Wednesday, December 24, 2014

BitGold: The Digitalisation of Metal

Earlier this year I wrote about several attempts to back cryptocurrencies with Gold (The Truth About "Gold Backed" CryptoCurrencies). Most of those I covered weren't backed by Gold in the conventional sense (i.e. a fixed amount of Gold that could be redeemed per currency unit), instead offering only partial backing. There were exceptions such as Ripple Singapore which offers fully backed units on the Ripple network, but totals held are still very modest (not quite 53 ounces of Gold).

Since that article I've noticed new entrants being marketed in this space and interestingly two competing products appear to be jostling for the same name, BitGold.

The first of those to market comes from Bitreserve, a company offering a digital wallet service where you can transfer between Bitcoin, various currencies (USD, EUR, CNY, YEN, GBP) and now Gold (stored and audited by GBI) all through their 'card' system. Think of it like having accounts in various currencies, you can only deposit funds into their system using Bitcoin, but once deposited you can diversify that value across any of the aforementioned currencies if you don't want exposure to Bitcoin's fluctuating value. Bitreserve maintains real reserves to cover their obligations to customers which are published live on a status page.
With our Gold Card, we are reviving gold for the purchase of goods and services. Bitreserve members can convert their bitcoin to bitgold, whose value is substantiated by bullion in our reserve, but still spend it as bitcoin. By creating a bridge between the revolutionary Bitcoin protocol and good old gold bullion, we enable our members to instantly send or spend bitcoin from the ounces of gold held in their Bitreserve wallet. Our Gold Card makes this ancient store of value instantly transferable, infinitely divisible and accessible to anyone with a networked device. Now anybody with some bitcoin and a Bitreserve wallet can have the Midas touch. Old King Croesus would be chuffed. Bitreserve
They're also introducing a similarly structured card that offers their customers exposure to the oil price.
For the first time in history, oil will become a form of payment and compete against all major global fiat currencies. Using Bitreserve’s Oil Card, anyone can hold their value as oil — the fuel for the modern world economy — and transfer that value instantly and for free.

Bitoil™ will work just as bitgold does today. Oil value can instantly be converted into five currencies, gold, or bitcoin at very low cost and can be spent immediately. Oil has a massive and direct impact on the global economy, and a currency that tracks oil prices could become one of the world’s most widely used digital currencies. Whether you are a consumer looking to hold money that’s tied to gas prices, or a business with a large portion of your expenses in oil related activities, Bitreserve’s Oil Card gives you yet another welcome currency option for holding and spending digital value. Bitreserve
To be honest their system sounds quite innovative, but I am still skeptical about attempts to digitise physical assets as I will explain shortly.

The second "BitGold", is being launched early next year. The site is taking email addresses for pre-launch access at BitGold.com and they've raised C$3.5 million from investors. The founders are Roy Sebag (CEO of Natural Resource Holdings Ltd) and Josh Crumb (Former Senior Metals Analyst at Goldman Sachs).
"The Toronto-based company will allow account holders to purchase bitcoins and exchange them for gold redeemable in various vaults around the world, as well as convert the metal back into the digital currency. Customers will also get a debit card, said Sebag, 29.

The company is trying to muscle in on traditional bullion dealers and gold-backed exchange-traded funds, two of the most popular ways for retail investors to get hold of physical gold." Bloomberg
Interestingly the name that both of these new products are launching with, Bit Gold, has already been used by Nick Szabo to describe what could be considered the inspiration for Bitcoin. 
The Bit Gold proposal, by Nick Szabo, describes a system for the decentralized creation of unforgeable chains of proofs of work, with each one being attributed to its discoverer's public key, using timestamps and digital signatures. It is said that these proofs of work would have value because they would be scarce, difficult to produce, and securely stored and transferred. Bitcoin.it
His early proposal was so closely worded to the way Bitcoin works that many speculated Nick may in fact be Satoshi Nakamoto (or form part of a team that wrote the Bitcoin whitepaper).

Even ignoring the naming issue, I'm still not convinced that trying to link physical Gold with a digital representation is a good idea and here are some reasons why...

Counterparty Risk: As I said in a recent post (How Safe Are Unallocated Bullion Accounts?), I own precious metals because they have a lower level of counterparty risk, putting other parties between myself and a claim on the physical metal is counterproductive to one of the reasons I hold them. Some of these products are structured so that your claim is with the company providing the digital wallet service, while the actual custodian of the Gold may be another layer or two down. Even if regular audits occur, I would not be comfortable that my Gold would be easily retrievable if something were to go wrong (and not all are offering the ability for redemption of the Gold).

Trusted Third Party: One of the key attributes of Bitcoin and many other cryptocurrencies is the lack of need for a trusted third party to confirm the transfer of units. Transactions occur on a shared public ledger (called the block chain). With no physical asset to account for this can all occur through the use of private keys to sign transactions. The benefit of this is lower transaction costs. Introducing a physical asset to the mix means that you do need a trusted third party (sometimes multiple) to verify the assets, even if a public ledger is still used for transparency of transactions.

