The virus entity is

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The following is from the web site of, an organisation that does not, I think share my goals in life. Please read it, it's important:

St. Kitts and Nevis Multiform Foundations Ordinance

The Multiform Foundations Ordinance came into force on October 1st 2005. It introduces a flexible hybrid multiform of foundation into the Nevis international financial services regime.

The Nevis Multiform Foundation is a legal entity shell into which a subscriber can self-design the form of the Foundation, subject to given rules that define it. Therefore, each Nevis Foundation will have a stated multiform, meaning that the constitution of the foundation will state how it is to be treated: whether as a trust, a company, a partnership or an ordinary foundation.

Through the multiform concept the stated identity of the Foundation can be changed during its lifetime, thus allowing for greater flexibility in its use and application.

The Ordinance provides for other entities to be converted or transformed, continued or consolidated or merged into a Nevis Multiform Foundation. Therefore, an entity incorporated outside of Nevis can be transformed into a Nevis Foundation; an existing Nevis entity can be converted into a Nevis Foundation; and any two or more entities from outside or within Nevis can merge into a Nevis Multiform Foundation.

The Ordinance provides for a balance between privacy and transparency and also provides for healthy corporate governance. In light of this, the Ordinance anticipates that Nevis Multiform Foundations will be used for estate planning, charity, financing and special investment holding arrangements.

The Ordinance has a section on forced heirship, making it clear that any Multiform Foundation governed by the laws of Nevis cannot be made void, voidable or liable to be set aside, or defective in any manner by reference to the law of a foreign jurisdiction.

The Ordinance provides that a Foundation can become tax resident in Nevis, subject to an annual fee of $1,000. The Multiform will then be subject to Corporation Tax at a rate of 1% of net income (net profits) with a minimum tax payable of US$1,000 per annum. This is particularly important for some jurisdictions, and again enhances the flexibility of these entities.

I admit, we in the Tax Justice Network thought we'd seen just about every form of abusive corporate structure imaginable until we came across this, but this takes it to new depths.

Here we have a company that behaves like a mutating virus, able to take on any form at will, resistant to the challenge of any other jurisdiction, capable of subsuming weaker structures and claiming to be good for health but actually fundamentally undermining it.

This structure is so abusive that it makes any attempt to list the type of entity offered within offshore/secrecy jurisdictions obsolete: since structures of this sort can take any form, and be reformed at will, then abuse has reached the point where the only meaningful action is to presume that every entity of every sort created within a secrecy jurisdiction is subversive unless proven, individually, otherwise.

The jurisdictions damn themselves with their own abuse.