Senate Report on Dividend Tax Abuse Using Offshore Banking

 

U.S. SENATE

PERMANENT SUBCOMMITTEE ON INVESTIGATIONS

 STAFF REPORT ON

DIVIDEND TAX ABUSE:

HOW OFFSHORE ENTITIES DODGE TAXES ON U.S. STOCK DIVIDENDS

 September 11, 2008

 EXECUTIVE SUMMARY

Each year, the United States loses an estimated $100 billion in tax revenues due to offshore tax abuses.1 The U.S. Senate Permanent Subcommittee on Investigations has examined various aspects of this problem, including how U.S. taxpayers have used offshore tax havens to escape payment of U.S. taxes. This Report focuses on a different subset of abusive practices that benefit only non-U.S. persons, have been developed and facilitated by leading U.S. financial institutions, and have been utilized by offshore hedge funds and others to dodge payment of billions of dollars in U.S. taxes owed on U.S. stock dividends.

Using phrases like “dividend enhancement,” “yield enhancement,” and “dividend uplift” to describe their products, U.S. financial institutions have developed, marketed, and profited from an array of transactions involving multi-million-dollar equity swaps and stock loans whose major purpose is to enable non-U.S. persons to dodge payment of U.S. taxes on U.S. stock dividends. In addition, many of the offshore hedge funds that have benefited from these abusive transactions appear to function as shell operations controlled by U.S. professionals who are helping them dodge U.S. dividend taxes. Six case histories illustrate the scope and nature of the offshore dividend tax abuse problem. 

Subcommittee Investigation 

The Permanent Subcommittee on Investigations has a long history of examining offshore tax abuses. Twenty-five years ago, for example, in 1983, under Chairman William Roth, the Subcommittee held landmark hearings exposing how U.S. taxpayers were using offshore banks and corporations to escape U.S. taxes.2  More recently, in March 2001, the Subcommittee took testimony from a U.S. owner of a Cayman Island offshore bank who estimated that 100% of his clients were engaged in tax evasion, and 95% were U.S. citizens.

In July 2001, the Subcommittee examined the historic lack of cooperation by some offshore tax havens with international tax enforcement efforts and their resistance to divulging information needed to detect, stop, and punish U.S. tax evasion.4

In 2003, the Subcommittee held hearings showing how some respected accounting firms, banks, investment advisors, and lawyers had become tax shelter promoters pushing the sale of abusive tax transactions, including some with offshore elements.5 In 2006, the Subcommittee examined six case studies illustrating how U.S. taxpayers were utilizing U.S. and offshore tax and financial professionals, corporate service providers, and trust administrators to hide assets offshore.6  Earlier this year, the Subcommittee held hearings showing how some tax haven banks have employed banking practices that facilitate tax evasion by U.S. clients.7

The Subcommittee began its investigation into offshore dividend tax abuse in September Since then, the Subcommittee has issued more than a dozen subpoenas and conducted numerous interviews of financial institution executives, tax attorneys, hedge fund managers, and others. The Subcommittee has also consulted with experts in the areas of tax, securities, and international law. During the investigation, the Subcommittee reviewed hundreds of thousands of pages of documents, including trading data, financial records, presentations, correspondence, and electronic communications. Using this information, the Subcommittee developed six case histories to illustrate the scope and nature of the problem. 

Abusive Dividend Tax Transactions

Offshore hedge funds and other sophisticated non-U.S. institutions and companies are active players in the U.S. stock market, often hold large volumes of U.S. stock, and are frequent recipients of U.S. stock dividends. Because many are located in tax haven jurisdictions, they are typically subject to a 30% rate of taxation on their U.S. stock dividends. It is not surprising, then, that these non-U.S. persons have sought ways to eliminate or reduce the 30% dividend tax, since to do so would provide them with significant tax savings and greater yield on their investments.