Spending Gold: Around 12 months ago I stumbled across a comment from Pierre Rochard talking about the consumer behaviour of those spending Bitcoin, he claimed "Consumers making payments generally replenish their bitcoin balance simultaneously, so it's a net zero." My response, why not just hold their Bitcoin balance steady and use fiat currency to make the purchase? Those introducing these digital Gold products assume there's lots of people out there who want an easier solution for 'spending' their Gold. My Gold holdings are not held for the purpose of short term spending on groceries or electrical goods, I'm not interested in giving up the security of possession for the ability to spend it more easily.

Capital Gains Tax: As I have covered on this site before, Gold (Let Australians Save in Gold Instead of Debt) and cryptocurrencies (Glenn Stevens Talks Bitcoin & Competing Currencies) are not really setup from a tax perspective to facilitate their use as a regular currency (despite the ATO recently giving a break to those using Bitcoins). It's likely that in most situations those using these digital wallet services are expected to keep records of any capital gains or losses (relative to their Australian Dollar value) to tally at the end of year for the purpose of declaring a loss or gain. The Australian tax system is not setup to cater for the use of assets (other than the Australian Dollar) as money and I suspect it would be similar in many other countries. We don't have competing currencies despite Glenn Stevens (Governor of the Reserve Bank of Australia) insistence that we do.

Government Regulation: The idea behind most cryptocurrencies is to have a distributed electronic method of creating and transferring value with no need to be in a specific physical location. Adding Gold to the mix literally destroys the advantages of a cryptocurrency because the asset it's linked to is stored centrally, leaving it vulnerable to the negative effects of government regulation.

One advocate for the mixing of these two assets has been Jan Skoyles, CEO at The Real Asset Company, whose opinion was recently covered by a Forbes contributor:
Jan’s argument therefore that there is demand for both a gold-backed currency, and a fully-transparent and accessible gold-trading system, is a persuasive one. By recording gold purchases on a block chain style ledger, the currency can be used not only as a medium of exchange, but also to facilitate gold ownership, and challenge the status quo for clearing and settlement in the gold market. In other words, you can buy your gold, and you can spend it too.
The article goes on to say that The Real Asset Company has their own product in the works. I tried to reach Jan (by email and Twitter) to confirm that's still the case and get some clarification on how it would work, but I'm yet to hear back (will update this post if I do). I'd think most Gold investors would prefer a level of privacy for their 'digital stack', something a public ledger wouldn't easily accommodate.

Everyone has different wants and needs from their assets, especially those used as a monetary resource, so perhaps there are some individuals who are prepared to look past the described shortcomings of a digitalised Gold product for the flexibility and convenience that it offers. If you are one of those people I'd love to hear your reasoning in the comments below.

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Thursday, December 18, 2014

Reserve Bank of Australia Audits Our Gold Reserves

Gold Bars Stored at the Bank of England
Two years ago the news was publicly broken on this site that 99.9% of Australia's Gold reserves are stored by the Bank of England in the United Kingdom. Attempts by another blogger, interested in the whereabouts of Australia's Gold, had been rejected by the RBA only several months earlier, "The Bank does not publish the location of its gold reserves."

Decisions like this don't happen in a black hole. Something changed the RBA's mind, between August 2012 and December 2012, on making the location of Australia's Gold reserves public.

From my observation, the RBA tends to follow the lead of other Central Banks, so the decision to release information on the location of Australia's Gold may have been a result of Germany's Central Bank (Deutsche Bundesbank) deciding to do so in October 2012 (interview containing the information originally released is no longer published on the site, but available via Web Archive). Only a month later, in November 2012, the Austrian Central Bank released the location of their Gold reserves, revealing that 80% resided in the UK, 3% in Switzerland and 17% in Austria. Cue the RBA feeling comfortable to release the location details of Australia's Gold around 1 month later.

A recent experience of mine with the RBA further highlighted their desire to follow in the footsteps of other Central Banks rather than to think for themselves. An FOI request I made for the Gold bar list was initially rejected, but after lodging an appeal with the OAIC, highlighting that the United States published a list of their Gold bars details (sans the serial number), the RBA decided to follow suit (Reserve Bank of Australia Releases Gold Bar Details).

Earlier this year I spotted a line in the RBA's annual report indicating an audit had been performed (not something I have seen mentioned in previous years):


A question posed by email to the RBA earlier in the year suggested that RBA officials had performed the audit themselves.

I decided to lodge another FOI request.
"I request that a copy of the following documents be provided to me: All documents pertaining to the audit of the RBA's gold holdings performed during the 2013/14 financial year, as was specified in the 'Operations in Financial Markets' section of the Reserve Bank of Australia Annual Report 2014 ("During the year in review, the Bank audited its gold holdings")."
Two months later (decision on the documents was delayed due to consultation with the Bank of England) I received the following list of documents that would be provided (on payment of fees, which were reduced from an original quote due to the small number of documents that could be released):


And today the documents arrived. Here's what we know...

In February 2013, the Assistant Governor (Financial Markets) requested Audit Department include in its audit program a review of the Bank’s gold holdings at the Bank of England (BoE). The Chief Representative in EU approached the BoE to facilitate this review and in late May 2013 initial planning discussions were held with BoE staff with tentative agreement that the review would take place in September 2013.

