IMS © International Monetary Specialists Bio and Timeline Press page for Immediate release
Patent Filed – July 2011
IMS (International Monetary Specialists ©) was formed in early July 2011
Before 2010 it was very apparent within the Forex © Trading circles and Online Currency Conversions that took place in the infancy stage of the internet, there was a serious transparency and (Slippage) problem facing Traders as well as Banking online. While billions of dollars around the world was being eaten up in lost transaction events with absolutely no accountability, the Challenge before IMS was clear. The Main focus of IMS © was then to design and develop certain proprietary technologies for currency transactions that gave complete transparency to the user. This method and system of Point of Conversion or (POC) with Time / Date stamping was born, then by sending a Report to the user of an exact transaction time down to the second this gave the user and exact moment of his or her transaction for taxation. This POC Report Characterizes clients’ Money Conversion so they can substantiate the value of the Spread to use it for tax purposes.
This simple concept yet difficult to patent system was set before IMS © to complete. In order for any multinational entity or individual performing currency exchanges for business or personal use this had to be implemented as soon as possible. By simply putting this into use would greatly enhance the Transparency of the Cash Conversion Process at the actual POINT OF CONVERSION (POC), revealing dealt and offset pricings and TIME thereof thus providing the customer with a complete report of conversion as with any commodity conversions. With the IMS (POC) method, the client will have a substantially complete accounting of the value of the funds conversion from one region’s currency to another. IMS decided early on the patentability of their (POC) system had merit and decided to enlist the top Intellectual Property Attorney Firm GreenbergTraurig, LLP ©
GREENBERG TRAURIG, LLP | ATTORNEYS AT LAW | WWW.GTLAW.COM
Patent Search and Provisional Filing
It was clear and through world patentability that the filing was open for the unique intellectual property of IMS’s POC system and on July 6, 2010 the initial provisional application was filed as Method and System for Currency Exchange By Point of Conversion. It wasn’t until March 4, 2014 that the patent US 8,666,860 B2 was granted by the USPTO in Washington, DC. The time was lengthy and expensive, partly due to the many other filings that came after our provisional was filed, this caused many other similar patents to be denied over and over to this very day.
After our Patent was granted, GreenbergTraurig, LLP. © issued a letter of great importance stating;
“This was the Most Significant Patent in Modern History EVER Granted to a firm or an individual”
Use on the Cambridge Exchange- 2011-2013
The IMS © System of POC was tested and performed flawlessly on the FXCM Cambridge Platform for three years beginning in 2011 using EZ-Trade user interface. A record of each deal a client created is recorded in our database. With the search criteria available in ‘Account Status & Reports’ a client can review all their account activity and create corresponding reports anytime they require the information.
By accessing the following categories from the drop-down menus, which include:
‘Payment History’, ‘Settlement History’, ‘Deal History’, ‘Forward History’, ‘Account Balances’ and ‘Today’s Trades’, a client can select the activities that will assist them in sorting and organizing key information.
For each search a client can add as much or as little information as they prefer, the more detail they provide gives them the opportunity to create customized reports for themselves and their team. These results are immediately displayed for their review or use the icons to print or export the results to an excel file which can then be used with their own accounting software.
Use on the FXCM Cambridge Exchange Listed NYSE © – 2013
Search and view historical account activity for all your accounts by a specific date range, deal, reference ID or beneficiary Select and download account history which you export to an excel file or Print Resource Center: Provides the client with any additional resources they might need. (Resource Center Dropdown Menu from Dashboard Screenshot)
Basic Principals Moving Forward – 2016
▪ Foreign currency (FX) is treated as personal property for US tax purposes.
▪ As such, disposition of FX is subject to the general realization principles.
▪ Thus, when FX is acquired, its basis is the cost.
▪ When the FX is disposed of, the resulting gain or loss equals the amount realized minus basis.
▪ Currency transactions with the taxpayer’s functional currency are generally not taxable events. For example, use of functional currency to purchase property denominated in functional currency does not result in FX gain or loss.
▪ Thus, it is important to determine what is the taxpayer’s functional currency.
▪ The taxpayer’s functional currency is determined by reference to either the taxpayer itself or the taxpayer’s identifiable separate business operation entitled “qualified business operation (“QBU”).
▪ Each QBU of the taxpayer has its own functional currency.
▪ The USD is the functional currency of a US taxpayer, or of the taxpayer’s QBU, if its activities are mostly conducted in USD.
▪ Any effectively connected income to a US trade or business of a foreign taxpayer is generally treated as a separate QBU with the USD as its functional currency.
▪ Taxpayers can generally elect to treat the USD as their functional currency.
▪ Functional currency is treated as a “method of accounting.”
Books and Recording
▪ A crucial factor in the functional currency determination is the books and records.▪ It is accepted that a QBU is deemed to maintain its books and records in the currency of the “economic environment” in which a significant part of its activities is conducted.
▪ A QBU’s economic environment is determined under a facts and circumstances test.
QBU (Qualified Business Unit)
▪ “any separate and clearly identified unit of a trade or business of a taxpayer” if such unit “maintains separate books and records.”