After reviewing practices at nearly a dozen financial institutions and hedge funds, the Subcommittee uncovered substantial evidence that U.S. financial institutions knowingly developed, marketed, and implemented a wide range of transactions aimed at enabling their non-U.S. clients to dodge U.S. dividend taxes.9  Using a variety of complex financial instruments, primarily involving equity swaps and stock loans, these U.S. financial institutions structured transactions to enable their non-U.S. clients to enjoy all of the economic benefits of owning shares of U.S. stock, including receiving dividends, without paying the tax applicable to those dividends. These structured transactions increased the amount of dividend returns obtained by some of their non-U.S. clients by 30% or more.

The evidence also showed that use of abusive dividend tax transactions is widespread throughout the offshore hedge fund industry. Offshore hedge funds actively sought these abusive transactions, negotiated the terms of the arrangements with the financial institutions, and at times played one financial institution against another to elicit the largest possible tax reduction. In addition, many of the offshore hedge funds benefiting from these tax dodges did not maintain physical offices or investment professionals in their offshore locations, and instead operated primarily under the control of U.S. persons serving as the fund’s general partner or investment manager. In these cases, U.S. hedge fund managers and their employees often played key roles in facilitating the offshore dividend tax abuse.

The purpose of this Report is not to condemn the use of complex financial transactions that utilize stock swaps, stock loans, or other forms of structured finance, which can be used for legitimate business purposes such as facilitating capital flows, reducing capital needs, and spreading risk. Instead, this Report attempts to identify abusive financial transactions that have no business purpose other than tax avoidance and to recommend measures to stop the misuse of structured finance to undermine the U.S. tax code.

Abusive dividend tax practices took hold in the 1990s, and have multiplied since, due to a variety of factors. These factors include the lowering of the dividend tax rate in 2003, which resulted in more companies paying dividends; the implementation of other tax code changes, such as more favorable treatment of swaps, which encouraged tax practitioners to think of ways to disguise dividend payments as swap payments to avoid the 30% dividend tax rate; the proliferation of hedge funds willing to engage in complex financial transactions; the proliferation of “dividend enhancement” products offered by financial institutions to attract and retain clients; the failure of regulators to keep track of and regulate these new products to prevent abusive practices; the general loosening of regulation and oversight of the financial industry, including with respect to offshore activities; and the willingness on the part financial institutions, hedge funds, and their legal advisors to adopt more aggressive and abusive tax practices. 

Abusive Stock Swap and Loan Transactions.

The abusive tax products examined by the Subcommittee were primarily associated with stock swaps and stock lending transactions. These transactions varied in form, complexity, and the degree to which they transgressed, distorted, or undermined current tax law.

Abusive stock swap transactions essentially involve an effort to recast a dividend payment as a swap payment in order to take advantage of the favored tax treatment currently given to swap agreements involving non-U.S. persons. Right now, under the U.S. tax code, while U.S. stock dividends paid to non-U.S. persons are generally subject to a 30% tax rate, “dividend equivalents” paid to non-U.S. persons as part of a swap agreement are not subject to any U.S. tax at all.

Abusive stock swap tax transactions seek to take advantage of this disparity in tax treatment. For example, in one of the most blatant forms of this type of transaction, a few days before a stock is scheduled to issue a dividend, an offshore hedge fund sells its stock to a U.S. institution, temporarily replacing its stock holdings with a swap agreement tied to the economic performance of the same stock. After the dividend is issued, the offshore hedge fund receives from the financial institution a “dividend equivalent” payment under the swap agreement equal to the full dividend amount less a fee. The fee, charged by the financial institution, is usually tied to the tax savings, and generally equals 3% to 8% of the dividend amount. The end result is that the offshore hedge fund receives 92% to 97% of the dividend amount instead of the 70% that it would have received if the 30% in taxes had been withheld. A few days after the dividend date, the offshore hedge fund terminates the swap agreement and repurchases the stock, leaving the offshore hedge fund with the same status it had before the transaction was undertaken.

This type of transaction is intended to enable the offshore client to maintain the same economic benefits (including the receipt of dividend payments) and market risks as owning the real stock, while dodging payment of tax on the dividend equivalent payments. That the offshore client enters into the swap agreement for only a short period of time around the dividend period, and owns shares of the underlying stock both before and after the swap, demonstrates that this type of transaction has no purpose other than to avoid the dividend tax.

