Family Money: Offshore companies

By Leslie Wright

Many people with international assets have little idea of how to structure their holdings through a privately held offshore company. It all seems too complicated and potentially expensive. Actually, the reverse is true. But before outlining the uses of these vehicles it is worth reiterating exactly what they are, simplistic though it may seem.

To start with the basics, a company is defined as a legal entity that can own assets, which are themselves owned through the medium of shares. The primary use of an offshore company is to shift the legal status of assets that might otherwise carry with them adverse tax consequences. When an asset is bought through, or transferred to, an offshore company, the consequence is that the shares of the company are treated as the asset for tax purposes, while the underlying company owned asset ceases to have the tax consequences that it would have if it was owned directly: the asset becomes the tax liability of the offshore company.

The most obvious example of a situation where use of an offshore company confers an advantage is with regard to real-estate property. For example, an expatriate who owns property in the UK has an asset that will potentially complicate his or her tax situation. On the other hand, an expatriate who owns shares in, say, an Isle of Man-based company will be better placed for tax purposes, even if that company in turn owns property in the UK, because his or her direct asset for tax purposes is an offshore company rather than a property.

Difficulties may arise for an expatriate attempting to sell a property in an onshore jurisdiction - difficulties that could be avoided if that person was simply selling shares in an Isle of Man or other offshore company, even if that company owned a property in the onshore jurisdiction. And when a UK expatriate decides to sell a UK property which is owned through an offshore company, no stamp duty will be incurred, as for tax purposes the property will not be sold.

Ownership of the property will remain with the offshore company throughout the transaction. What will be transferred, however, is ownership of the shares in that company. The vendor will simply sell the company shares for a consideration equal to the agreed sale price of the property.

Simple trading

Transferring ownership of an offshore company can also be administratively simpler for an expatriate than transferring title to an onshore property. The shares in an offshore company are, simply by virtue of being offshore, a tax-efficient asset in a way that no onshore asset can be. The uses of an offshore company, however, go beyond simply achieving tax advantages for British expatriates owning UK property and other assets. Owning an offshore company which in turn owns one or more onshore assets in one or more jurisdictions can also be a method of simplifying a range of administrative activities.

Gaining probate in the event of the death of the asset-owner is one such process. When a wealthy individual dies with assets in several jurisdictions, the executors have to prove probate in each jurisdiction where the assets were held. Holding all the assets through an offshore company will greatly simplify this process, as the executors then only have to prove probate in the jurisdiction where the company was based.

Other potential uses of these vehicles include centralising the administration of a diversified investment portfolio. An offshore company can be a convenient fixed point at which to collect, say, dividends and interest payments.

Tax efficiency

Generally speaking, offshore companies do not pay tax, subject to the condition that they do not trade in the jurisdiction where they are constituted. In most jurisdictions they will pay a flat duty instead, of around $650 to $800 per annum. While this obviously makes them tax-neutral vehicles, they can go beyond neutrality and be used to secure a more favourable tax treatment for their owners in other jurisdictions. In some cases offshore companies can be structured so that their shareholders may opt to pay tax at a percentage rate rather than a flat duty.

This kind of set-up is particularly attractive where the beneficial owner of an offshore company is active in onshore, relatively high-tax jurisdictions where there may be a requirement to pay tax unless there has already been a payment of, for example, 75% of the tax liability elsewhere.

Avoiding work

International Business Companies, or IBCs as they are commonly known, impart a similar freedom to their beneficial owners in respect of corporate registration, imposing minimal reporting requirements on their directors and generally not requiring the filing of detailed accounts.

Additionally, an IBC that is active in an onshore jurisdiction may avoid potentially onerous local registration requirements by indicating that it is already registered offshore. IBCs are most useful where an individual has multi-jurisdictional interests such as, for example, the collection of royalties on musical recordings. Offshore companies can also offer significant advantages when it comes to career management. For an expatriate working for an employer in a less legally developed jurisdiction, it can be sensible not to be employed directly, but to act effectively as a consultant by contracting out his services from an offshore company.

The expatriate can, for example, use the company for the import and export of goods for commercial purposes, and for invoicing for their services. An employment contract with an overseas employer, enforceable in an overseas jurisdiction, might afford less protection than a simple, flexible company-to-company contract for services rendered - so again the offshore company comes into its own in this situation. If a directly employed expatriate faces a problem that requires legal adjudication, the question also arises of which jurisdiction in which to hear the case.

