The finance industry is rallying its trolls today: ample are seeking to comment on the blog saying three things.
The first is that Cameron did not avoid tax using an offshore fund. Well actually, that's not true: part (but I agree not all) of all such funds can be rolled up tax free. But to be candid, I'm not making a big deal of this.
Second they say there was no avoidance in the fund. But in that case why go to such lengths to be offshore to ensure no tax was paid? Of course there was avoidance.
And third, all seem to ignore the bearer share issue and the fact that the additional costs of being offshore must have been for a good reason, which can only be tax.
So they are by and large being deleted and this is the reply to all who try to repeat the exercise.
But I repeat,my argument is fourfold.
First Ian Cameron avoided tax, legally.
Second, Cameron benefitted from that.
Third, he says he is proud of what his dad did.
And fourth he condemned Jimmy Carr for avoiding tax.
This is the problem.
If he said, as I mentioned earlier this week, that he respected his dad but would not have done as he did then David Cameron could walk away from this head held high. His having an investment in the fund for a while would not have changed that for me. But it's the fact that he has condoned the use of offshore by his father (and so by implication, I presume, by others) that I think is wrong and the trolls seem quite unable to get that this is what I am saying.
I won't repeat myself for each of their sakes.
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Another problem seems to be that he never declared ownership of these shares in the register of interests as MPs are supposed to. Others will know more than me on this I’m sure.
Do we know this to be true? Have to say, it was my first thought when I watched the news on Thursday evening.
Isn’t there some rule that if it’s less than 15% of total shares you don’t need to. Be assured his dad’s money (all earned by hard productive grift!) will be squirreled away somewhere nice and safe.
It’s 15% need not be distributed
I thought he said he did declare this – he’d be in a lot of trouble if he had not.
OK, I got this from Martin Odoni on FB;
“Okay, here’s the ‘seriouser and seriouser’ detail…..
David Cameron says he sold off the 5,000 units he held in Blairmore Investment Trust in January 2010. Unfortunately, this will in no way get him off the hook.
Why? Because the Register of Members Financial Interests reports dated from the 9th Dec 2009, through to the 3rd February 2010 show no record of him holding or trading these shares, even though he had been a serving MP for nine years by that point. The guidelines even as they stood in 2009-10 stated clearly that all shareholdings should be declared.
Therefore, Cameron is not only a hypocrite over tax-avoidance, he is also guilty of failing to declare a financial interest, which is possible fraud.”
As I said, some know more than me on this.
MPs were not required at the time to report shareholdings worth less than £70,000, interests in a partnership amounting to less than a 15% interest and shares inheld in unit trusts.
On what basis do you think he should have declared the shares?
Full disclosure – always wise
Typo alert: ‘Fiancne’ (conjures up image of ‘acne’ ridden city slickers!).
Correction in its way
I am so tired…..
Look after yourself Richard-I get the impression you’ve been pushing it for some time-if it’s any consolation Bill Mitchell’s blog has his fair share of typos, impossible to avoid working so fast whilst trying to keep up with the information flow (I can barely get through a psot(sic) without at least one!)
It’s the content, not the typos, that matter, that we read and greatly appreciate and learn from.
Whatever the workload, I’ve learned the hard way that you must take a few days out to recover, whatever the news. Just do it; your regular readers will not only understand but also be glad to know that you’re looking after yourself in the most essential way, ie so that you don’t burn out. At this moment, I wish you only the conviction to rest and recover as you must.
Well Trolls are not particulalry intelligent beings by all accounts – be they on the internet are in fantasy stories.
Take 5 Richard – get some of your favourite choccy biscuits, make a cup of tea and take stock of the wool you have helped to remove from people’s eyes about this issue.
Actually, I am now in my faviourite cioffee shop writing a chapter plan for a new book on ….. tax havens
Hi Richard. I don’t post often but I’m an ardent fan and read your blog several times a day. It is surely one of the most intelligent, informative and pro-active of its kind on the Net. You are doing an amazing job in raising people’s awareness as to what ‘goes on’ in financial and political circles and, perhaps more importantly, educating us in the complexities of international tax and finance. In addition you find time to author books and appear in public. I’m am amazed at your energy and output. So, please do take all the time you need to chill and switch off. It’s important. Your country needs you! Enjoy the coffee. (It’s a personal message so no need to publish it if you’d rather not).
