The exclusive club of offshore accounts

Fred R. Conrad/New York Times

James H. Simons of Boston was the main beneficiary of a private trust that was one of the largest in the world.

By Scott Shane and Spencer Woodman New York Times 

NEW YORK — James H. Simons, a reserved mathematician and hedge fund operator from Boston now approaching 80, is a big Democratic donor. Warren A. Stephens, a 60-year-old golf enthusiast once called the king of Little Rock, Ark., inherited a family investment bank and became a booster of conservative Republicans.

But Simons and Stephens are both billionaires who have used the services of offshore finance, the trusts and shell companies that the world’s wealthiest people use to park their money beyond the reach of tax collectors and out of the public eye.


Simons was the main beneficiary of a private trust, never previously described, that was one of the largest in the world. In response to recent questions about the trust, Simons said that he had transferred his share to a Bermuda-registered charitable foundation.

Stephens used an opaque holding company to own an approximately 40 percent stake in a loan business accused by the federal Consumer Financial Protection Bureau of cheating working-class and poor Americans. While earning millions from the investment, Stephens helped finance a political onslaught against the bureau, never mentioning his personal connection to the fight.

The details of the two men’s hidden wealth come from the files of Appleby, founded in Bermuda more than a century ago and considered one of the world’s top offshore law firms. A collection of 6.8 million Appleby documents, obtained by the German newspaper Süddeutsche Zeitung and shared with media organizations through the International Consortium of Investigative Journalists, offers an inside look at the firm’s services and customers.

Appleby operates in a rarefied universe of UHNWI’s — the industry’s abbreviation for ultra-high-net-worth individuals — where yachts and private jets are preferred transport and mansions sit empty because their owner has several others. Some of Appleby’s customers are also PEP’s — politically exposed persons — for whom avoiding unwanted attention is a crucial goal.

What offshore services offer to a diverse international elite is secrecy and discretion, along with the opportunity to minimize or defer taxes.


Appleby had 31,000 US clients, the most common nationality by far. The firm’s files include a who’s who of the nation’s wealthiest citizens: prominent Democrats like George Soros, the financier and philanthropist, and Penny Pritzker, commerce secretary in the Obama administration; and high-profile Republican supporters of President Trump, including Sheldon Adelson, the casino magnate, and Carl Icahn, the private equity investor.

Queen Elizabeth II, according to Appleby documents, invested through a Cayman Islands fund in a company that owned a share of a British rent-to-own company widely criticized for financing the sale of household items at interest rates as high as 99.9 percent. The leaked files reveal Madonna’s shares in a medical supplies firm, Bono’s investment in a Lithuanian shopping center and Microsoft co-founder Paul Allen’s yacht and submarines.

In a statement, Appleby said the firm had done nothing wrong. “We are an offshore law firm who advises clients on legitimate and lawful ways to conduct their business,” the statement said. “We do not tolerate illegal behaviour.”

Simons, the hedge fund billionaire, was a young math professor in 1974 when a Colombian friend established a trust in Bermuda on his behalf using a gift of $100,000 to him, his parents, and his descendants. US tax authorities would consider the Lord Jim Trust, as it was named, a foreign entity, limiting the visibility of the IRS into its holdings and its ability to tax its funds until it made distributions to the Simons family. (Appleby did not create the trust but later provided legal advice.)

In 1982, Simons founded Renaissance Technologies, a New York-based hedge fund whose secret trading algorithms soon generated rates of return that became legendary on Wall Street. Over the next three decades, Renaissance became one of the most lucrative hedge funds on the planet, making Simons a billionaire many times over.

Simons, in response to questions, said that when he and his family received distributions from the Bermuda trust, they were reported to the IRS. But Simons said he and his relatives took out only limited amounts, mainly in the early years of the trust, whose main investments were Renaissance funds that enjoyed spectacular returns.


In 2014, a Senate committee accused Renaissance and another hedge fund of using a complex accounting maneuver to improperly avoid taxes. Renaissance is still fighting the resulting tax bill, estimated at $6.8 billion.

As the tax dispute has proceeded, Simons is now estimated to be the 25th-richest person in the United States, with a net worth estimated at $18.5 billion, according to the Forbes list of richest Americans. But such rankings often rely on incomplete public data.

Simons’ Lord Jim Trust offers one example. Though the trust has been listed in various filings, a 2010 document in Appleby’s files provides details for the first time. If it had been fully accounted for in calculating his net worth, he would have vaulted even higher in the ranks of the superrich.

Yet factoring the trust into his wealth isn’t so straightforward, because Simons says his share is now in an offshore charity, Simons Foundation International. In 2010, he and his wife, Marilyn, signed the “giving pledge” established by Bill Gates and Warren Buffett, vowing to give “the great majority” of their wealth to philanthropic purposes.