The audit included:
  • An on-site physical verification commencing 23 September 2013, which will take 4-5 days to complete, assuming two RBA auditors are involved given the proposed scope.
  • Inspecting a sample of RBA Gold bars (list to be provided in advance), including checking the details of these bars against the Bank’s inventory list and weighing of the bars by BoE staff using their equipment.
  • Randomly selecting additional Gold bars from the inventory list and observing these bars being located and retrieved from their vault (plus verifying the details and weighing them).
  • Obtain a high level understanding of the BoE gold safe custody service.
  • Continuing discussions for a comprehensive safe custody agreement between the RBA and BoE.
As the above document list shows, those relating to final audit results were not provided. I would assume the audit was successful, but no doubt that would be a highly contested opinion in the Gold blogosphere. The following reason was provided for denying access to the report:
Documents 10, 11 and 12 are drafts of the report prepared by the RBA’s Audit Department detailing the findings of the audit and document 13 is the final of that report.

Denial of access to these four documents in terms of s33(a)(iii) is appropriate because release of the information (which relates to procedures for the conduct of the audit with the BoE and the subsequent results) ‘would, or could reasonably be expected to, cause damage to’ the relationship between the RBA and the BoE.  This belief is soundly held by us on the basis that we are aware that the BoE provides safe custody services not only to the RBA, but also to other central banks around the world.  Disclosure of the information in these documents could damage the relationship between the BoE and its other central bank clients, and by extension (as the source of the information), the relationship between the BoE and RBA.  As foreshadowed to you in earlier correspondence, we consulted with the BoE in relation to these documents and they affirmed the views we held regarding the damage that would be done to the relationship between the BoE and RBA if the redacted information were disclosed.

Denial of access to these four documents is also appropriate in terms of s47E(a) (‘disclosure would, or could be reasonably expected to, prejudice the effectiveness of procedures or methods for the conduct of tests, examinations or audits’ by the Bank) and (b) (‘disclosure would, or could be reasonably expected to, prejudice the attainment of the objects of particular tests, examinations or audits conducted, or to be conducted’, by the Bank).  The documents in question concern the ‘procedures and methods’ within both the RBA and the BoE regarding the conduct of the physical check of a sample of gold bars (for the purpose of conducting the audit).  Disclosure of this information would, of course, reveal those procedures and methods, and by logical extension render them less effective. Also, the ability of the Bank to attain the objects of the audit (which is to reveal whether the Bank’s arrangements are robust and secure) would be prejudiced. These considerations apply to both the audit currently the subject of your FOI request and also any other audits undertaken by the RBA. A key requirement for undertaking a successful audit (of any aspect of the RBA’s work) is that there is as little opportunity as possible for individuals to take steps to predict what an auditor may choose to focus on, and/or how they will conduct the audit. It is self-evident that if such procedures and methods are revealed, then the opportunity to circumvent them is greatly increased.  As s47E is a public interest conditional exemption, I must take into account whether the giving of access is in the general public interest (in terms of s11A(5)).  When deciding whether access is in the public interest, I must take into account the following from s11B(3) and have noted my views in each case:

Section 11B(3) factors favouring access to the document in the public interest include whether access to the document would do any of the following:

(a) promote the objects of this Act (including all the matters set out in sections 3 and 3A); release would be contrary to some sections, particularly sections 2(a) and 3(3)

(b) inform debate on a matter of public importance; the Bank’s gold holdings, while important and of interest to some, are not a matter of public importance generating any level of debate

(c) promote effective oversight of public expenditure; release of the information would not do this

(d) allow a person to access his or her own personal information; the request is not seeking personal information.

Taking into account these factors, and the implications release of the information would have on the Bank’s audit processes, I have decided that it is clearly not in the public interest to disclose the information in these four documents (10, 11, 12 and 13).  Disclosure of these documents would manifestly harm the public interest by way of reducing the ability of the RBA to successfully conduct audits and tests of its operations going forward.
The released documents (mostly a chain of various emails) also suggested the RBA have been invited back for another review in 12 months.

One interesting point from the documents, the Bank of England was emailing clients in June 2013 (those for whom they're providing custodial services) inviting them to audit samples of their Gold:

Click Above Text To Enlarge
However discussions on the RBA audit were already well advanced at that time.

Given that the RBA has followed the lead of other countries to release reserve location details, perform audits and release (some) bar list details, it will be interesting to see whether they go further and follow the lead of the many countries now deciding to repatriate some or all of their Gold reserves...


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Monday, December 8, 2014

Attention Traders: The Value Of Cash Is Not Absolute

Over the last few years, as the price of Gold declined, several professional traders and financial commentators have taken it upon themselves to unleash their wisdom about the metal being "just a trade". They've decided that everyone should see the financial world through their narrow lens and have used it's declining price as "proof" you should always have a stop and be prepared to exit your position.

The way I've framed the above might suggest I have a problem with their view. In fact I don't, it's one way of looking at the assets in your investment portfolio. However, to take their view you also have to give thought to ALL positions and that includes cash, which should also be considered a trade as it's value can change.

Earlier this year I wrote about Ritholtz's position on gold bugs ('Barry Ritholtz Mischaracterizes Gold Bugs'), one of the rules in his article was:
The Danger of One-Way Trades: What would make you reverse your biggest present holding? What facts or situations would force you to change your views and sell? If your answer to that question is, “Nothing,” you have a huge, devastating flaw in your approach to investing.
I hear traders talking day in and out about 'going back to cash' or 'sitting in cash' after exiting all positions, but if a trader was to think about what they are doing logically, as they would any other position, they are simply moving from one asset which fluctuates in value to another.