Thanks
Richard
Hearing you say that you were knackered today with all the work you have done and then telling us you were in a coffee shop planning your next book made me realise that perhaps you ( and those few people like you) are the real super-heroes of our time.
You may not wear a special suit of any kind, propel yourself through the air or have a fancy name; nor do you carry a shield or drive a fancy car that can fly or have x-ray vision.
You are in fact by your own admission in your late fifties, have a bald patch, eat too many biscuits and like trains.ïŠ
Not to worry.
You are the best super-hero ever in my opinion – a real super hero. How can anyone give up hope with you around.
Keep on keeping on.
I can assure you I don’t feel like one
JohnD, you forgot to mention his City Uni lecturing job…
Richard,
Look upon this trolling as a badge of honour.
The more truth you tell the more they will try and drown your message with lies and obfuscation.
On the plus side (for me anyway) I do enjoy your terse responses to the trolls. You certainly don’t feed them!
Peston accused me of being grumpy
How dare he!
I’m much angrier than that
It’s reminiscent of 2008 when (radio 4 comes to mind) when financiers were given media priority to write their own script and thus tilt the perspective of culpabilty away from themselves and towards ‘global pressures’ and ‘state overspend’.
Agreed BBC and other media wheeled them in today – I wonder who phoned around to arrange this?
Good.
Another lid being lifted.
More light being shed on the dark recesses of finance and money.
Looking forward to it already.
Back of envelope calculations on loss of tax through offshore fund like one Mr Cameron part of:
If profit to be distributed is say 100.
If based in UK, corp tax is say 20.
If investors British and on basic rate(both unlikely): dividend is 80 and HMRC receives 20 in income tax.
So HMRC gets 40 if Blairmore in London.
If Blairmore in offshore zero tax jurisdiction:
Investors (on same basis as above) dividend is full 100.
HMRC receives 25 in tax from investors.
At these rates: HMRC gets 15 LESS than would have got if Blairmore in London.
That is tax evasion, isn’t it?
If figures changed to 40% higher personal income tax (more likely, obviously), but same corp tax, the figures change as follows:
Blairmore in UK HMRC receives : 52
Blairmore offshore HMRC receives: 40 (ie full 40 on full 100 paid out).
So now HMRC gets 12 LESS than if Blairmore not offshore.
Either way on these rounded bald figures, HMRC is shortchanged by fund between 12-15%.
That is what is wrong with Mr Cameron’s position, especially in light of his ‘commitment’ to austerity (for others).
I am not an economist or an accountant, so someone in the know please tell me I’m wrong, if indeed I am.
Thanks
This is wrong but I am too tir to explain why
Robert
I honestly don’t think DC’s ownership of those small number of units would have much tax effect one way or the other. The CGT on, like, £30k will always be negligible.
I don’t know why DC didn’t start by saying that he owned them, but he didn’t.
I assume it is more to do with public relations. In which case the Tories made a big mistake allowing Mr Quarmby to arrive on R4 & assure us that “millions” of people hold their investments in roll-up funds in BVI. I’m sure Tories honestly think that: when some poor fella is made redundant at Port Talbot they think, well, he’ll need to repatriate his Cayman Island funds.
There is a horrible disconnect between us & the people who govern us &, regrettably, UKIP have been first out of the blocks in recognising that.
I accept your tax points entirely
It is why there is doubt about whether the whole truth has been told
“First Ian Cameron avoided tax, legally”
The Panama papers suggest that the fund was administered from within the UK. If this is the case (& I’d guess that this would require a court case by HMRC) then I’d suggest that Cameron-senior did not avoid tax legally – he dodged it. This is the core problem, I’m guessing that HMRC has never considered looking at the Cameron-seniors tax affairs.
It is claimed that when one invokes the Nazis one loses the argument. Hitler was being persued by the German tax authorities up to the point he became Chancellor. It all stopped at that point. In the UK it “all stopped” in 1979 with respect to Tories and tax dodging – the rest is history. The Tories have instituted a UK tax regime where those with the resources dodge tax and the serfs (=PAYE) pay.
You have forced Godwin’s Law to be invoked. What a shame.
For those (much rarer but it does happen) that invoke 1066 as a defining moment can we call it Godwinson’s Law?
