemes in order to generate losses and refunds, including the following:

i) the generating of a tax loss sufficient to wipe out an individual's income for the current, plus the prior three years, but purportedly entering into foreign currency futures or forward contracts through a United Kingdom broker called Union Cal Limited ("Unioncal") and then purporting to enter into offsetting currency futures or forward contracts, with the individual claiming the loss leg in 1998 and the gain leg in 1999; and

ii) the generating of a tax loss sufficient to wipe out the 1999 gain leg by purportedly carrying on trading through another non-resident broker such as LFG or LLC (the "Permanent Loss Scheme");

d) in 1998, the Appellant and numerous other individuals entered into the scheme outlined in paragraph 14(c) by way of their purported participation in one or more joint ventures through Unioncal (the "Union Joint Ventures");
. . .

f) the tax refund so obtained was in some cases used by individuals to access the Permanent Loss Scheme, as cash was needed to pay the promoter associated with Global Prosperity to access the various Permanent Loss Schemes, commissions to the accommodating non-resident broker, such as LFG or LLC, and for capital for the purported trades in 1999;

g) the cash needed by an individual wanting to enter into a Permanent Loss Scheme was 13% of the loss they wanted to generate;

h) the Appellant purportedly entered into currency futures or forward contracts with Unioncal in 1998 and a Permanent Loss Scheme in 1999, pursuant to the promotion by various individuals connected with Global Prosperity, including Gordon Feil ("Feil");
. . .

j) the Appellant's claimed 1999 "trading losses and expenses" of $3,952,543 was claimed on the basis of the Appellant entering into the Permanent Loss Scheme;

Gordon Feil
. . .

l) Feil is associated with Global Prosperity, and is one of a number of individuals who promoted the Unioncal Joint Ventures, the Permanent Loss Scheme and various other schemes offered by Global Prosperity;

. . .

The Unioncal Joint Ventures

. . .

u) the majority of the Participants paid cash for their units, while the remainder borrowed funds from a company called 16857 Yukon Inc. ("Yukon") to purchase their units;

v) Yukon was incorported in the Yukon, and had a non-resident director and shareholder, but at all times Feil had Power of Attorney and signing authority with respect to Yukon's bank accounts and those bank accounts were under Feil's name;
. . .

z) 33 of the Participants purportedly participated in the Unioncal Trading Joint Venture 1998 and, in total, subscribed for 97 joint venture units while also purportedly participating in another Global Prosperity promoted joint venture called the Futures Trading Joint Venture, claiming losses of $13,229,945 from the Unioncal Trading Joint 1998 and $1,593,654 from the Futures Trading Joint Venture;

aa) Nelson Bayford ("Bayford"), administrator of the Futures Trading Joint Venture, was associated with Global Prosperity and was also one of a number of individuals who promoted the Unioncal Joint Ventures, the Permanent Loss Scheme and various other schemes offered by Global Prosperity;

bb) 32 of the Participants purportedly participated in the Unioncal Trading Joint Ventures #1 and, in total, subscribed for 90 joint venture units and claimed losses of $20,431,672 and interest expenses of $760,264;

cc) 23 of the Participants who purportedly participated in the Unioncal Trading Joint Venture #1 also purportedly participated in another purported joint venture promoted by Feil called the Westview, LLC ("Westview"), and claimed further losses of $4,714,543 while being allocated a greater proportion of the Unioncal Trading Jointe Venture #1 losses on a ratio of US $1.6667 to every US $1 for the non-Westview Participants;

dd) the Participants who purportedly participated in Westview borrowed money from Yukon to finance their entire Westview investment and subscription costs;

ee) only three of the nine Participants in the Unioncal Trading Joint Venture #1 who did not participate in Westview put up any funds for their investment and subscription costs;

ff) most of the Participants in the Unioncal Joint Ventures were middle-income earners with little or no investment or trading history;

. . .

ii) other than Feil, none of the Participants provided Unioncal with any information with respect to their net worth or financial position before being issued units in a Unioncal Joint Venture;

jj) on or about December 17, 1998, Feil purportedly signed a Client Agreement and opened a trading account with Unioncal;

. . .

mm) no further funds were ever asked for or deposited into Feil's Unioncal account or any other account with Unioncal respecting the Participants, and no margin calls were ever made or satisfied;

. . .

xx) one Swiss Francs contract was not offset and was never reflected on the Open Position Statement for 1998;

. . .

ddd) when the results of all the contracts were netted there was a gain of $63,765, and when the purported trading ceased on February 4, 1999 there was a cash balance of $739,007 in the Feil's Unioncal account;

eee) between January 11, 1999 and February 2, Feil's Unioncal cash account was in an overdraft position ranging from US$37,350,174 as at January 11, 1999 to $66,539,854 as at January 22, 1999;

. . .

iii) no commissions were payable under the standard form Client Agreement purportedly entered into between Feil and Unioncal;

http://decision.tcc-cci.gc.ca/en/2007/2 ... cc480.html

(The case involves procedural matters and there is no determination as to the merits of the various tax positions taken by the taxpayer.)

[Leftcoaster]

This was what brought me to Quatloos in the first place!

[ASITStands]

There's been a number of groups with the "Global Prosperity" name, and they all seem to have someone named "Struckman" in the background somewhere. Are they all related?

I presume so, but I'd like to see how they all tie together.

[jcolvin2]

There's been a number of groups with the "Global Prosperity" name, and they all seem to have someone named "Struckman" in the background somewhere. Are they all related?

I presume so, but I'd like to see how they all tie together.

To the best of my memory, the Institute for Global Prosperity was a venture run by David Struckman, Dan Anderson and Lorenzo LaMantia. The IGP provided a forum for all types of "interesting" tax and financial products. Initially, Keith Anderson of Anderson's Ark & Associates (AAA) sold tapes through IGP. Keith Anderson ran his operation (which turned out to be a giant Ponzi scheme) from Costa Rica. Keith Anderson and AAA broke with IGP.

I think Gordon Feil's Canadian group maintained connections with AAA. The Canadian authorities description makes it sound like the numbered Yukon company acting essentially in the same way that Keith Anderson's Costa Rican La Machina Blanca operated.

In approximately 2002, the government executed search warrants on numerous IGP and AAA personnel/offices. Dan Anderson and Lorenzo LaManita ceased IGP activity and cooperated with the government. David Struckman fled to Panama, where he started operating PQI. Costa Rica ultimately returned Keith Anderson to the US, where he was tried and convicted. Panama likewise return David Struckman to the US, where he also was tried and convicted.

[ASITStands]

Thanks. Very interesting.

I remember something called "Global Prosperity 2000." Was it just an offshoot of IGP?