More complex variants of this transaction include a multitude of parties, longer time frames, multiple stock sales, and coordinated pricing to give the appearance of market risk and arms length dealing. These elements have been added, as offshore hedge funds and U.S. financial institutions have tried to disguise the true nature of the transactions and avoid their recharacterization by the Internal Revenue Service (IRS) as ones which are subject to dividend taxes.

Another effort to dodge payment of U.S. dividend taxes utilizes stock lending transactions. In a typical transaction, a U.S. financial institution uses an offshore corporation it owns and controls to borrow U.S. stock from an offshore hedge fund. The offshore corporation borrows the stock a few days before a dividend is issued, sells the stock, and simultaneously enters into a swap agreement with its affiliated financial institution. After receiving a tax-free “dividend equivalent” payment under the swap agreement, the offshore corporation passes the payment (now called a “substitute dividend”) back to the offshore hedge fund from which it had borrowed the stock. Relying upon a misinterpretation of an IRS notice on substitute dividends, the parties then claim that no withholding of the substitute dividend payment is required and the payment can be made tax-free. A few days after the dividend payment, the offshore corporation returns the borrowed stock to the offshore hedge fund which then regains the same status as before the stock loan took place.

When this type of stock loan first began appearing, a vigorous debate erupted among legal counsel and their clients about its legitimacy. JPMorgan Chase told Morgan Stanley that the substitute dividend payment was tax-free only if someone earlier in the stock loan lending chain had paid the initial withholding. A potential client told Merrill Lynch that its legal counsel had said the stock loan works “once, maybe twice” but “repeated use, coincidentally around dividend payment time, would provide a strong case for the IRS to assert tax evasion.” He observed that, “it is the repeated ‘overuse’, e.g. pigs trying to be hogs, that proves problematic.”

1 This $100 billion estimate is derived from studies conducted by a variety of tax experts. See, e.g., Joseph Guttentag and Reuven Avi-Yonah, “Closing the International Tax Gap,” in Max B. Sawicky, ed., Bridging the Tax Gap: Addressing the Crisis in Federal Tax Administration (2006) (estimating offshore tax evasion by individuals at $40-$70 billion annually in lost U.S. tax revenues); Kimberly A. Clausing, “Multinational Firm Tax Avoidance and U.S. Government Revenue” (Aug. 2007) (estimating corporate offshore transfer pricing abuses resulted in $60 billion in lost U.S. tax revenues in 2004); John Zdanowics, “Who’s watching our back door?” Business Accents magazine, Volume 1, No.1, Florida International University (Fall 2004) (estimating offshore corporate transfer pricing abuses resulted in $53 billion in lost U.S. tax revenues in 2001); “The Price of Offshore,” Tax Justice Network briefing paper (Mar. 2005) (estimating that, worldwide, individuals have offshore assets totaling $11.5 trillion, resulting in $255 billion in annual lost tax revenues worldwide); “Governments and Multinational Corporations in the Race to the Bottom,” Tax Notes (Feb. 27, 2006); “Data Show Dramatic Shift of Profits to Tax Havens,” Tax Notes (Sept. 13, 2004). See also series of 2007 articles authored by Martin Sullivan in Tax Notes (estimating over $1.5 trillion in hidden assets in four tax havens, Guernsey, Jersey, Isle of Man, and Switzerland, beneficially owned by nonresident individuals likely avoiding tax in their home jurisdictions): “Tax Analysts Offshore Project: Offshore Explorations: Guernsey,” Tax Notes (Oct. 8, 2007) at 93 (estimating Guernsey has $293 billion in assets beneficially owned by nonresident individuals who were likely avoiding tax in their home jurisdictions); “Tax Analysts Offshore Project: Offshore Explorations: Jersey,” Tax Notes (Oct. 22, 2007) at 294 (estimating Jersey has $491 billion in assets beneficially owned by nonresident individuals who were likely avoiding tax in their home jurisdictions); “Tax Analysts Offshore Project: Offshore Explorations: Isle of Man,” Tax Notes (Nov. 5, 2007) at 560 (estimating Isle of Man has $150 billion in assets beneficially owned by non-resident individuals who were likely avoiding tax in their home jurisdictions); “Tax Analysts Offshore Project: Offshore Explorations: Switzerland,” Tax Notes (Dec. 10, 2007) (estimating Switzerland has $607 billion in assets beneficially owned by nonresident individuals who were likely avoiding tax in their home jurisdictions).