What facts or situations would force a trader to consider a position in cash being unsafe? Answer that and you might be on the path to understanding the reasons that some investors choose to hold physical Gold.

A reader of my Ritholtz article commented: "Ritholtz essentially supports his analysis by treating fiat currencies as a bedrock, i.e. asset changes are all relative to this unchanging fiat value." I agreed: "Ritholtz claims to be ‘asset class agnostic’, but then measures the performance of other assets back to fiat which doesn’t have static value."

Newsflash: Cash / fiat currency is not a neutral position.

There is no asset which remains absolute in it's price or value relative to everything else (and yes that includes cash or Gold).

I tried to explain this briefly to one trader (Mark Dow) who regularly has a crack at gold bugs on Twitter, to my amusement he suggested that you don't have to hedge against fiat currency because it's "legal tender".

Click Image to Enlarge
How could anyone think that a currency being legal tender protects the holder from changes in it's value?

Sure it's a unit of account and may remain a constant relative to some assets, for example a $10,000 loan will always require $10,000 in cash (+ interest) in order to repay it, but the value of currencies can be affected in various ways, sometimes to devastating effect.

So how does one hedge or insure themselves against fiat currency and the financial system?

This question reminds me of a discussion that took place in the comments on Cullen Roche's site (comments since disabled, but they were here) a couple of months back when he suggested that those wishing to hedge against the financial system should take a short position on the finance sector. 

Imagine taking out insurance against your house burning down and then leaving the only paper work you could use to make a claim inside the very same house.

That is basically what Cullen proposed. Some of the sensible responses below his suggestion included:
“Gold like cash is a unique hedge because unlike options, or bonds or financial hedges it has infinite duration.”

“I have an allocation to gold and silver because its the only way that I can be 100% sure that my “insurance” isn’t someone else’s liability.”
Precious metals are unique in the sense that they are one of few assets which can be held physically outside of the financial system & can't be diluted in the same way as fiat currencies.

Some traders might argue that significant changes in the value of cash occur so infrequently that it's not worth worrying about (tell that to someone living in Russia, Japan, Cyprus, North Korea, Venezuela), but that's exactly the mindset that some of these traders criticise others for, that is, having a baked on view that holding an asset poses no risk. 

Holding a 100% position in any asset is risky, whether that's cash, Gold, Silver, property or anything else. Diversify or be prepared to wear the consequences if the value of that position moves against you.


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Friday, September 26, 2014

Why Serviceability ≠ Affordability (Australian Property)

Still today I see many commentators using the terms serviceability and affordability interchangeably in relation to Australian property. The most recent occasion I noticed was in a post from David Bassanese a week ago where he wrote:
A better measure of house price valuations – which at least allows for the structural change in interest rates over time, though not financial deregulation – is mortgage affordability.  As seen in the chart below, there has been no obvious structural worsening in mortgage affordability over recent decades. Assuming a 20% deposit, loan repayments to purchase the median-priced Australian house have averaged just over 30 per cent of average household disposable income since at least the mid-1980s.
And posted the following chart to support his assertion:
 
 
It shows that initial loan repayments on a median-priced house have remained fairly stable over time (as a percentage of household disposable income). The chart and commentary suggests that "affordability" was the same in the early 1990s as it is today (we have higher prices relative to income, but interest rates are lower), let's compare an example using figures between the two periods to see if affordability really is the same.
 
Based on Bassanese's house price to income ratio:
 

The ratio was around 3.5x in 1992 and 5.5x today. Keep in mind that other commentators who calculate these ratios use different methods, so while the ratio might change around a bit, the change between historical ratios and those today should be similar in a single set/series of numbers. Let's do the sums.
 
With a household on $100k. They save their deposit at a rate of 20% gross income and repay the loan at a fixed amount of $3,500 per month (using this mortgage calculator & interest rates from here to get my numbers below).
 
1992 Numbers: $350,000 purchase price (3.5x income)
Deposit (20%): $70,000. 3.5 years to save.
Interest rate: 11%
Loan amount: $280,000
Repayment: Loan is repaid in 12 years, 1 months. Total paid, $506,980.
 
2014 Numbers: $550,000 purchase price (5.5x income)
Deposit (20%): $110,000. 5.5 years to save.
Interest rate: 5.5%
Loan amount: $440,000
Repayment: Loan is repaid in 15 years, 8 months. Total paid, $657,061.
 
So even if interest rates had remained elevated the entire period of the loan, it still ends up more affordable over the long run to have double the interest rate, but lower price to income ratio. Not only that but it would be faster to save the deposit given that it's a lower amount (relative to income) and I haven't taken into account the higher interest rate on saving for the deposit which would have benefited the 1992 scenario. Costs such as stamp duty which are tied to the price paid would be lower too. Finally, higher interest rates tend to come with a higher rate of inflation, so the real value of the debt would be reduced faster as wages increased, meaning the buyer in 1992 would have found it easier to ramp up the level of repayment.
 
