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09-04-26 panasonic
| Carib, search no more, perfectly legal. |
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09-04-26 panasonic
| Ford minis are notes, not prefs., no w/h taxes and yield near 8% |
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09-04-26 carib
That said, my issue was about dividends, and withholding taxes.
Avoiding capital gain taxes in the USA (and elsewhere) on the other hand, seems quite easy:
1) you hold appreciating assets
2) you do not sell any
3) for your expenses, you borrow using the assets as collateral
4) when you die, you leave the assets to the kids, who benefit from the "step up" loophole.. and continue the exercise.
5) in order to pay back the loan, you sell assets that did not appreciate, or lost value. |
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09-04-26 panasonic
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09-04-26 carib
| In the EU, a contribution to a pension or life insurance account, is considered equal to a sale, in tax terms, so an independent valuation is required in case of unlisted securities. I am not sure about the US rules. But anyway, you can have funding shares in a certain vehicle that initially, from an accounting point of view, are worth peanuts, but when the vehicle becomes multi-billion, are worth a fortune. As an example, Dolce and Gabbana sold their trademark to a Luxembourg company when their firm was in its infancy, and the appreciation took place within the purchasing vehicle when it became a billion euro business.. |
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09-04-26 carib
| Panas: I do not know the details (none of my business) but one thing does not exclude the other. |
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09-04-26 panasonic
| Carib, my interpretation is that Romney sold himself unlisted shares at pennies to his retirement account, and once listed the value exploded to "real" value, legally funding his retirement account in millions. |
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09-04-26 carib
| Panas: thanks, that is easy to understand. I also understood Romney, who was managing Bain, kept very legally offshore structures, which accrued without US taxation as long as there were no distributions. |
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09-04-26 panasonic
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09-04-26 panasonic
Sinply explained (not everyone has access to penny stocks private placements before value explodes).
The "Loophole" That Bypassed the Limits.
Romney did not build his massive wealth by making multi-million dollar deposits, which would have violated IRS contribution caps.
Instead, he worked within the $30,000 annual limit by changing what he bought via Bain Capital.
Nominal Pricing: If Bain Capital set up a new company, the initial shares had virtually no open-market value. Romney could legally use his retirement account to buy thousands of these private shares for a total cost of under $30,000.
Infinite Growth Cap: While the IRS strictly caps the money going into an account, there is no legal cap on how much an investment can grow once inside.
When those small startups were restructured or went public, his $30,000 investments exploded into millions of dollars entirely tax-free |
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09-04-26 carib
Spal: I am not denying that, and my interest is purely academic, not being a "US person". I would be interested in reading something about "unlimited contributions IRAs, for my persoal culture.
But, as a non-US person, who already has perfectly legal tax avoidance vehicles, my main tax problem is avoiding withholding taxes. Tax deferral instruments are not required.
I do understand that in the US one can use arrangements that allow tax deferrals.. and passover to the next generation. Interesting for US persons. |
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09-04-26 panasonic
| Spal, of course generally speaking, retirement accounts of US middle class. |
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09-04-26 spal
but I read that exempt contributions are only allowed in very small annual amounts.
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Then check in with Mitt Romney and Peter Theil - both big IRA users. There are clear ways to around limitations. |
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09-04-26 carib
| not really worth a comment.. but if the USA was to stop importing from countries producing cheap stuff.. that would increase US inflation, and require higher rates, not lower ones. |
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09-04-26 victor
savo, also upset because of the usa's trade deficit..
in spite of all his BS, he has been unable to turn the usa into having a trade surplus.
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Trump threatens to stop trading with countries that have a trade deficit unless the Fed cuts rates
Touting Friday's blowout jobs number, President Trump used the opportunity to weigh in on a new spike in the US trade deficit, threatening embargoes on unfavored countries.
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09-04-26 victor
savo, he's upset because bond traders don't buy his BS.
so he now pressures the fed to lower rates in their next meeting.