2 See “Crime and Secrecy: the Use of Offshore Banks and Companies,” hearing before the U.S. Senate Permanent Subcommittee on Investigations, S.Hrg. 98-151 (March 15, 16 and May 24, 1983).

3 See “Role of U.S. Correspondent Banking in International Money Laundering,” hearing before the U.S. Senate Permanent Subcommittee on Investigations, S.Hrg. 107-84 (March 1, 2 and 6, 2001), testimony of John M. Mathewson, at 12-13.

4 See “What is the U.S. Position on Offshore Tax Havens?” before the U.S. Senate Permanent Subcommittee on Investigations, S.Hrg. 107-152 (July 18, 2001).

5 See “U.S. Tax Shelter Industry: The Role of Accountants, Layers, and Financial Professionals,” hearing before the U.S. Senate Permanent Subcommittee on Investigations, S.Hrg. 108-473 (Nov. 18 and 20, 2003).

6 See “Tax Haven Abuses: The Enablers, the Tools and Secrecy,” hearing before the U.S. Senate Permanent

Subcommittee on Investigations, S.Hrg. 109-797 (Aug. 1, 2006).

7 See “Tax Haven Banks and U.S. Tax Compliance,” hearing before the U.S. Senate Permanent Subcommittee on Investigations (July 17, 2008).

8 The financial institutions examined by the Subcommittee included Citigroup, Deutsche Bank, Goldman Sachs,

Lehman Brothers, Merrill Lynch, Morgan Stanley, and UBS. The hedge funds included Angelo Gordon, Highbridge (a JPMorgan Chase affiliate), Maverick, Moore Capital, and funds managed by the financial institutions listed above. The documents produced by those entities and the interviews conducted by the Subcommittee show that the industry practices described in this Report extend beyond the specific institutions reviewed. In particular, the documents produced by the financial institutions include references to a large number of hedge fund clients.

9 “U.S. financial institution” includes both financial institutions that are organized in the United States and U.S. branches of foreign financial institutions.

10 If one is entitled, for example, to a $70 dividend and receives $100 instead, the increase is approximately 43%.

11 The Subcommittee also identified other financial transactions, such as equity linked certificates and certain stock option transactions using puts and calls, that were used by a few financial institutions to enable their clients to dodge U.S. dividend taxes. These transactions are discussed in brief in the case histories.

12 Treas. Reg. § 1.863-7(b)(1).

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Saint Francis of Assisi, founder of the mendicant Order of Friars Minor, as painted by El Greco.

Catholic religious order

Catholic religious orders are one of two types of religious institutes (‘Religious Institutes’, cf. canons 573–746), the major form of consecrated life in the Roman Catholic Church. They are organizations of laity [...] Read more →

The Racing Knockabout Gosling

The Racing Knockabout Gosling.

Gosling was the winning yacht of 1897 in one of the best racing classes now existing in this country, the Roston knockabout class. The origin of this class dates back about six years, when Carl, a small keel cutter, was built for C. H. [...] Read more →

U.S. Plant Variety Protection Act – Full Text

WIPO HQ Geneva

UNITED STATES PLANT VARIETY PROTECTION ACT

TITLE I – PLANT VARIETY PROTECTION OFFICE Chapter Section 1. Organization and Publications . 1 2. Legal Provisions as to the Plant Variety Protection Office . 21 3. Plant Variety Protection Fees . 31

CHAPTER 1.-ORGANIZATION AND PUBLICATIONS Section [...] Read more →

Guaranteed 6% Dividend for Life. Any takers?