As I have mentioned in the past on housing affordability, I prefer the following basis as a definition for affordability:
 
"Afford: To manage or bear without disadvantage or risk to oneself."

It's clear that although initial loan serviceability might be similar with lower rates and higher prices, the buyer is also at a clear disadvantage over the term of the loan.
 
When considering affordability we need to take a holistic approach and not use a simple snapshot of a single repayment as the basis to make judgement calls on whether house prices or a mortgage used to purchase them is affordable. A mortgage is a long term commitment and shouldn't be treated so trivially by market commentators.

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Wednesday, August 20, 2014

Bitcoin Gets Capital Gains Tax Break, Why Not Gold?

Late last year ('Glenn Stevens Talks Bitcoin & Competing Currencies') I pointed out that Bitcoin effectively can't be used as a competing currency (likewise for foreign currency or other assets such as Gold) given that it is subject to Capital Gains Tax (CGT) and monitoring the value of Bitcoins as they are acquired and disposed of would not be practical:
"Can you just imagine the administrative nightmare that would result from performing regular transactions in a foreign currency and having to maintain a record of whether you made a gain or loss as a result of fluctuation in the currency markets? It is simply not practical. Bitcoin is not immune from the same requirements." - Bullion Baron
However, earlier today the Australian Tax Office (ATO) released a statement (ATO delivers guidance on Bitcoin) in regards to Bitcoins and their tax treatment. Further information is available on the following page 'Tax treatment of crypto-currencies in Australia – specifically bitcoin' which specifies the following in regards to Bitcoins used in personal transactions:
Using Bitcoin to pay for personal transactions
Generally, there will be no income tax or GST implications if you are not in business or carrying on an enterprise and you simply pay for goods or services in bitcoin (for example, acquiring personal goods or services on the internet using Bitcoin). Where you use bitcoin to purchase goods or services for personal use or consumption, any capital gain or loss from disposal of the bitcoin will be disregarded (as a personal use asset) provided the cost of the bitcoin is $10,000 or less.
The 'personal use asset' exemption would normally be reserved for items such as a boat, furniture, electrical goods or other household items which are exempt from CGT if purchased for less than $10,000.

The wording on the ATO website is somewhat ambiguous. Does the limit apply per year or can I buy low (to a maximum of $10,000 worth of Bitcoin) and spend high several times in the same financial year and still avoid CGT?

I think this is a good start and would like to see a similar CGT exemption for Gold (as I suggested last year in 'Let Australians Save in Gold Instead of Debt'). That said, I think the limit imposed is patronizing, why impose a limit at all if the Bitcoins are being purchased with the intention of spending them at a later time? Putting a $10,000 cap on the exemption limits the spending of Bitcoins to novelty use only, it wouldn't be adequate for someone having their income paid in Bitcoins, which was also covered on the site:
Paying salary or wages in bitcoins

Where an employee has a valid salary sacrifice arrangement with their employer to receive bitcoins as remuneration instead of Australian dollars, the payment of the bitcoins is a fringe benefit and the employer is subject to the provisions of the Fringe Benefits Tax Assessment Act.

In the absence of a valid salary sacrifice agreement, the remuneration is treated as normal salary or wages and the employer will need to meet their pay as you go obligations as usual.
I would like to see any monetary asset (Bitcoin, Gold or otherwise) that is saved for future consumption be exempt of Capital Gains Tax. That would allow us to truly have competing currencies in Australia. Being forced to save in a currency whose value is purposefully devalued (via central bank mandate to target 2-3% annual inflation) is madness, especially when interest earned on those savings is taxed and with the real cash rate already below 0.


Those who have purchased and sold Bitcoin specifically for investment are subject to CGT (or taxed as part of your income if traded in the business of regular profit-making):
Disposing of bitcoin acquired for investment

If you have acquired bitcoin as an investment, but are not carrying on a business of bitcoin investment, you will not be assessed on any profits resulting from the sale or be allowed any deductions for any losses made (however, capital gains tax could apply – although see the comments above about personal transactions). However, if your transactions amount to a profit-making undertaking or plan then the profits on disposal of the bitcoin will be assessable income.

There are no GST consequences where the bitcoin is not supplied or acquired in the course or furtherance of an enterprise you are carrying on.
There is another section for those in the business of mining Bitcoins:
Mining Bitcoin

Where you are in the business of mining bitcoin, any income that you derive from the transfer of the mined bitcoin to a third party would be included in your assessable income. Any expenses incurred in respect to the mining activity would be allowed as a deduction. Losses you make from the mining activity may also be subject to the non-commercial loss provisions.

Your bitcoin is trading stock and you are required to bring to account any bitcoin on hand at the end of each income year.

GST is payable on the supply of bitcoin made in the course or furtherance of your bitcoin mining enterprise. Input tax credits may be available for acquisitions made in carrying on your bitcoin mining enterprise.
The section that deals with ATMs and exchanges is probably the most off putting with an indication that businesses in this area will need to charge Goods and Services Tax (GST), likewise in the supply via mining as mentioned above:
Taxpayers conducting a bitcoin exchange (including bitcoin ATMs)

Where you are carrying on a business of buying and selling bitcoin as an exchange service, the proceeds you derive from the sale of bitcoin are included in assessable income. Any expenses incurred in respect to the exchange service, including the acquisition of bitcoin for sale, are allowed as a deduction. In these circumstances, the bitcoin is trading stock and you are required to bring to account any bitcoin on hand at the end of each income year.