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LOWER THE RATE OR I’LL STOP TRADING WITH COUNTRIES WITH WHICH WE HAVE A DEFICIT |
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09-04-26 savo
| the first jobs number is always fake... and revised down in following months. |
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09-04-26 victor
| Great jobs number just announced, breaking all estimates (except mine!) by double and triple - And you haven’t seen anything yet! EMPLOYERS ADDED 162,000 JOB IN AUGUST. Lower the interest rates because the U.S.A. is a much stronger credit than it was just a short time ago! A STRONG COUNTRY MEANS A LOWER INTEREST RATE - IT’S A BETTER CREDIT…Very simple! We should have the LOWEST RATE of any country in the World, like “the old days.” Without the United States agreeing to allow them their big surpluses, and we could stop that immediately, they would no longer be considered financially ELITE! LOWER THE RATE OR I’LL STOP TRADING WITH COUNTRIES WITH WHICH WE HAVE A DEFICIT, which the U.S. Supreme Court, in its ridiculous and very costly Tariff decision, strongly acknowledged “the President” has an absolute right to do. IT’S BETTER THAN TARIFFS! The Fed Board, with its great new leader, must get smart - BE PATRIOTS for a change. High interest rates put the U.S.A. at a very unfair disadvantage, and I won’t allow that to happen! President DONALD J. TRUMP |
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09-04-26 victor
| How crazy is this? We just got GREAT Numbers on Jobs, the Market should go UP, because our Credit and Economy are better but, as always, for the past 25 years, the Stock Market goes DOWN, because we’re living under False Reality that if things are good, you’ve got to “KILL IT” because of a “fear” of Inflation. It should be the opposite, and always was until 25 years ago. If we stay with this Theory, we will never be able to have the True Economic Greatness for our Country that it deserves, because every time we do well, the stupid people want to immediately stop this Great Upward Momentum. GROWTH DOES NOT CAUSE INFLATION! I knew this morning as soon as I looked at these fantastic Job Numbers that the Market would go down when it should be going UP like a Rocketship. We should be doing GDP of 15 and 20%, not 2, 3, and 4%, and America should become Far Greater Financially than it is right now. Our Debt would be paid off, and all of these other things would happen. Remember, every point in the Interest Rate costs the U.S. 650 Billion Dollars a year. We should pay the Lowest Interest Rates in the World because we make everything run, and give otherwise failed countries Great Economic Wealth! Thank you for your attention to this matter. President DONALD J. TRUMP |
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09-04-26 carib
"Venezuela tiene muchísimo más petróleo": Toro Hardy apunta al fracking como clave del potencial real
El exdirectivo de Pdvsa afirmó que al país le habría convenido que empresas líderes del sector, como ExxonMobil y ConocoPhillips, ingresaran para impulsar la recuperación de la industria, pero han evitado invertir por los riesgos políticos y judiciales. Consideró que primero se debió ir a un proceso de democratización para avanzar hacia en acuerdo petrolero con Estados Unidos
El presidente Trump parece no haber obtenido los resultados que esperaba de la reunión que sostuvo con empresarios del sector en la Casa Blanca el 9 de enero, apenas días después de la captura de Nicolás Maduro. El magnate neoyorquino exigió a las petroleras invertir 100.000 millones de dólares en Venezuela para revitalizar la industria, pero los directivos expresaron serias dudas relacionadas con la seguridad política y jurídica del país.
Uno de ellos fue Darren Woods, director ejecutivo de ExxonMobil, quien señaló la confiscación de los activos de la firma en dos ocasiones y condicionó su reingreso por tercera vez a cambios significativos con respecto a lo que históricamente se ha experimentado en la industria y a las condiciones actuales en Venezuela.
En el encuentro, en el que estuvieron además representantes de ConocoPhillips, Shell, Hilcorp, Eni y Repsol, Woods también dejó claro que Venezuela no es atractiva para la inversión si continúan vigentes las mismas estructuras y marcos legales y comerciales. Afirmó que, si se solventaran esas condiciones, su compañía trabajaría de inmediato en la nación. |
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09-04-26 carib
| China, militarily, remains a "regional superpower". Venezuela is way too far for "power projection". The main chinese tool in latin america remains trade. Now in Brasil most new cars one sees in the streets tend to be chinese (assembled locally). |
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09-04-26 victor
china.. interesting
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Bloomberg) -- Venezuela is becoming a major testing ground for Donald Trump's hemispheric ambitions, emerging as another potential source of rivalry with China.
After announcing plans to seize control of more than 65 billion barrels of Venezuela's crude reserves, the Trump administration made clear that was only the start. Ahead is a campaign to squeeze out China and powers like Russia that the White House has called "malign foreign actors," in a push to ensure "American dominance in our hemisphere is never again questioned."
Next on Washington's agenda is an attempt to restructure Venezuela's debt, which includes billions of dollars owed to China. US Energy Secretary Chris Wright on Wednesday declared Beijing won't have any claims to revenue from Venezuela's oil production — severing Caracas' primary channel for making repayments.