Any prudent investor would jump at the chance to receive a guaranteed 6% dividend for life. So how does one get in on this action?

The fact of the matter is…YOU can’t…That is unless you are a shareholder of one of the twelve Federal Reserve Banks and the banks under [...] Read more →

The Intaglio Processes for Audubon’s Birds of America

Notes on the intaglio processes of the most expensive book on birds available for sale in the world today.

The Audubon prints in “The Birds of America” were all made from copper plates utilizing four of the so called “intaglio” processes, engraving, etching, aquatint, and drypoint. Intaglio [...] Read more →

The Kalmar War

Wojna Kalmarska – 1611

The Kalmar War

From The Historian’s History of the World (In 25 Volumes) by Henry Smith William L.L.D. – Vol. XVI.(Scandinavia) Pg. 308-310

The northern part of the Scandinavian peninsula, as already noticed, had been peopled from the remotest times by nomadic tribes called Finns or Cwenas by [...] Read more →

A Creative Approach to Saving Ye Olde Cassette Tapes

Quite possibly, the most agonizing decision being made by Baby Boomers across the nation these days is what to do with all that vintage Hi-fi equipment and boxes full of classic rock and roll cassettes and 8-Tracks.

I faced this dilemma head-on this past summer as I definitely wanted in [...] Read more →

Valentine Poetry from the Cotswold Explorer

 

There is nothing more delightful than a great poetry reading to warm ones heart on a cold winter night fireside. Today is one of the coldest Valentine’s days on record, thus, nothing could be better than listening to the resonant voice of Robin Shuckbrugh, The Cotswold [...] Read more →

Cup of Tea? To be or not to be

Twinings London – photo by Elisa.rolle

Is the tea in your cup genuine?

The fact is, had one been living in the early 19th Century, one might occasionally encounter a counterfeit cup of tea. Food adulterations to include added poisonings and suspect substitutions were a common problem in Europe at [...] Read more →

A Conversation between H.F. Leonard and K. Higashi

H.F. Leonard was an instructor in wrestling at the New York Athletic Club. Katsukum Higashi was an instructor in Jujitsu.

“I say with emphasis and without qualification that I have been unable to find anything in jujitsu which is not known to Western wrestling. So far as I can see, [...] Read more →

Proper Wines to Serve with Food

Foie gras with Sauternes, Photo by Laurent Espitallier

As an Appetizer

Pale dry Sherry, with or without bitters, chilled or not. Plain or mixed Vermouth, with or without bitters. A dry cocktail.

With Oysters, Clams or Caviar

A dry flinty wine such as Chablis, Moselle, Champagne. Home Top of [...] Read more →

Modern Slow Cookers, A Critical Design Flaw

Modern slow cookers come in all sizes and colors with various bells and whistles, including timers and shut off mechanisms. They also come with a serious design flaw, that being the lack of a proper domed lid.

The first photo below depict a popular model Crock-Pot® sold far and wide [...] Read more →

British Craftsmanship is Alive and Well

The Queen Elizabeth Trust, or QEST, is an organisation dedicated to the promotion of British craftsmanship through the funding of scholarships and educational endeavours to include apprenticeships, trade schools, and traditional university classwork. The work of QEST is instrumental in keeping alive age old arts and crafts such as masonry, glassblowing, shoemaking, [...] Read more →

AB Bookman’s 1948 Guide to Describing Conditions

AB Bookman’s 1948 Guide to Describing Conditions:

As New is self-explanatory. It means that the book is in the state that it should have been in when it left the publisher. This is the equivalent of Mint condition in numismatics. Fine (F or FN) is As New but allowing for the normal effects of [...] Read more →

The Master of Hounds

Photo Caption: The Marquis of Zetland, KC, PC – otherwise known as Lawrence Dundas Son of: John Charles Dundas and: Margaret Matilda Talbot born: Friday 16 August 1844 died: Monday 11 March 1929 at Aske Hall Occupation: M.P. for Richmond Viceroy of Ireland Vice Lord Lieutenant of North Yorkshire Lord – in – Waiting [...] Read more →