GST is payable on a supply of bitcoin by you in the course or furtherance of your exchange service enterprise. Input tax credits are available for bitcoin acquired if the supply of bitcoin to you is a taxable supply.
This seems to put local Bitcoin exchange and supply businesses at a competitive disadvantage if they have to charge buyers a 10% premium. It would be likely to drive Australian Bitcoin buyers to international sources which don't charge GST.

It is good to see that the ATO has finally addressed Bitcoins for tax purposes, but I don't think they've done a particularly good job here.


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Monday, August 4, 2014

Replica vs Real: 1oz Gold PAMP Bar Comparison

It was bought to my attention that there are fake Gold bars being sold on ebay that replicate popular investment grade 1oz Gold bars. On this occasion they were being advertised as pure bars in the title, but if you read the full description it did state they are only layered in pure Gold. Having some real PAMP 1oz Bars myself I decided to buy one of the replicas to provide a comparison for others (and it arrived late last week). 

I have written about fake Gold and Silver products in the past, you can read my previous posts at these links:

Warning: Fake/Counterfeit Silver & Gold

Counterfeit Silver Lunar Dragons - Don't Get Stung!

Fake/Counterfeit Silver Lunar Coins on eBay, BEWARE! (Perth Mint Replicas)

The ebay auction from which I purchased my fake bar was titled “1 Oz Switzerland Pamp Suisse PURE 24K .999 1oz Gold Bullion Coin Bar Ingot”. The full description was as follows:
VERY RARE AND VERY LIMITED CAST

Brand new "1oz Switzerland Pamp Suisse bar " This bar is not solid gold.  It is clad/layered in pure fine 100Mills of 24k gold. This is a high quality item beautifully designed and manufactured to very high standard by master craftsmen in a small family owned mint in Australia.

Weight 1 ounce. 30 grams.

DONT MISS YOUR CHANCE TO OWN THIS BEAUTIFUL PIECE . A GREAT GIFT OR ADDITION TO YOUR OWN COLLECTION.

Beautifully designed and this Gold Bullion bar will be delivered to you in a free protective airtight capsule.
The title and parts of the description appear intentionally worded to try and deceive unwary buyers into mistaking it for a pure Gold bar from PAMP Suisse, even if it did also mention that it’s not solid and clad/layered. This reminds me of the old ‘console box’ scam where a seller advertises the box of a new console, stating as such, but obviously intending for buyers to bid thinking it’s the whole system. 

The seller of the fake Gold bar also suggested in the description that it was manufactured in Australia, when it’s clearly just a Chinese knockoff, likely to have been purchased from Alibaba (China's biggest online commerce company, which will be floated on the stock market later this year). Further to the misleading wording, the auction also had 3 images, the first two images depicted a real PAMP Suisse 1oz Gold Bar, with the final image showing one of the fake bars the buyer will actually receive.

Below is a photo comparison of the fake bar I received and a real bar, can you tell which is which before enlarging to view the detail and labels? See the top right corner of each image for the answer (click each image to enlarge):


Without the cropping it becomes a lot more obvious which is the fake, see below for a size comparison (click the image to enlarge):


Some obvious design differences include:

- No border around 'PAMP Suisse' logo on real bar
- Missing 'TROY' in text on fake bar (and wording order differs)
- Missing serial number on fake bar
- Corners are more rounded on real bar
- Detail on 'Lady Fortuna' design more intricate on real bar
- Real bar has a stronger yellow hue under the same lighting

Here are some specifications showing the weight and size difference between the fake and real PAMP Suisse bar…

Weight of fake bar (in plastic): 39.80g
Weight of real bar (in plastic): 36.28g

Weight of fake bar (out of plastic): 31.49g
Weight of real bar (per official specifications): 31.10g

Measurements of fake bar: 50 x 28 x 3 (mm)
Measurements of real bar (per official specifications): 41 x 24 x 1.70 (mm)

In this case it was relatively easy to differentiate the fake from the real bar, but keep in mind a copy like this can be purchased in bulk for less than US$1 per piece. There’s nothing to say that better quality fakes (including replication of the official packaging) might be out there. If they can produce this for less than a dollar, then imagine the quality of fake they could produce for $10.

By the way, if you were wondering about the red spots on the real bar, they are a common occurrence even on pure Gold bars and coins (via Lynn Coins):

Gold coins (and even pure gold bars) can sometimes develop brown (rust colored spots) on them. Yes, a gold plated item (when the gold plating wears off) would expose the non-gold metal underneath and that exposed metal could tarnish or rust. However, a brown or reddish spot on gold doesn't mean the item is not real solid gold. Here's why:

Rust spots or brown spots can occur on genuine gold coins when a very faint trace of other metal adheres to the surface of the coin or bar. As the other metal is exposed to oxygen or other materials in the surrounding air (can even be the air that is in the holder) it causes that trace metal to change color.