The US has cast its campaign as the latest chapter of the "Donroe Doctrine," codified in the White House's National Security Strategy and which asserts a unilateral US right to deny rival powers the ability to own or control "strategically vital assets." Under that banner, taking Venezuelan oil fields from Chinese companies is a geopolitical opportunity to align them with Washington's interests.
China has reduced its exposure to Venezuela in recent years and Trump would likely struggle to replicate the scale of his actions in Venezuela elsewhere, meaning for Beijing the implications are more political than economic.
A more interventionist US risks bumping up against China's broader interests in South America, said Christian Reyes, a Beijing-based political risk analyst originally from Ecuador.
"Venezuela isn't necessarily a precedent for direct expropriation, but it may be a precedent for coerced exclusion," he said. "The United States is increasingly willing to define parts of the region's economic relationship with China as a security concern and to leverage considerable influence to enforce those red lines."
China's reaction so far has been relatively muted. Foreign Ministry spokesperson Guo Jiakun said China's legitimate rights and interests in Venezuela "must be protected," at a regular briefing in Beijing on Thursday. "Cooperation between China and Venezuela is protected by international law," he added. "It doesn't concern any third party."
Ahead of President Xi Jinping's first state visit to the US in over a decade this month, officials from the world's top economies are seeking to avoid any major bust-ups, even as they clash on issues from trade imbalances and Beijing's economic support for Tehran.
For Beijing, Venezuela has become a less important source of energy in recent years. Crude from the country accounted for only 4% of the country's total oil imports in 2025. No Venezuelan cargoes have been recorded arriving in China since the Trump administration assumed control of the assets following the capture earlier this year of then President Nicolás Maduro.
The bigger blow might be to the billions of dollars in debt owned to Chinese banks, which is tied to undelivered oil barrels. While Caracas stopped publishing detailed information about such liabilities after its sovereign default in 2017, the total debt pile to China was believed to total at least $10 billion as of 2025.
That figure has already come down considerably from its peak. China first began financing Venezuelan infrastructure and energy projects in 2007 under former President Hugo Chávez. Publicly available data suggests Chinese state banks had extended more than $60 billion in oil-backed lending to the country by 2015.
As US sanctions on Caracas intensified over the following years, China emerged as Venezuela's largest crude customer and its most significant foreign creditor. State-run companies including China National Petroleum Corp., the parent of PetroChina Co., and China National Offshore Oil Corp. developed oil and gas projects in the Orinoco heavy-oil belt and elsewhere.
Chinese private firms, among them Concord Resources, also invested into stakes in upstream assets.
But the operating environment became increasingly difficult as Venezuela's economy deteriorated and production facilities ran well below their intended capacity. Such moves accelerated after the US sanctioned Venezuela's oil sector in 2019, although some legacy Chinese joint ventures and contracting staff including those from CNPC may still remain in Caracas.
That means claims the US is taking back oil fields from foreign adversaries won't have a huge impact on Chinese companies, which had scaled back as Beijing's strategic priorities evolved.
The bigger hit might be to Chinese refiners, already suffering from disruptions to their supply from Iran.
Independent processors in Shandong province, in particular, have long relied on Venezuelan heavy crude as a feedstock for bitumen production. The loss of those supplies has tightened the domestic bitumen market, helping drive futures prices sharply higher.
For most Chinese companies and creditors in Venezuela, the risks of doing business were already well known, analysts say, meaning the latest upheaval won't come as a shock.
"South America has long been a geopolitical crossroads where the interests of China and the US intersect and, at times, collide," said Liao Na, founder of energy research focused firm GL Consulting. "Given the importance both powers attach to Venezuela, friction is almost inevitable whenever their interests overlap."
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09-04-26 carib
| Panas: IRAs are a very intelligent tool indeed. |
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09-04-26 panasonic
"only allowed in very small annual amounts"
Yes, contributions to retirement plans are limited, but has been a great way to create wealth in USA, the numbers surprise me for good, compound has been astronomic on the past 30 years.
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09-04-26 carib
Panas: as I suspected.
I understand SPAL has a legal way to avoid withholding tax on US dividends, but I suspect it applies only to US persons.