But indeed, identifying the nazi invoke as a ‘thing’ has accelerated its use especially as a debate blocker.
I think it depends on why cameron pere fabricated non-UK control.
If he did it to reduce the company’s tax or others’ liability then he almost certainly would have committed a criminal offence.
If, as has been suggested elsewhere, he did it enable the company to participate in current markets more effectively, that may or may not have been a criminal offence.
Either way, fabricating non-UK control is disgraceful and not something that anyone can be proud of.
“he did it (to) enable the company to participate in current markets”
I have been investing in companies/stock markets for more than 30 years. Europe, US, Australia. Oddly, I never felt the need to “go off shore” to “participate” in those markets. It would thus be interesting to hear under which circumstances, apart from tax dodging, having an off-shore company (better?) “enable(s) a company to participate in current markets”.
I’d add a rider to this. I have heard that the fund was around UKP35m. This requires active management, i.e the regular monitoring of investments and the companies in which the money is invested. A board meeting, once per year in the BVI does not & cannot do this. Of course, if the test is “where does the board meet” – then Camoron-senior & co are in the clear. Thing is: I do not think that is the HMRC test. In which case, the fund was not managed off-shore – & can only have been manged from the UK. We are in “if it walks like a duck, talks like a duck and looks like a duck – it’s a duck” territory.
I see Camoron-junior is now talking about more regulation. The current ones are not applied (e.g. diff’ area – same principle: minmum wage legislation is not applied ‘cos local gov’ (the ones responsible) lack resources). The new legislation will lead to a box ticking exercise which the well resourced (tax dodgers) will side step. So far, so predictable, so pathetic – but that has been Cameron all the way through this saga.
“First Ian Cameron avoided tax, legally.”
I think what does get some but not enough attention is that the problem is exactly that it was and is legal.
Cameron as a legistlator could have changed the laws.
But then he couldnt because he was too deep in it himself.
Among the many things I don’t understand about all this is why, if it was necessary for Blairmore to be in the dollar zone, they chose to incorporate in Panama, at the time run by a violent and corrupt military regime, rather than, say, the British Virgin Islands or even the United States.
Also, since the company is now based in Dublin, when and why did it become unnecessary for them to be based in the dollar zone / Panama ?
The dollar story is, to be polite, utter BS
It is the exact opposite of the truth, I’d say
Thanks again Richard. I’m new to blogging and I follow just a handful of sites.
I assume the more links the better for your cause or am I wrong?
Here’s Mark Avery’s (writer, blogger and environmental campaigner). If you don’t like it you can of course delete.
There are some very good debates here with interesting ‘left field’ stuff….
http://markavery.info/blog/
I am a big fan of Mark’s work – especially on hen harriers
And his book on Martha was great
Most of us have never heard of, let alone considered, that a ‘bearer share’ could be legal but now that the public are being exposed to the concept … doesn’t it rather beg the question of how to track any politician’s involvement in offshore or personal conflicts of interest?
‘A bearer share is an equity security that is wholly owned by whoever holds the physical stock certificate. The issuing firm neither registers the owner of the stock, nor does it track transfers of ownership. The company disperses dividends to bearer shares when a physical coupon is presented to the firm.’
For example, a trusted politician’s relative could hold a shoe box/ bank safe full of Bearer shares to be returned, after the politician’s retirement … and even if somehow discovered, the bearer shares could not be linked to that politician. Or have I misunderstood the position?
Oh you cynic!
As if such a thing could ever happen…
As if
Good thing Cameron’s government made them illegal, then.
Wasn’t Al Capone finally arrested for his tax misdemeanours?
They should make a sister series to ‘The Wire’, starring accountants (even tired accountants). They could call it ‘The Balance Sheet’ or ‘Double Entry’… I’ll get my coat…
Richard, I wasn’t sure which of the various threads to post this in, but here seems as good a place as any.
I don’t know if you ever pay any attention to the Another Angry Voice blog by Thomas G Clark (his stuff is widely shared on social media), but a post he has just put up on Cameron and Blairmore – http://anotherangryvoice.blogspot.co.uk/2016/04/time-for-david-cameron-to-resign.html – has drawn the following lengthy comment from someone ‘in financial services’ who ‘administers offshore funds’:
(Begin Quote)
‘I will begin by making one thing absolutely clear. I am not a supporter of David Cameron. Far from it, I think he has led the most economically destructive Government since the Baldwin era. However, the accusations that are flying around at the moment are misleading and doing harm to a lot of innocent people who work in various islands around the world in the process.
