Final Report. Feasibility Analysis for Establishment of an International Finance Zone in Lower Manhattan. DCG Corplan Consulting LLC

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1 Feasibility Analysis for Establishment of an International Finance Zone in Lower Manhattan prepared for the Empire State Development Corp. 633 Third Avenue New York, NY by: Hutton Park Executive Center Nineteen Hutton Avenue West Orange, NJ 07052

2 TABLE OF CONTENTS Project Background Part 1. Review of Global Finance Centers and Offshore Havens Part 2. Interviews with Government and Financial Industry Leaders Part 3. Preliminary Design of the International Finance Zone Part 4. Key Findings of the Analysis Part 5. Recommended Next Steps

3 Project Background

4 Project Background Strategic Plan for Development Finance, Insurance and Real Estate Industries in Lower Manhattan DCG Corplan Consulting assignment commissioned by Empire State Development Corporation in May 2002 Key Recommendations: Building Owner s s and Tenant s s Insurance Relief Package FIRE Job Creation Program The Finance and Insurance Academy Security-Led Benefits Package Midtown-Downtown Light Rail Enhanced Incentives Program The International Finance Zone

5 Part 1. Review of Global Finance Centers and Offshore Havens

6 Part 1. Review of Global Finance Centers and Offshore Havens Key global financial centers International banking Frankfurt, Germany Hong Kong (SAR) Taipei, Taiwan Singapore Tokyo, Japan Offshore tax havens Nassau (Bahamas) Cayman Islands Channel islands (UK) Ireland Liechtenstein Luxembourg Captive insurance & reinsurance Bermuda Key US domestic domiciles Captive insurance & reinsurance Arizona Arkansas Colorado Delaware Dist. of Columbia Georgia Hawaii Illinois Maine Montana Nevada New York Rhode Island South Carolina South Dakota Tennessee Vermont

7 Part 2. Interviews with Government and Financial Industry Leaders

8 Part 2. Interviews with Government and Financial Industry Leaders Government interviews Banking NY State Banking Dept. Central Bank of the Bahamas Bermuda Ministry of Finance Bermuda Monetary Authority Insurance NY State Insurance Dept. Vermont Dept. of Captive Insurance Arizona Dept. of Insurance Hawaii Dept. of Commerce & Consumer Affairs (Insurance) Industry interviews Financial services A leading Money Center Bank (NY) Federal Reserve Bank of NY A foreign Bank with NY Branch A leading financial consulting company, Bahamas The Bahamas International Securities Exchange 2 leading insurance mngmt. companies, Bermuda

9 Part 3. Preliminary Design of the International Finance Zone

10 Part 3. Preliminary Design of the International Finance Zone Program objectives A tax-advantaged, advantaged, regulatory-enhanced enhanced services zone for the banking, financial and insurance industries The identification of key financial services industries by 4-digit 4 SIC code for inclusion in the Zone IFZ boundaries that would coincide with the Liberty Zone and proposed WTC Tax zone and access their incentives Full disclosure to curb money-laundering or funding of terrorist activities as per efforts by the US Government and OECD The creation of an Authority encourage, promote, market and administer the zone, but be self-sustaining sustaining in 4 years A benefit to cost ratio of at least 15-to to-1

11 Part 4. Key Findings of the Analysis

12 Part 4. Key Findings of the Analysis Key Finding A. Infusion of $1 trillion in deposits will strengthen position of Lower Manhattan US is 10% behind the UK in deposits for share of the $10 trillion global offshore investment market $1 trillion (10%) is achievable given the enhanced US efforts to collect income and excise taxes on flight capital Capital infusions would be considered as new business that is currently untaxed and lost to offshore domiciles New deposits will create jobs, enhance demand for new office space, and increase governmental revenues New York can assert its role in the re-insurance markets through regulatory reform and captives recruitment

13 Part 4. Key Findings of the Analysis Key Finding B. Triple Triple-tax exempt treatment within the IFZ will provide an alternative to offshore havens Model regulatory environment offering safety and soundness and operating in full compliance with US tax codes and the OECD US Investor: Amnesty from federal, state and city income and excise taxes on capital repatriated from offshore domiciles US Investor: Triple tax-exemption on capital gains, interest, and dividends for funds held in deposit in the IFZ until withdrawn Foreign: Continuation of income tax exemptions on capital gains, bank interest and portfolio interest Foreign: Exemption from 30% flat tax on dividends, branch profits and non-bank interest