For those, I know about 401K and Roth IRAs, but I read that exempt contributions are only allowed in very small annual amounts. |
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09-04-26 panasonic
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09-04-26 leopardo
| Carib don’t forget Hat and Glasses When you go fishing… |
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09-04-26 carib
| SPAL: is it dividend or interest payment? |
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09-04-26 leopardo
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09-04-26 carib
Leo: thanks for the advice!
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09-04-26 spal
1. The Arbitrage: Preferred Seniority vs. Discounted Pricing
At ~$16.95 per share, BHR.PRD trades at a ~32% discount to its $25.00 liquidation preference.
Contractual Coupon: It carries a 8.25% fixed coupon on its $25 par value ($2.0625/year). At today’s market price, that translates to a ~12.1% current dividend yield.
Capital Appreciation Upside: If BHR successfully internalizes and normalizes its capital structure, the preferred stock should trade back toward par ($25.00), yielding an additional ~47% capital gain on top of the double-digit dividend.
2. Why Preferreds Area Better "Play" Than Common Equity
CAPITAL STRUCTURE SENIORITY
┌─────────────────────────────────────────┐
│ Property Mortgages & Debt │ ◄── Paid First
├─────────────────────────────────────────┤
│ Series D Preferred Stock (BHR.PRD) │ ◄── YOU ARE HERE (Par Value: $25)
├─────────────────────────────────────────┤
│ Ashford Exit Toll / Termination Cash │ ◄── Contracted Settlement
├─────────────────────────────────────────┤
│ Common Stock (BHR) │ ◄── Residual Value Only (High Dilution Risk)
└─────────────────────────────────────────┘
A. The Cumulative Dividend Shield
Unlike common stock dividends (which can be cut or eliminated at board discretion), BHR.PRD dividends are cumulative. If BHR pauses or trims a preferred payout during a tight liquidity phase while asset sales close, the company cannot pay a single cent to common shareholders or execute common stock buybacks until all accrued preferred dividends are paid in full.
B. Priority Over the Common Equity Ransom
The fundamental risk of the common stock (BHR) is that selling off trophy assets (like the Park Hyatt Beaver Creek or Sarasota properties) to satisfy debt and Ashford's $480 million fee will shrink the company's asset base so drastically that very little common equity remains.
However, the Preferred Stock doesn't care if the common equity gets diluted. As long as the shrunken, surviving self-managed core (holding ~$1 Billion in luxury hotels) generates enough net operating income to service mortgage debt and cover preferred dividends, preferred unitholders get paid 100% of their money.
C. The M&A / Takeover Ceiling
If a private equity firm (such as Blackstone or Starwood) steps in to acquire the clean, self-managed BHR post-Ashford, they cannot simply wipe out the preferred stock. In a buyout or liquidation scenario, preferred unitholders must be redeemed at their full $25.00 par liquidation preference (plus accrued dividends) before the buyer takes the remaining equity.
3. The Key Risks to Monitor
While BHR.PRD is safer than common stock, it is still a high-yield corporate credit play:
Liquidity Timing Drag: Asset sales take time to close. If hospitality RevPAR softens before the final transactions settle, cash flow could tighten, causing short-term price volatility.
Subordination to Senior Mortgages: The preferred stock sits below property-level debt. BHR must execute its refinancing and debt paydown plan successfully to avoid balance sheet strain.
Summary
Playing the BHR separation via the common stock is an unhedged gamble on the residual "stub."
Playing it via Series D Preferred (BHR.PRD) converts the situation into a senior credit trade: you lock in a ~12% yield to wait out the divorce from Bennett, with a clear legal path to a ~47% upside payout to $25 par value as institutional governance is restored. |
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09-04-26 spal
Savo - there is likely nothing written on it except what I have dredged together with AI. This is a RE REIT controlled by Ashford. It was put together by Monty Bennett who is one of the world's most abusive RE manipulators. Braemar was a spin out of his very upmarket properties. Basically he retained the "externalized" management rights including probably one of the world's most egregious exit clauses (legal under Maryland law). Long story is that an activist is now in charge of Braemar and is exiting all ties with Bennett - at a cost of about 500 million. My view is that there will still be substantial value in the vehicle after they pay the king's randsom, but this depends on REVPAR of very exclusive resorts staying reasonable as they are sold.
1. Probability of a Successful Escape: ~75% to 80%
The probability of physically severing ties with Bennett and remaining an independent company is high, but the probability of doing so without significant equity dilution is moderate.