Cocktails and Canapés

From The How and When, An Authoritative reference reference guide to the origin, use and classification of the world’s choicest vintages and spirits by Hyman Gale and Gerald F. Marco. The Marco name is of a Chicago family that were involved in all aspects of the liquor business and ran Marco’s Bar [...] Read more →

Cocillana Syrup Compound

Guarea guidonia

Recipe

5 Per Cent Alcohol 8-24 Grain – Heroin Hydrochloride 120 Minims – Tincture Euphorbia Pilulifera 120 Minims – Syrup Wild Lettuce 40 Minims – Tincture Cocillana 24 Minims – Syrup Squill Compound 8 Gram – Ca(s)ecarin (P, D, & Co.) 8-100 Grain Menthol

Dose – One-half to one fluidrams (2 to [...] Read more →

King Lear

Edwin Austin Abbey. King Lear, Act I, Scene I (Cordelia’s Farewell) The Metropolitan Museum of Art. Dates: 1897-1898 Dimensions: Height: 137.8 cm (54.25 in.), Width: 323.2 cm (127.24 in.) Medium: Painting – oil on canvas

Home Top of Pg. Read more →

Gold and Economic Freedom

by Alan Greenspan, 1967

An almost hysterical antagonism toward the gold standard is one issue which unites statists of all persuasions. They seem to sense-perhaps more clearly and subtly than many consistent defenders of laissez-faire — that gold and economic freedom are inseparable, that the gold standard is an instrument [...] Read more →

The Hoochie Coochie Hex

From Dr. Marvel’s 1929 book entitled Hoodoo for the Common Man, we find his infamous Hoochie Coochie Hex.

What follows is a verbatim transcription of the text:

The Hoochie Coochie Hex should not be used in conjunction with any other Hexes. This can lead to [...] Read more →

Horn Measurement

Jul. 23, 1898 Forest and Stream, Pg. 65

Horn Measurements.

Editor Forest and Stream: “Record head.” How shamefully this term is being abused, especially in the past three years; or since the giant moose from Alaska made his appearance in public and placed all former records (so far as [...] Read more →

Seeds for Rootstocks of Fruit and Nut Trees

Citrus Fruit Culture

THE PRINCIPAL fruit and nut trees grown commercially in the United States (except figs, tung, and filberts) are grown as varieties or clonal lines propagated on rootstocks.

Almost all the rootstocks are grown from seed. The resulting seedlings then are either budded or grafted with propagating wood [...] Read more →

History of the Cabildo in New Orleans

Cabildo circa 1936

The Cabildo houses a rare copy of Audubon’s Bird’s of America, a book now valued at $10 million+.

Should one desire to visit the Cabildo, click here to gain free entry with a lowcost New Orleans Pass.

Home Top of [...] Read more →

Mrs. Beeton’s Poultry & Game – Choosing Poultry

To Choose Poultry.

When fresh, the eyes should be clear and not sunken, the feet limp and pliable, stiff dry feet being a sure indication that the bird has not been recently killed; the flesh should be firm and thick and if the bird is plucked there should be no [...] Read more →

Platform of the American Institute of Banking in 1919

Resolution adapted at the New Orleans Convention of the American Institute of Banking, October 9, 1919:

“Ours is an educational association organized for the benefit of the banking fraternity of the country and within our membership may be found on an equal basis both employees and employers; [...] Read more →

A Summer Memory

 

Here, where these low lush meadows lie, We wandered in the summer weather, When earth and air and arching sky, Blazed grandly, goldenly together.

And oft, in that same summertime, We sought and roamed these self-same meadows, When evening brought the curfew chime, And peopled field and fold with shadows.

