About Me

Mark Morris Consulting, is registered in Zurich, Switzerland. Regular interaction and input with the OECD Global Transparency Forum board members on the CRS. Currently advising the EU Parliament on the introduction of a mini FATCA against USA for breach of promised FATCA IGA reciprocal reporting. Has been recognised by the EU Commission for his valuable exchange of views on the EU Savings Tax Directive Amendments since 2005.

Mr. Morris was called to testify before the German Parliament hearings on 24 September 2012 regarding his technical analysis on the strengths and flaws of the Swiss-German tax agreement.

Currently advises several competent authorities on the misapplication in their official guidelines concerning Automatic Exchange of Information (AEOI).

Edits the AEoI technical papers for Tax Justice Network.

Authors e-learning scripts for law firms on the CRS.

Provides live training on the CRS to law firms, trustees, wealth managers and major banks.
I am considered by the EU Commission as a leading expert in the EU Savings Tax Directive.
German Bundestag Tax Expert:
I was called by the German Parliament hearings on 24th September 2012 to give presentation the Rubik loopholes. (Jump to 2:05:50 to see me)

My is testmony is here. The German version is here.

Here is the list of attending experts.

The subjects I have been actively involved with include, inter alia others:-

  • I work with regulatory and tax authorities, banking supervisors, parliaments, commissions on the ambiguities, weaknesses, misunderstandings of guidelines, etc.
  • I consult for trustees, lawyers, banks and wealth managers regarding structures that are legitimately exempt from CRS / FATCA reciprocal reporting.
  • The use of untaxed entities active entities used to camouflage financial asset investments.
  • Linking of money laundering and anti-terrorist financing requirements to identify beneficial owner
  • Insurance effectively prohibited from being sold across borders is major loophole
  • Deeming the initial contributor as beneficial owner of a trust / foundation when an immediate beneficiary is not identifiable
  • Capital guaranteed structured products which rely mostly on debt claim assets yet are classified as a non-debt derivatives.
  • Detailed analysis of annuities (fixed, variable, temporary, certain, etc.) and non-standard life policies (e.g. with-profits, capital redemption, etc.)
  • Risk analysis, solvency costs and liquidity requirements of life insurance wrappers versus bank deposits.
  • Analysis of derivatives which contain or are based on debt claims (e.g. Swaps, floored, etc.)
  • Study of products similar to debt claims but may not be classified as such, e.g. Sharia deposits, Sukuk bonds, static and dynamic certificates and baskets, hybrid capital, LEPOS and REPOS, etc.
  • Routing of payments via international network to avoid directive
  • Study of effective place of management

Mark Morris
Zurichstrasse 28, CH-8306 Bruettisellen, Switzerland
(t) +41-43-538-97.58
(m) +41-76-212-20.24
            E-mail           mark.morris@the-best-of-both-worlds.com