Why it will succeed operationally: BHR concluded its strategic review by formally agreeing to internalize management and become a self-managed REIT. The board overhaul is underway, executive search firms are placing an internal team, and high-value asset sales (such as the Park Hyatt Beaver Creek for $176M, The Clancy, and the Sarasota/Yountville properties) have already closed to fund debt paydowns and the $480M exit toll.
The Residual Failure Risk (20–25%): The primary remaining operational threat is liquidity/execution drag. If broader hotel RevPAR slows rapidly before the full $480M buyout toll is cleared, asset sale pricing could soften, forcing BHR to sell more of its core properties than initially planned to pay off Ashford.
2. Are the Units Currently Discounted? Yes, Massively
At a common share price of ~$2.00–$2.05 (Market Cap ~$140M), BHR trades at an extreme governance discount:
Discount to Private NAV: Conservative private-market asset valuations (post-asset-dispositions and accounting for remaining mortgage debt and preferred stock) put BHR’s net asset value between $6.00 and $7.50 per share. The stock currently trades at roughly a 65%–70% discount to its underlying NAV.
Preferred vs. Common Disconnect: BHR’s Series D Preferred stock (`BHR.PRD`) trades near $16.95 (a ~32% discount to its $25 liquidation preference) yielding ~10%. This indicates the debt and preferred markets see a surviving business, while the common stock is priced like an distressed asset liquidation.
3. Can They Bounce Back? (The Two Recovery Scenarios)
Yes, but the nature of the bounce depends on how management treats the surviving equity:
Scenario A: The Standalone Re-Rating (Base Case)
Once the $480M fee is fully satisfied and Ashford is legally gone, BHR cuts $25M+ in annual G&A/advisory expenses.
The Math: Adding $25M back to net cash flows raises Adjusted Funds From Operations (AFFO) back to $0.50–$0.70/share. On a standard self-managed hotel REIT multiple (8x–10x AFFO), the common stock naturally re-rates to $4.50 – $6.00.
Scenario B: The Private Equity Takeover (Bull Case)
Historically, once an externally managed REIT internalizes and cleans its balance sheet, it becomes a prime target for private equity buyers (e.g., Blackstone, Starwood) who want trophy luxury real estate unencumbered by poison pills. An outright buyout would likely clear at $6.50 – $8.50 per share.
4. What Is the Realistic Time Frame? (12 to 36 Months)
A turnaround of this structural magnitude moves through three distinct phases:
```
PHASE 1: Execution & Ransom (Months 0–6)
├── Finalize asset sales & remit Ashford's cash payout.
└── Complete Board seats refresh & hire internal C-suite.
↓
PHASE 2: Baseline Stabilization (Months 6–18)
├── First clean earnings quarters showing $25M+ G&A savings.
└── Re-establish institutional coverage; eliminate legal noise.
↓
PHASE 3: Institutional Re-Rating / Sale (Months 18–36)
└── Stock multiple expands toward peers ($5.00–$7.00+) OR buyout.
```
Near-Term (0–6 Months): High volatility. The stock will remain range-bound ($2.00–$3.00) while asset sales close, legal disputes with activists settle, and cash flows to Ashford.
Medium-Term (6–18 Months): The initial recovery window. As BHR reports its first full quarters as a self-managed entity showing lower G&A costs and improved AFFO margins, institutional investors begin returning, driving a move toward $4.00–$5.00.
Long-Term (18–36 Months): Full value realization. The market fully prices in the clean luxury portfolio, or an M&A buyer acquires the remaining shrunken luxury core, closing the gap to the $6.00–$7.50+ NAV.
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09-04-26 spal
| Only AI compositive stuff ... unfortunately I go by cyber-Schpal these days ... I will check my logs. |
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09-04-26 savo
| thanks spal... do you have anything I can read on it? |
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09-04-26 spal
where is a current fixed income instrument or a non current one in the process of being restructured that can offer 50% upside over the next 2 years like veni today?
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I am have been buying BRAEMAR HOTELS & RES 8.25% PFD Callable BHR/PRD at c.$17 - it can certainly go to 25 in two years and is current. |
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09-04-26 leopardo
| Just keep your positions and go fishing. |
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09-04-26 leopardo
Every deal that will increase prosuction over time, every good political news will support our Blonds...
No rush to sell.. |
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09-04-26 leopardo
| Our bonds will continue climbing Carib…smoothly |
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09-04-26 pillz
Pill: can't a good AI programme run that call/put programme automatically?
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NO , I tried some trading with AI , and they have NO feeling for trading ... |
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