I know the writer of this blog prizes evidence and reason above ideological posturing so I hope I will get a sympathetic audience here. I despise David Cameron for his dishonesty which is why, for me, it is of huge importance that when he is booted out of Number 10 it is done for honest reasons.
Suggesting David Cameron dodged tax by investing in Blairmore however is not an honest statement. Whilst I think there is a considerable possibility that Cameron does dodge tax using offshore vehicles – or did so in the past – Blairmore would be an entirely useless way to go about it. Indeed, the right wing media might even be stoking this story up to its collapse to make the public more sceptical and malleable when real evidence emerges.
So, who am I? I work in financial services, I administer offshore funds and none of my investors avoid any taxes. Fact. You simply cannot avoid taxes in an offshore fund, the only material difference with an onshore fund is how the tax is paid. In an onshore fund, a UK OEIC pays corporation tax and then any dividends paid to UK holders is ‘franked’ with a tax credit. In other words, a higher rate taxpayer in a UK Fund who should pay 32.5% dividend tax gets a tax credit of 10% and pays 22.5%. Also, on sale of their investment, they might pay capital gains tax.
In contrast, an offshore fund pays no corporation tax but also the investor gets no franked dividend either. In other words, they pay 32.5% tax on dividends and also, on sale of their investment, they might pay capital gains tax.
So, say both funds made £10k income for the investor. The UK OEIC would pay tax of £2k, the investor would get £8k and pay £1.8k income tax, net gain of £6.2k. In the offshore fund, they’d get £6.75k. Now, you might say, hang on, the offshore fund is better off. Well, it is until you take off the withholding taxes and additional administrative costs.
You might wonder why then offshore funds exist. Well, okay, I will concede there is some very dodgy stuff out there for private individuals who take advantage of the opaqueness to actually break the law by laundering money or evading tax. Labour are right when they call for transparency. Offshore staff – and I know a lot of them – genuinely do try and stop this activity to the best of their abilities. Most people who work on offshore funds in these havens aren’t rich themselves and hold exactly the same standards of morality as people onshore. They certainly don’t want to help a terrorist finance their next attack or a ruthless dictator to squirrel away his country’s wealth.
The main reason offshore funds exist is administrative and the increase in popularity is because of the single market. It’s easier to run one fund than one for every country your potential investors are in. And it’s easier from the fund manager’s perspective to not have to worry about administering tax, double taxation agreements etc. Put the fund in a 0% tax jurisdiction and leave tax reporting to your investors and you save hiring a tax accountant. National governments also like this too. If a UK investor just bought, say, shares in EDF they’d be taxed in France first and the double taxation agreement would mean the UK just gets the net of what is owed to the UK after the tax has been paid in France, which might be nothing. Using offshore funds, each national government gets their residents’ taxes in their own country.
So, in my view, Blairmore is a red herring. Offshore funds are a useless vehicle to avoid tax. What the Icelandic Prime Minister did is far more dodgy. Captive insurance is dodgy. Shell companies that make loans or hold intellectual property for onshore companies is dodgy. Transfer pricing is dodgy.
Don’t get caught up in funds and fall into a right wing trap to make you look foolish; look for the real, unquestionable wrong doing. Ian Cameron clearly hid his money in Jersey so start by looking there at how he did that.’
(End quote)
Do you have an opinion on the accuracy of this response to the AAV blog? Would it really be as ‘useless’ a method as claimed above? It appears from the first example he gives that less tax would be forthcoming in the UK through the offshore fund (though the withholding tax figure wasn’t stated), but the investor wouldn’t be any better off either when everything was tallied up.
To be clear, I fully support your principle that the right amount of tax should be paid at the right rate in the right place at the right time. Achieving that in a highly interconnected financial world is obviously tricky, but not impossible if the principle of being taxed where the actual economic activity takes place shapes policy, and tax havens are forced to share information fully or be blacklisted.
It certainly seems as if there is more to discover about Ian Cameron’s offshore dealings in Jersey and by extension if/how David Cameron has benefited from that. Whether that information will come to light, who knows?
