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09-06-26  Merlino

https://www.eluniversal.com/el-universal/240771/presidente-trump-necesitamos-mas-nabeps

09-06-26  pillz

if I remember well I sold them between 12 and 15 $

09-06-26  pillz

and of cause I sold way to early :-(

09-06-26  pillz

there was a time that Ford mini notes traded at 2.5$ , most of my portfolio was of those minis, as Ford had 20B$ cash ...and don't needed the US to help them ,,,, this was the time of the mini blonds ...

09-06-26  panasonic

Carib, to recap:

1) Large holding of something like aaple, worth holding not worth go thru w/h hassle.

2) Solid investment, say JPM prefs., yield 6%, not even worth holding.

3) Speculative prefs. in small size not worth it bcz of dividend size.

4) Other speculative prefs. in large size without being in driver seat, not advisable.

09-06-26  carib

Panas: 67K$ on 71MM$ in not worth the hassle, as you say. But my question stays: what is the "expert solution"? In the EU, I can tell you what the legal solutions are, for large size. In the US I just do not know, but I doubt there is a "magical secret sauce" that remained secret. If there is a sauce, it will be known.

09-06-26  panasonic

Carib, back to apple, keep.in mind that 30% of $224k is $67k so not sure if worth the hassle.

09-06-26  panasonic

Carib, on Spals hotel pref. shares keep in mind the whole market cap is 175MM, a big size investor would find hard to invest in it w/o falling in the 10% control under sec rules.

09-06-26  panasonic

Carib, that is clear, hence my question how much dividend should be to justify picking something that has 30% w/h?

Yearly $224k may be worth paying a visit with an expert, me think.

09-06-26  carib

Panas: that misses the point, I am afraid. AAPL is not a "high dividend" stock. It is a capital gain stock. You might remember myself and Wally discussing it 30 years ago. My 2.000 AAPL shares of 1994 would be now, if my memory is correct, 224.000 AAPL shares, worth 71.000.000 $ and change. Dividends, initially 0, are still small change.
But if you take the hotel pref suggested by SPAL, with a 12% dividend.. the tax impact is huge.

09-05-26  panasonic

Carib, this is why I mentioned aapl as example.

Say holder has 30k shares of apple and receives $30k in dividends, I don't think he should find ways to avert a $10k w/h.

09-05-26  panasonic

U.S. sanctions Turkish bank, accusing it of helping Iran transfer oil revenue from China to Turkey by converting it to cash and gold:

https://www.reuters.com/world/middle-east/us-targets-turkish-entities-with-iran-related-sanctions-2026-09-04/

09-05-26  carib

Savo: the iranian regime killed 40.000 of its own subjects this spring, to quell protests. Different scale. Who is the real "satan"? the one wearing a turban IMHO.

09-05-26  carib

Panas: my argument is simple. Investors taxed on dividends, but not on cap gains, prefer shares that appreciate (or have buybacks)to shares that pay high dividends.. unless there is a simple vehicle that avoids taxation.
If, for example, there is an EFT that only invests in high dividend shares, does not suffer taxes on such dividends, and does not distribute any dividend itself, but just delivers capital gains, that would solve the problem... provided the stock composition of the etf is the desired one.

09-05-26  panasonic

Carib, your question remains academic, if dividend is from a company in which holder has "control" is very different from public company.

What anual dividend would you consider worth the effort, bcz ETFs already exist is just looking for one that fits no?

09-05-26  savo

meanwhile the most Satanist States continue killing innocent civilians...

How a US glide bomb soaked an Iranian wedding in blood

Witnesses describe horror after a direct hit on a reception room in Kuhestak that left five people dead


https://www.telegraph.co.uk/world-news/2026/09/04/inside-the-iranian-wedding-bombed-in-us-strike/

09-05-26  carib

Iranian leaders have long warned that they can’t allow a situation in which Arab Gulf states export their oil while Iran’s trade is strangled. When the U.S. blockade was first imposed by Trump, Iranian officials estimated they could hold out for five months or so without catastrophic repercussions for the economy. That point is now approaching fast, forcing a strategic decision on Tehran.

“One option for them is to cave in. The other is to escalate in a much bigger way, to try to fight their way out of the corner,”

WSJ

09-05-26  carib

WHT on dividends can be reduced under existing DTAs, basically to 15%, or to 5% in case of qualified holdings, as far as I remember, but not eliminated.

09-05-26  carib

Panas: such vehicle might exist for non US persons, but I remain curious precisely which one. if it exists, I am pretty sure plenty non-US investors are already using it. Interest paid by US entities is already tax free, and so are capital gains, so the issue is dividends. WT can be reduced by DTA agreements, but only marginally.