14 Part 4. Key Findings of the Analysis Key Finding C. Providers in the IFZ can expect an increase of $23.75 billion in annual revenues by 2013 New business for banking and financial industries, and higher volume for insurance companies, particularly captives Annual revenue projections are based on $1.64 million per employee per year (US Dept. of Labor averages) Year 1 revenue: $ 1.25 billion (762 employees) Year 5 revenue: $11.25 billion (5,335 employees) Year 10 revenue: $23.75 billion (14,482 employees) $1 trillion: End-of of-year deposit assets by year 2013 New business for providers will translate into demand for indirect services and vendors

15 Part 4. Key Findings of the Analysis Key Finding D. The International Finance Zone will create almost 32,000 new jobs in 10 years 14,482 permanent direct positions in 17 key industries, 14,482 indirect positions, and 3,000 construction-related related jobs 3,658 positions Commercial banks and services 913 positions Foreign bank branches/agencies 292 positions Credit institutions 6,285 positions Securities and related services 3,334 positions Insurance Average employment growth of 1,525 persons annually New York State will provide about 80% of these applicants

16 Part 4. Key Findings of the Analysis Key Finding E. The IFZ providers will require about 6.4 million square feet of new office space Class A absorption is forecasted for 674,000 square feet per year through based on gross 442 s.f. per direct employee 1.83 million s.f. Commercial banks and services 0.46 million s.f. Foreign bank branches/agencies 0.15 million s.f. Credit institutions 3.14 million s.f. Securities and related services 0.83 million s.f. Insurance $1.92 billion = total hard cost investment by 2013 Indirect multiplier should absorb equivalent amount of current vacancies

17 Part 4. Key Findings of the Analysis Key Finding F. Zero investments by federal, state or city governments are needed Temporary outlays of $54.7 million fully recoverable from $2 billion lion in total benefits over 10 year period benefit/cost ratio of $3.2 million for obtaining Federal and NYS legislation (2003) $3.5 million estimated for formation and operations of the International Finance Zone Authority (IFZA) (until 2008) $9 million* allocated for assemblage of targeted sites $14 million* for relocation of occupants from assemblages $25 million* for premiums on default protection for bonds issued $54.7 million Total costs for program implementation * Recoverable from private developers

18 Part 5. Recommended Next Steps

19 Part 5. Recommended Next Steps Federal Government Agreements or actions necessary to establish the IFZ No capital gains, interest, or dividends tax on capital deposited with a bank or securities firm located in the IFZ Upon withdrawal, no withholdings or other tax will be applied for foreign investments (unless the alien investor has another defined source of U.S. income) Upon withdrawal, a U.S. citizen or resident alien will be subject to capital gains and ordinary income on investment proceeds Tax amnesty to encourage U.S. investors to repatriate their funds from offshore accounts Foreign branch tax eliminated Relaxation on rules for International Banking Facilities (IBF)

20 Part 5. Recommended Next Steps New York State Agreements or actions necessary to establish the IFZ Taxation agreement similar to Federal government Tax amnesty to encourage New York State citizens to repatriate their funds from offshore accounts Formation of Agreement Corporations (Edge Acts) Reduction in capitalization requirements for formation of new captive insurance companies Legislative provisions for formation of the International Finance nce Zone Authority Legislative provision for funding of IFZA investments for site assemblages, occupant relocations and premiums on default Exploration of any sunset provisions for IFZ legislation

21 Part 5. Recommended Next Steps New York City Agreements or actions necessary to establish the IFZ Taxation agreements similar to Federal and State governments Tax amnesty to encourage New York City residents to repatriate their funds from offshore accounts No other incentives or inducements needed

22 Part 5. Recommended Next Steps Other Investigations Recommended consultants activities Analysis of a taxation limit for incremental business within the IFZ or other radical tax incentives as an inducement for financial institutions to enter the Zone tax disparities between Federal, state and city for International Banking Facilities (IBF s) response to the proposed IFZ program through a series of forums, white papers, and site visits Examination of the tax disparities between Federal, state and Exploration of stakeholders response to the proposed IFZ

23 We wish to thank the Empire State Development Corporation for the opportunity to present this analysis.

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