▪ An individual may have a qualified business unit (QBU) that has a non-dollar functional currency.
▪ However, an activity that does not generate deductible expenses does not qualify as a QBU.
▪ Corporations, partnerships, trusts and branches may be considered QBUs.
▪ Certain activities of the above entities may qualify as a separate QBU if such activities
constitute a trade or business and (2) separate books and records are kept for such activities.
▪ The activities or an individual, as an employee, are generally not considered a separate QBU.
QBU (Qualified Business Unit)
▪ The currency of the country in which the QBU is a resident.
▪ The currencies of the QBU’s cash flows.
▪ The currencies in which the QBU generates revenues and incurs expenses.
▪ The currencies in which the QBU borrows and lends.
▪ The currencies of the QBU’s sales markets.
▪ The currencies in which pricing and other financial decisions are made.
▪ The duration of the QBU’s business operations.
▪ The significance and/or volume of the QBU’s independent activities.
Section 988 Timing
Section 988 and regulations thereunder provide guidance as to the timing, character and source of gains and losses from FX transactions that are subject to it.
▪ Section 988 requires gain or loss from the overall transaction as a threshold matter.
▪ The second step is to bifurcate the overall gain or loss between gain or loss attributable to changes in the exchange rates and gain or loss attributed to the underlying transaction.
▪ The “SPOT” rate is used to determine the extent of the FX gain or loss
▪ If there is gain or loss on the underlying transaction, and an offsetting FX gain or loss, the two are netted and only the excess is recognized.
Section 988 Character
▪ As any general rule, FX gain or loss is ordinary within this framework
▪ Upon a taxpayer’s election, FX gains or losses from certain FX denominated contracts, including forwards, futures and options can be treated as capital.
▪ Some FX gains and losses in connection with FX denominated debt instrument are characterized as interest.
Section 988 Source
In general, the source of FX gains and losses is determined by reference to the taxpayer’s residence or the residence of the taxpayer’s QBU.
FX gains/losses in connection with trade or business
Certain high yield related party FX denominated loans
FX gains/losses characterized as interest
Integrated FX debt and a hedge.
Disposition of FX
▪ A mere decline in the FX’s value does not result in taxable event, unless the FX was held in connection with a trade or business and becomes valueless during the year.
▪ If a taxpayer disposes of functional currency, there are no taxable consequences.
▪ Sale and other disposition of nonfunctional currency will give rise to FX gain or loss, computed under the general principles of section 1001.
Exchange of FX for Other Currency
▪ Exchange of functional currency with functional currency does not give rise to FX gain or loss.
▪ Exchange of units of nonfunctional currency with different units of same nonfunctional currency is not taxable event.
▪ Exchange of one nonfunctional currency with another nonfunctional currency (e.g., Euro to Yen) is taxable event.
▪ Exchange of nonfunctional currency with functional currency is taxable event.
Exchange of FX for Property
Treated as a 2-step transaction:
exchange of nonfunctional currency to functional currency at the spot rate.
Purchase of the property for functional currency.
▪ Company G is a U.S. corporation with the U.S. dollar as its functional currency.
▪ On January 1, 2018, Company G enters into a contract to purchase a paper manufacturing machine for 10,000,000 British pounds for delivery on January 1, 2021.
▪ On January 1, 2021, when Company G exchanges the BP 10,000,000 (which G purchased for $ 12,000,000) for the machine, the fair market value of the machine is BP17,000,000.
▪ On January 1, 2021, the spot exchange rate is BP1 = $ 1.50.
▪ The transaction is treated as an exchange of BP 10,000,000 for $ 15,000,000 and the purchase of the machine for $ 15,000,000.
▪ Accordingly, in computing Company G’s exchange gain of $ 3,000,000 on the disposition of the BP 10,000,000, the amount realized is $ 15,000,000.
▪ Company G’s basis in the machine is $ 15,000,000.
▪ No gain is recognized on the bargain purchase of the machine.
Definition of Stock Trading and The Term (Slippage)
While a limit order can prevent negative slippage, it carries with it the inherent risk of the trade not being fully executed if the price does not return to a favorable amount. This risk increases in situations where market fluctuations occur more swiftly and significantly limits the amount of time for a trade to be completed at an acceptable price, also known as “Stock Trading Slippage”
“The last main issue is Incorrect and misleading Time Stamps. The timing factor is the most difficult of all, even if you have a diligent CFO or treasury watching the pricing against the published interbank rate.”
As published in -The Wall Street Journal ©
There is an estimated $144,000,000,000 Per Day accounting gap due to slippage
The lack of transparency in Global Payments and FX exchange is now being questioned
No legal remedy exists to solve for this problem UNTIL NOW!
IMS Implements Proof of Concept – Jan 2013
International Monetary Specialists © (IMS) designed and developed a proprietary hardware/software solution system that solves currency and crypto currency exchange fraud by using Time / Date Stamping with Reporting. The Company’s core offerings are designed to meet the needs of the security challenged transaction processing industry. There is no present-day solution to this problem and it’s growing. Even Forex and Stock Exchange Platforms have not reduced currency theft by any significant factor. The IMS solution has reduced theft to zero in transaction pilots. The Company’s proven and highly scalable solution is gaining worldwide attention and placing IMS © at the forefront of the fraud prevention list of companies the SEC is looking for.
