Comment Text:
i0-001
COMMENT
CL-04925
From:
Sent:
To:
Subject:
Attach:
RobPlank
Thursday, February 4, 2010 4:40 AM
secretary
Regulation of Retail Forex
USA debt clock.bmp
I have read that there are proposals to change rules again, one of
several in the last twelve months.
The CFTC needs to serious consider what the end effect will be on USA
tax revenue if the CFTC imposes rules
which are more restrictive or different than other countries. Basically,
like several other industries it will be
driven to oversea's locations and markets. Worse in my opinion, the
profits will be first taxed where the account or corporation
is located, even if the trader is located in the USA. Yes, the trader
will finally pay taxes to the USA.
Note, the foreign taxes paid will be credited against the USA taxes
owed/paid. That is unless the tax laws
are changed also.
If reducing leverage is the true goal, then this must be done on an
international basis; otherwise the traders/corporation
will just relocate the trading accounts overseas. The major effect will
be reduce USA tax receipts.
With the projected budget deficits,and current USA government debt and
unfunded obligations, this is not a wise move, simply stated. See
attachment.
Unless the leverage requirement is implemented on a international basis
the only effect will be to change the
leverage requirement for people who do not have significant assets to
open an overseas account and or form an overseas corporation.
I would suggest that the CFTC investigate what percentage of accounts
would be effected by the proposed change in leverage.
My guess would be that $100,000 of assets (total - not just in the
trading account would be needed) in order to
economically justify setting up an account or corporation overseas so
one would not be at a disadvantage to "foreign" competitors.
The actual percentage of accounts that would be effected would be much
less than five percent as a guess. The other
95% of the accounts, would move overseas. What would be the loss in tax
revenue to the U.S. Treasury if this was to occur?
Furthermore, this would prevent or discourage USA taxpayer who do not
yet have sufficient assets to form get an "overseas" account
from taking an interest in the markets. Just like any serious
occupation, one does not immediately jump in and start making money, it
takes
time, experience and training. If discouraged, this is just one more
industry that will permanently move off shore, taking with it the taxi0-001
COMMENT
CL-04925
receipt, present
and future.
Bottom line, unless the leverage requirement is implemented on an
international basis, the only effect ~vill be is to decrease
USA tax revenue. Is the CFTC really this desperate to decrease USA tax
revenue?