Oh dear, another apologist
Blairmore is not a red herring
D Cameron’s holding is, a bit
But his endorsement of what his dad did is the issue
So this commentator wholly misses the point
Mark Nortfield
I’m not a tax expert but the commetns made sound plausible. I’ve certainly been told that an offshore roll-up fund doesn’t escape any tax, it just means you pay all the tax at the end. Of course, if you can arrange to be not UK Resident when the end arrives then you will escape tax.
I hadn’t heard about Ian Cameron’s Jersey interests but the commentator suggests they were extensive & seems to imply they were questionable. I think that IF it turns out that DC is a beneficiary of, or entitled to, funds in Jersey & those weren’t disclosed then it would be curtains for DC.
How one would find out, given Jersey’s record of secrecy, is another matter.
I did an MBA – & specialised in “applied deviousness” or as the lecturer insisted on calling it “international taxation”. Those were the days of “Belgian coordination centres” – giving money washing machines a bad name (the “action” later shifted to Luxy)
The comment by the tax “expert” – “The main reason offshore funds exist is administrative” is complete & total nonsense. There is one administrative reason for “off-shore fund” – dodge taxes if you can.
Look – can I be frank here – Godwins Law in my opinion is simply a denial of observed human behaviour – even history itself. It is one of those phenomena born of so-called ‘polite society’ who do not like to get their hands dirty talking about what really is going on around them. Such people usually want to talk about the value of their house, their conspicuous consumption and how it sets them apart from others and where they are holidaying this year. Fine – but don’t try to hobble those of us who think bigger, eh?
There are plenty of parallels between societies at different points in history.
For example we hear talk of the extinct population of Easter Island (and the apparent over-consumption of their natural resources that led to their society collapsing) as a comparator with our own unlimited thirst for resources today – resources which are getting more scarce and of course will produce consequences that will generate problems for the World at large in our age.
The Nazis are worth talking about today because essentially their vile behaviour and indifference to human suffering was due to idealism born out of a desire to rebirth the nation (do we not see echoes of the far-right even now in Europe after 2008?). Nazi idealism was seen in their racial pretensions (belonging to a mythical race of people) as well as thinking that they could take on the whole of Europe and more besides because they were superior mentally and technologically to everyone else.
Neo-libs like many of the Tories – some of whom like our Business Secretary think that a minor novelist called Ayn Rand provides some sort of philosophical framework for the good society – are also idealists whose ideas came about at a time of change and have caused suffering and economic injustice in equal amounts.
They believe in self-correcting markets (even now we know they fail – the nail in the coffin was 2008); the ‘unseen hand’ – which rather than being a collection of same-thinking people is actually consists of those already dominating and influencing the market; that anyone who is not doing well is the product of their own behaviour and not a result of an inefficient capitalist system and therefore should be left to fend for themselves; that the State and the public sector used to put its policies for its people to work is illegitimate and unnatural.
This same idealism produced financial derivatives – CDOs – that was thought would help spread the risk for the investor. What actually happened was that these instruments help to spread the collapse of the system much faster when trouble did brew in 2008.
History does repeat itself in lots of different ways. It does and it will continue to do so as long as there are human beings around to make it happen.
Because of Nazi idealism, millions of people died in WWII and made homeless in Europe (and let us not forget what happened in the Pacific too). It was a human catastrophe. For example recent research on the population of ethnic Germans in Europe after the war who had to return to Germany tell of anything between 3 to 11 million individuals who were forced out with millions of deaths as a result – mostly the elderly, children and of course women.
Because of Neo-lib idealism, millions of people have lost jobs, savings, livelihoods and a future GLOBALLY – not just Europe. Suicide is once again common because of despair.
The future for everyone is now much more uncertain – even the mega rich – who are potentially sitting on a powder keg of discontent created by their own blindness and idealism around accruing wealth are at risk.
And today’s Nazis’ in Europe and elsewhere are all waiting for their chance. There is always someone else to blame – it is human nature.
All of this because of idealism. Wanting to believe in dreams. Just like the Nazis.
Can you remember the documentary ‘The Nazi’s: A Warning from History’? Godwins Law negates that warning and therefore I heartily recommend that Godwin’s Law itself is consigned history.
There seems to be agreement that DC won’t have avoided tax, or at least not much, through this scheme. But as you say, Richard, if that’s the case then why go to the inconvenience and expense of engineering an offshore fund at all?