An increasing number of transactions and money transfers are done online, electronically, or through credit/debit cards. More than $10 trillion was exchanged in various electronic forms across the world in 2017. This trend is expected to increase. IMS is poised to implement its technology throughout every transactional exchange server in the world.
To date the company has invested over $3.5 million to design and streamline our system to be open ended and to easily integrate into every global multi-currency exchanges, trading platforms and cryptocurrency exchange.
IMS Proprietary Technology– February 2018
Headquartered in Orlando, Florida International Monetary Specialists © (IMS) is a Technology Company that develops, operates and markets leading payment processing solutions to combat transaction fraud.
IMS developed this technology for one main reason, to stop currency theft, however it also provides proof of transaction through software which provides comprehensive solutions for taxation and slippage. IMS’s solutions are also expected to dramatically reduce fraud for consumer clients, cryptocurrencies, credit card companies, ALL financial institutions and merchant gateways.
IMS successfully completed a pilot test in early 2011, which was conducted with various processing gateways via FXCM through Cambridge Mercantile Group Global Payment Services Platform. Transactions worth over $1.5MN were verified with reporting. This remarkable result has proven the technology and has brought the IMS Technology into the public eye recently and established it as a leader in the fight against currency and cryptocurrency cybercrimes. IMS’s unique anti-fraud technology was developed using a technology that is Patented and Patent Pending (PCT approved) across 29 countries based on strategic importance and wireless penetration rate.
The software operates using a cellular phone for secured verification of monetary transactions. The industry changing transaction services model is non-invasive (does not require system changes) with instant verification that is inexpensive to implement and simple to use. The software has been developed to include debit card purchases, internet purchases, money transfers, remittances and identification verification. Additional applications for the software are constantly being identified and will be implemented in due course.
Most Asian countries have almost a 100% adoption rate for cell phones and have one of the highest user rates for SMS (short message service) in the world. These statistics will accelerate the adoption of IMS’s verification method.
Time / Date Stamping and Transparency through Reporting solves “high risk” transaction merchants which have the highest rate of fraud and charge-backs. High risk industries such as Adult Entertainment, Gaming, Gambling, Pharmaceutical, Travel and e-Commerce, industries that produce over $300 BN annually. According to, APACS (Association of Payment Clearing Services) card fraud losses totaled £609.9 million (US $896.5) in 2008 or 0.12% of card turnover. This statistic was 0.14% prior to the introduction of “Chip and PIN”, meaning an overall reduction of a meager 0.02% in losses.
Exactly What the SEC is Looking For– May 2018
Considering the brief history since the advent of the World Wide Web and since online trading of exchange rates, problems of theft, cyber-attacks and the past Foreign Exchange attacks has dominated world news as of late. Quite simply The IMS is the only patented system issued by the USPTO for Time / Date stamping and the ONLY one that ever will be.
The following identifiable problems have been the dominating factors prompting the creation of a totally secure online exchange using IMS Patented technology as outlined below:
FACT! Fiat transactions are expensive, lengthy, and labor intensive
FACT! Volatile price swings in Crypto markets
FACT! Massive lack of Transparency from exchanges
FACT! Unclear Price Formation and inadequate reporting tools
FACT! Continuous hacks, fraud and charge-backs are rampant in the online commerce, trade and transactional sectors.
FACT! With all this in mind, this means currencies, foreign trades and Forex transactions and cryptocurrencies are NOT as secure as the public is easily lead to believe. Looking ahead, current blockchain technology such as Bitcoin is unprepared for the next generation of supercomputers and quantum computers that can produce the necessary computations to crack their best encryption efforts.
Transactional Industry related crimes are estimated to cost trillions of dollars each and every year escalating to a critical bottleneck, ultimately ending in the complete collapse of a monetary system that has taken a hundred years to develop. The industry is facing a global crisis in fraudulent transactions that are negatively impacting profitability and transaction viability. One in six online consumers is the victim of credit card fraud; one in 12 has been hit with identity theft, despite advances in encryption and card protection developed by the banks themselves. Financial institutions, cryptocurrency organizations and merchants are desperately searching for effective solutions to reduce and eliminate transaction fraud.
The SEC and Taxability Issues– June 2018
Despite its massive growth, Cryptocurrencies are still far from a secure and stable place to store value, or for use as a transactional solution to today’s financial problems. Decentralized currencies are at massive risk of various forms of attack. With the advent of Quantum Computers, these risks become greater over time. The rapid growth of the power of supercomputers will soon overtake conventional encryption methods, and when this happens, conventional Blockchain technology and those who store their value in them will be at severe risk.
With IMS POC Point of Conversion means Zero Transaction Fees (no conversion costs) Time / Date Stamping of POC Transaction through IMS Proprietary System Full transparency through regular account audits, & 24/7 published balances provide proof of funds Get Tracked and Verified Complete Transparency through customized reporting sent immediately SMS or Email Detailed Report is sent to the user immediately upon confirmation as a tax receipt