Often the a faint amount of trace metal or other material will get on the dies prior to the  striking of the coin or bar. When the coin is struck the molecules of the other metal (or impurities) are then fixed into the coin.  They may be so thin or dispersed that they are not obvious to the naked eye. Other times such impurities may come in contact with the coin blank before striking it into a coin. This surface discoloration can occur on gold coins and gold bars.
Be vigilant when buying precious metals, there’s likely to be more unscrupulous sellers than those who try to mislead, but confirm in the detail that they are selling a layered product. Some may even market a listing with description and images of real bars, but then send fake products while hoping the buyer doesn’t realise they are being swindled.

Some of the ways you can protect yourself when buying precious metals:

  • Buy from bullion dealers who source their product through official channels (I can recommend site sponsor Bullion Money for an Australian company and have also had good dealings with Gold Stackers, Bullion List, Perth Bullion, Perth Mint, City Gold Bullion, Ainslie Bullion Company and Bullion Mark, amongst others).
  • If the bullion dealer you are buying from sells buy-backs (second-hand), ensure they have equipment to test what they’re selling to you (e.g. XRF machine).
  • Limit the size of any single order with an individual or dealer to an amount you’d be prepared to lose if the deal goes sour.
  • When buying from ebay, pay with PayPal to ensure you are protected (this doesn’t cost the buyer any extra if purchasing through ebay).
  • If you are unsure about a the legitimacy of a product you’ve purchased, see if there is a local bullion dealer with an XRF machine who can test it for you.
Another way to test whether the product you have is pure Gold is to perform a specific gravity test.

Bullion manufacturers have been innovating in this space, but those replicating their products never seem to be far behind in copying their features. Take every precaution you can when turning your hard earned fiat into hard assets.


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Thursday, July 31, 2014

How Safe Are Unallocated Bullion Accounts?

Imagine you owned a small business. It’s a retail store and you sell a physical product which lines the shelves. You need to keep a variety of different products to ensure that customers who enter your store have plenty of choice. Not only do you have to stock a range of goods, but you have to keep a lot of each on hand as customers often purchase in bulk, due to fluctuating prices (they may buy large quantities when they believe it is well priced). As the store owner you have to hedge your exposure to the fluctuating price of the product you keep on hand to reduce the chance of getting caught on the wrong side of a price swing, this adds further complexity to managing your inventory.

The products you sell are expensive, this is no $2 store where your entire inventory only totals a few thousand dollars, almost all of your products cost over $20 each and up to $44,000 or more, remembering that you have to keep multiple of each in stock for those customers who want to purchase in bulk. The worst of it is you can only charge a small mark-up on the products (over cost price), otherwise your customers will go elsewhere. Obviously the capital you need for running this store will be substantial. Likely to be in the millions of dollars.

Now imagine there was a way to offer such a wide selection of expensive products, but have your customers fund the capital costs to do so… sounds too good to be true?! They will essentially pre-purchase your stock (allowing them to lock in the price they want), which provides substantial capital for putting product on your shelves. The customer can come in and use their store credit to make a purchase from your product range and take delivery at a time of their choosing. All you have to do as the store owner is promise your customers that you won’t take more funds from them than you have product on your shelves.

…you’ve probably worked out by now that I’m talking about the challenges faced by a bullion dealer. I have a lot of respect for those in the industry, it’s a cut-throat business with small margins and high volumes, lots of regulations to abide by and is littered with risks. However, as a consumer of their services, I have to think about the safety of my own capital first.

The solution I talk about above, where the customer can provide capital for stocking a larger product range, is unallocated bullion accounts. Unallocated accounts have become a popular offering from bullion dealers in Australia over the last few years, I suspect this is partially a result of an increase in the number of bullion dealers trading and also boosted by the closure of new funds to Perth Mint’s Unallocated Silver Accounts (as of March 2011, Unallocated Gold remains open at this time). The advance in functionality of bullion dealers online stores means the process to buy unallocated metal today is very easy, sign up an account, hit the buy button and transfer the money to the dealers bank account.

There are some benefits for a customer purchasing unallocated metal (as opposed to taking delivery of physical). There’s generally no cost charged for storage, the premium (over spot) charged will be lower allowing exposure to a larger number of ounces (e.g. $5000 buys 192 1 ounce silver coins at $26/oz, but buys 208 ounces of unallocated Silver at $24/oz), you don’t have to pay for delivery and it’s easier to trade (for example a dealer may offer Gold:Silver Ratio swaps or to buy it back at the click of a button). I have used unallocated accounts from two Australian bullion dealers in the past and may do so in the future, but I manage the risk by limiting my exposure to an amount I'd feel comfortable losing (the same amount that I'd risk placing any single order with a dealer).

This brings me to the problem I have with unallocated accounts. One of the reasons I own precious metals is that they have a lower level of counter-party risk compared with traditional assets such as shares. Buying precious metals in unallocated form potentially exposes the client to the solvency of the company offering the service, which is counterproductive to the reasons I hold precious metals.


The ownership (title) of the bullion in an unallocated account is a grey area and will likely differ depending on the specific setup for each dealer. I've had it explained that some bullion dealers in Australia have structured their unallocated products so that the client retains ownership of the metal in the event of bankruptcy, but I'm not an accountant or lawyer, so even if I was shown 'proof' of these claims I'd not trust myself to be confident that was definitely the case. I haven't seen any bullion dealer with a Product Disclosure Statement on their website outlining the offer, ownership structure, how the metal is treated and risks, most of them provide little more than a few sentences describing their unallocated products.