The FT’s description of the fund (perhaps rather generous?)
http://www.ft.com/cms/s/0/01f5b790-fd9f-11e5-b5f5-070dca6d0a0d.html#axzz45KFpm5DT
claims that a structure like this, going via Panama and the Bahamas was necessary for investors to avoid double taxation — really? Weren’t double-taxation agreements in place between virtually all major jurisdictions long before 1982? And it goes on to say that the initial opportunities for avoidance were eliminated 2 years after establishment, in 1984. In that case, why bother keeping the fund in the Bahamas with games played over engineering a non-UK dominated board for the next 28 years?! And why go to tax-light Ireland rather than fully repatriate to Britain when eventually relocating, if tax was not an issue?
It’s all very strange and feels like the whole story is still not being told. Were there secrecy advantages for the fund clients, that overrode the alleged lack of tax efficiency? No illegality is alleged, but the media coverage I’ve heard has been pretty woeful at disambiguating when slippery interviewees intentionally mix up the technical and informal meanings of “avoidance”.
I simply do not agree with the FT on this
I was intrigued by comments in this article in the Washington Post, for example:
“In recent years, Americans have been slowly running out of places to conceal their cash from the federal government, offshore experts say. In 2007, the veil of secrecy was shattered by a whistleblower named Bradley Birkenfeld, who disclosed that 19,000 U.S. citizens were hiding an estimated $20 billion in Swiss accounts held by the bank, UBS.
Through a federal whistleblower reward program, Birkenfeld received $104 million and UBS was fined $780 million in a tax-avoidance case brought by the U.S. Justice Department.”
Now I know the HMRC does now have a whistleblower programme, and I believe some people have even been awarded a few thousand pounds in the UK, but this is hardly going to provide the basis to tempt an honest lawyer, banker or accountant to risk their career prospects and do the decent thing.
The prospect of $104 million (or some other significant sum based on a percentage of proceeds recovered/fines incurred) would certainly get their attention though!!
Of course that also requires confidence in an HMRC who will actually follow up on the leaked data.
https://www.washingtonpost.com/investigations/for-us-tax-cheats-panama-papers-reveals-a-perilous-new-world/2016/04/08/a3467e9a-fd9f-11e5-886f-a037dba38301_story.html?hpid=hp_hp-top-table-main_offshore-4pm%3Ahomepage%2Fstory
My great fear is HMRC will do nothing at all
They will be sacking staff instead
Indeed Richard, it is most peculiar how a state that supposedly encourages whistle blowing suddenly turns very aggressively on whistle blowers who expose the activities of the state itself!
Double standards, hypocrisy, smoke and mirrors – or just plain state sponsored criminality?
http://www.theguardian.com/politics/2014/mar/24/hmrc-criticised-mps-terror-law-tax-whistleblower-hodge
Richard,
For what it’s worth, here are my thoughts on the Cameron saga.
Cameron says he sold these shares for £30k, and the media is repeatedly stating that this is ‘an awful lot of money’, but I don’t think it amounts to much for the likes of the Camerons. It may be more than the average wage, but people who revolve in their circles regularly spend such a sum on a foreign holiday.
When assessing the Camerons’ wealth, no mention is made of any property in Oxfordshire. But I thought they were part of the ‘Chipping Norton Set’ and counted Rebecca Brooks and Jeremy Clarkson as neighbours? Am I missing something?
Why didn’t Cameron make his hair shirt speech in front of HMRC staff instead of PWCs? He chose a sympathetic audience who were not going to speak up in front of their bosses (a common setup for Cameron speeches) and to a class of people complicit in the tax avoidance industry. I’m sure I’m not the only one who thought it made him look even more dodgy.
Remember the orchestrated furore over Ken Livingstone’s apparent tax avoidance? Well Cameron’s case is much worse and I can see any successor to the Tory leadership being similarly involved in offshore activities.
As is often the case with Cameron, I expect him to use this episode to do the exact opposite of what is required. He will make all the right noises about transparency but I reckon he will use it as an opportunity to strengthen the secrecy surrounding tax havens. The small print will include further safeguards of their sovereignty and harsh penalties for those responsible for data breaches in future.
It is odd that the house was omitted
But of course it does not go on the tax return and I guess that is why
I share some of your fears: it is entirely possible there could be a backlash