I mind me [...] Read more →

Palermo Wine

Take to every quart of water one pound of Malaga raisins, rub and cut the raisins small, and put them to the water, and let them stand ten days, stirring once or twice a day. You may boil the water an hour before you put it to the raisins, and let it [...] Read more →

Rendering Amber Clear for Use in Lens-Making for Magnifying Glass

by John Partridge,drawing,1825

From the work of Sir Charles Lock Eastlake entitled Materials for a history of oil painting, (London: Longman, Brown, Green, and Longmans, 1846), we learn the following:

The effect of oil at certain temperatures, in penetrating “the minute pores of the amber” (as Hoffman elsewhere writes), is still more [...] Read more →

JP Morgan’s Digital Currency Patent Application

J.P. Morgan Patent #8,452,703

Method and system for processing internet payments using the electronic funds transfer network.

Abstract

Embodiments of the invention include a method and system for conducting financial transactions over a payment network. The method may include associating a payment address of an account [...] Read more →

A History of Fowling – Ravens and Jays

From A History of Fowling, Being an Account of the Many Curios Devices by Which Wild Birds are, or Have Been, Captured in Different Parts of the World by Rev. H.A. MacPherson, M.A.

THE RAVEN (Corvus corax) is generally accredited with a large endowment of mother wit. Its warning [...] Read more →

Commercial Tuna Salad Recipe

Tom Oates, aka Nabokov at en.wikipedia

No two commercial tuna salads are prepared by exactly the same formula, but they do not show the wide variety characteristic of herring salad. The recipe given here is typical. It is offered, however, only as a guide. The same recipe with minor variations to suit [...] Read more →

The Snipe

THE SNIPE, from the Shooter’s Guide by B. Thomas – 1811

AFTER having given a particular description of the woodcock, it will only. be necessary to observe, that the plumage and shape of the snipe is much the same ; and indeed its habits and manners sets bear a great [...] Read more →

Chinese 9 Course Dinner

The following recipes form the most popular items in a nine-course dinner program:

BIRD’S NEST SOUP

Soak one pound bird’s nest in cold water overnight. Drain the cold water and cook in boiling water. Drain again. Do this twice. Clean the bird’s nest. Be sure [...] Read more →

Making Apple Cider Vinegar

The greatest cause of failure in vinegar making is carelessness on the part of the operator. Intelligent separation should be made of the process into its various steps from the beginning to end.

PRESSING THE JUICE

The apples should be clean and ripe. If not clean, undesirable fermentations [...] Read more →

List of the 60 Franklin Library Signed Limited Editions

The following highly collectible Franklin Library Signed Editions were published between 1977 and 1982. They are all fully leather bound with beautiful covers and contain gorgeous and rich silk moire endpapers. Signatures are protected by unattached tissue inserts.

The values listed are average prices that were sought by [...] Read more →

Why Beauty Matters

Roger Scruton by Peter Helm

This is one of those videos that the so-called intellectual left would rather not be seen by the general public as it makes a laughing stock of the idiots running the artworld, a multi-billion dollar business.

https://archive.org/details/why-beauty-matters-roger-scruton

or Click here to watch

[...] Read more →

Painting Plaster Work and the History of Terra Cotta

The 1896 Victorian terracotta Bell Edison Telephone Building – 17 & 19 Newhall Street, Birmingham, England. A grade I listed building designed by Frederick Martin of the firm Martin & Chamberlain. Now offices for firms of architects. Photographed 10 May 2006 by Oosoom

[Reprint from Victoria and Albert Museum included below on [...] Read more →

Protecting Rare Books: How to Build a Silverfish Trap

Silverfish damage to book – photo by Micha L. Rieser

The beauty of hunting silverfish is that they are not the most clever of creatures in the insect kingdom.

Simply take a small clean glass jar and wrap it in masking tape. The masking tape gives the silverfish something to [...] Read more →

Fly Casting Instructions

It is a pity that the traditions and literature in praise of fly fishing have unconsciously hampered instead of expanded this graceful, effective sport. Many a sportsman has been anxious to share its joys, but appalled by the rapture of expression in describing its countless thrills and niceties he has been literally [...] Read more →

The Charge of the Light Brigade

Half a league, half a league, Half a league onward, All in the valley of Death Rode the six hundred. “Forward, the Light Brigade! Charge for the guns!” he said. Into the valley of Death Rode the six hundred. Home Top of [...] Read more →