After reading the above you may be wondering how likely is the collapse of a well established bullion dealer offering an unallocated product?

It's not something that has occurred very often, the last recorded instance that I've been made aware of was back in 1996 with the collapse of "Perth Bullion Exchange" (of Sydney, not to be confused with any current trading entities with similar names). This particular case was highlighted in a Sunday Mail article where a couple had written to "The Fixer". They had purchased 20 bars of silver bullion totaling $12,900 (in 1993-1994) for which they had certificates showing ownership and when they went to redeem their metal in 1998 the business had vanished. The Fixer managed to track down the bankruptcy proceedings and the couple supposedly got around half their money back following the sale of the companies assets:

Perth Bullion Exchange had been trading for some 18 years at the time of their bankruptcy (via records of the bankruptcy proceedings). Over those years they had offered various services that would be comparable to some unallocated accounts today (keeping in mind that all dealers do things a little differently). Early on their certificates of ownership stated that "THE ABOVE INGOT IS BEING STORED BY THIS EXCHANGE - FULLY COVERED BY INSURANCE AND FREE OF STORAGE CHARGE UNTIL REQUIRED", other customers had received notification that "The Perth Bullion Exchange agrees to store these ingots free of charge under the best security available on the condition that we may use the physical bullion in the normal course of our business". As prices for bullion fell and the bankrupt's business deteriorated, the owner progressively sold all his stock of bullion. At the date of the sequestration order, the bankrupt was in possession of various giftware, jewellery, fixtures and fittings (but no bullion).

There was little warning of Perth Bullion Exchange's demise, in fact just several months prior the Sydney Morning Herald ran a positive article
(read in full here) on the company describing a proprietor who was interested in floating the company publicly:



Another example, this time in New Zealand, was that of Goldcorp Exchange Ltd, Wikipedia summarises:
Goldcorp Exchange Ltd had a business of holding gold reserves in coins and ingots for customers wishing to invest in gold. Some gold was held for customers, but the levels varied from time to time. The company's employees also told customers that the company would maintain a separate and sufficient stock of each type of bullion to meet their demands, but in fact it did not. The Bank of New Zealand on 11 July 1988, being owed money by Goldcorp Exchange Ltd, petitioned for the business to be wound up. It transpired that Goldcorp had not held anywhere near enough money for the members of the public, around 1000 people, who had supposedly bought gold with it, even though in their contracts they were entitled to delivery of the gold (in 7 days, for a fee) if they wished. The company also lacked enough assets to satisfy the debts to the bank. The members of the public alleged that the gold that remained in stock was entrusted to them. The bank argued that because the gold stocks had never been isolated, it did not, that all the gold customers were unsecured creditors and that its security interest (a floating charge) took priority.
In this case, there was Gold remaining in stock at the time of their bankruptcy but the title of the metal hadn't been structured to verify ownership by the clients holding unallocated accounts. An early brochure read "Basically you agree to buy metal at the prevailing market rate and a paper transaction takes place. [The company] is responsible for storing and insuring your metal free of charge and you are given a 'Non-Allocated invoice' which verifies your ownership of the metal. In the case of gold or silver, physical delivery can be taken upon seven days notice and payment of nominal delivery charges." (via records of the bankruptcy proceeding), but the judgement was made:
The Privy Council advised that the customers had no property interest in the gold, and therefore the bank could use it to satisfy its debts. The customers' purchase contracts did not transfer title, because which gold specifically was to be sold was not yet certain. Although Goldcorp's brochures had promised title, a trust did not arise because there was no declaration of it. It was contrary to policy to imply a fiduciary duty simply because there was a breach of contract. It was also rejected that equity required any restitution of the purchase money.
Both of these examples are very dated. One might look at these precedents and think that recurrence is unlikely today. However, my current concern lies with the recent revelation of missing Gold and suspected tax fraud occurring as previously covered on this site in my article 'ATO & AFP Investigate Australian Gold Industry Fraud'.

I don't know what will come of this investigation and those companies named in the exposé by Chris Vedelago, but the potential for some of them to suffer losses (or potentially worse) as a result of these events seems worthy of consideration. As far as I know ATO garnishee notices take priority over other creditors, so unlike the New Zealand case detailed above, you'd want to be sure that the customer ownership of any metal in unallocated accounts was air tight if you have a substantial holding in this form.

This article was not written with the intent to panic those investors with unallocated accounts, but simply to draw attention to the risks associated with having another party store your precious metals. In the case of outright theft of customer metal, which seems to be what occurred in the case of Perth Bullion Exchange, allocated accounts aren't completely safe either. However, even if bullion dealers offering unallocated accounts do everything by the book and are a reputable long-standing business, they may inadvertently expose themselves to external risks that put their company and the unallocated accounts of their clients at risk.

I said in another recent article '7 Ways To Keep Your Gold And Silver Safe' that "there is no completely risk free way to own precious metals, as is the case with any other investment", it's just a matter of assessing the risks of the various options available and judging for yourself which you think is safest.


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 Buy bullion online - quickly, safely and at low prices