09-05-26  panasonic

Carib, same for me, but if size is large enough a savvy financial advisor could help to incorporate something where dividends are reinvested and only sell as needed, under capital gains figure.

As US taxpayer, both dividends (after holding over one year) vs long term capital gains are taxed at same discount rate, so doesn't apply.

09-05-26  carib

Panas: it's academic, for me.. but what "vehicle"?

09-05-26  panasonic

"in size" of course, and exclusively for dividends that can't be solved via an ETF for instance, but if size justifies you could even apply for a vehicle that works that way, cost probably not that high.

09-05-26  carib

Panas: I think the legal way to avoid withholding tax on US dividends, legally, is to arrange a "cum-ex" trade with a counterparty that can compensate the dividend with other losses, and just charges a fee for the service.
That is the idea that was presented in Bermuda.
Obviously.. "in size".

09-05-26  panasonic

Carib, exactly...back to your original question: size matters.

09-05-26  carib


ft

When politicians in, say, France or the UK, get into a tangle with markets, financial market analysts crack their knuckles and give the politicians hell — a healthy back-and-forth that helps politicians and voters to understand trade-offs. We are not quite at that point of brutal honesty with the US yet. 

But for whatever reason — whether analysts can sense blood in the water or whether they are learning to live with the risk of intimidation — they are filing just a slightly sharper point on their analysis. 



09-05-26  carib

Panas: the premise is 0% estate taxes.

09-05-26  carib

SPAL: my question related to not US persons who are merely investors, not employees.

09-05-26  panasonic

Spal, yep, on Carib's question about non-uS person, strategy is completely different.

09-05-26  spal

hile the IRS strictly caps the money going into an account,

===

Nope ... although many think so and that is intentional.

09-05-26  spal

SERPs and Non-Qualified Deferred Compensation (NQDC): Corporate executives structure non-qualified deferred compensation plans and Supplemental Executive Retirement Plans (SERPs). Upon retirement or separation, these multi-million-dollar executive packages are rolled directly into IRAs, transferring large fortunes into tax-deferred environments in a single transaction.

I had a SERP for example.

09-05-26  spal

Panas:

The $10M+ Tier: Approximately 32,000 individuals in the U.S. hold retirement accounts valued at over $10 million each.

Average Balance: ~$17 million per account.

Total Held in $10M+ Accounts: ~$550+ Billion.

The "Ultra-Mega" Tier ($400M+ Average): Within that group, a subset of 208 individuals hold a combined $85.1 billion in retirement accounts—an average balance of $409 million per person.

The $5M+ Tier: Expanding the scope to accounts worth $5 million or more captures roughly 50,000 to 60,000 taxpayers holding nearly $1 Trillion in total tax-sheltered retirement assets.

09-05-26  Merlino

Veni & Pdvsa bonds look set to make new nominal highs next week...we will see...plenty of good news related to the revamping of the country in general and the energy sector in particular.

Best strategy has been to hold and ride out relatively small price corrections...it seems it still is

09-05-26  panasonic

Carib, understood,the short answer is if someone has a large amount of income from USA via dividends, will be wise to check with a CPA and evaluate if worth a structure.

One thing I would consider before tax w/h is if said structure doesn't impact negatively estate taxes.

09-05-26  leopardo

For bondholders, the recovery of Venezuela’s oil sector is the main economic concern,” Austerweil wrote in a note last week. “It will be the only significant source of foreign currency needed to service the restructured bonds for many years.”

“We remain optimistic and expect further gains, but not excessively so, given the many questions that still remain unanswered,” Kulesz said, according to Bloomberg.

09-05-26  carib

Panas: my question was academic.

09-05-26  panasonic

Carib, normal non-us investors that invest in fixed income stick to bonds that have no w/h.

If want to invest in stocks, probably can find ETFs that capitalize dividends, so when sold capital gain is taxed at 0%.

Low dividend payers i.e. Apple, I would not enter complications.

You are referring to very specific name(s) that pay high dividends, enough to consider a structure?

09-05-26  carib

When I was in Bermuda, I was told there are ways to solve the conundrum, but they sounded too complicated for me. Maybe one can do it in large sizes.

09-05-26  carib

My question was: is there such a vehicle available to non-us persons?

09-05-26  carib

6) if you hold the security within a withholding tax exempt vehicle, even better, because you also cash dividends tax free, leave the cash in the vehicle, and get spending cash by borrowing against the shares or rights of the vehicle.

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