The answer will generally depend on where the initial contract of employment was negotiated and signed, but this can itself often be unclear; and ready access to non-employer legal representation in overseas jurisdictions can also be hard for an expatriate to find.

Another side-benefit for the expatriate is the continuity of being effectively employed by their own offshore company to implement and maintain insurance and other long-term benefits schemes, with the ‘real’ employing company making a contribution. Thus the individual avoids the need to change benefit arrangements every time he or she changes employer.

Keeping assets safe

Direct ownership of assets can also pose a threat to the expatriate working in an unstable jurisdiction and therefore vulnerable to kidnap or attack. If the management of those assets is remote, there will be less point in targeting the individual and if an offshore company holds the assets they will not be directly vulnerable to seizure. This protective element may work in conjunction with other, simpler uses, in that an offshore company provides a straightforward tax-neutral ‘portfolio’ within which to bundle assets.

Individuals can gain the advantage of being able to move from one jurisdiction to another without affecting their assets if they are contained within an offshore company; they may also, however, move them all, or indeed transfer their ownership, in a single transaction. As well as transferring assets offshore and simplifying their administration, offshore companies impart confidentiality in that the reporting requirements on offshore companies tend to be limited.

Geography also plays a part: an offshore company will generally be sited at some distance from the jurisdiction where the expatriate is living, and where any undue official or unofficial interest in his affairs might be expressed.

But offshore companies can be vulnerable to ‘look-through’ legislation whereby an expatriate living in the same jurisdiction as his company-owned asset and enjoying all the benefits of ownership of that asset may be treated for tax purposes as if he was the direct owner of the asset.

Ongoing questions

Offshore companies also have the potential to complicate the tax affairs of their owners by virtue of the possibility that their existence will prompt questions.

To take a simple example, an onshore tax authority could infer from the existence of such a structure that an individual has something to hide.

So there are two cardinal rules when using offshore companies: first, avoid centres which offer a greater degree of confidentiality than practically required by the client; and second, ensure the purpose of the company is not solely to foil legitimate attempts by onshore authorities to collect tax revenue.

by C. Schloemer

Good points: good temperament, intelligent and easy to train, splendid retriever, usually good with children and other dogs

Take heed: do not make a clown or fashion model out of a fundamentally outdoor type

Few dogs have climbed to such favor in so many different countries as has the Poodle. Intelligent and obedient, this breed also has a character full of fun. A great fondness for water and a strong swimmer, the Poodle was originally a water retriever. Today, it is much favoured for the show ring, where, exhibited in the traditional lion clip, it is a beauty to behold. It is also one of the most difficult breeds to prepare for the ring, involving the handler in a day-long session in canine beauty treatment. But the poodle has a character full of fun, and because he is so good with children makes a devoted family pet. Any owner who has other dogs will find a Poodle will fit into the home setting easily.

Size: Height: 38 cm and over. Present day Standard Poodles may be seen measuring 63.5 cm or more at the shoulder.

Exercise: This is a robust, healthy dog that loves the outdoors, has plenty of stamina, and has lost none of its retrieving and sporting instincts. Therefore the owner should be prepared to allow this breed ample room for lots of exercise and outdoor activities.

Grooming: Use a wire pin brush and a wire-tooth metal comb for daily grooming. The lion clip is essential for the show ring, but pet owners who do not show their Poodles find that the more natural lamb cut with the hair a short and uniform length to be much more practical. With the lamb cut it is possible to clip your own dog with a pair of hairdresser’s scissors. However, if the owner finds this tedious, a visit to a grooming salon every six weeks is advisable. Poodles should be bathed regularly.

Origin and history: The Poodle appeared so early in various parts of the world that there is some doubt as to the land of its origin. It is supposed to have originated in Germany, where it is known as the Pudel. However, for years it has been regarded as the national dog of France, where it was commonly used as a retriever as well as a travelling circus trick dog. The Poodle was originally a shaggy guard, a retriever and collector of sheep, with origins similar to the Irish Water Spaniel, and no doubt a common ancestor in the French Barbet and Hungarian Water Hound. The Standard, Miniature and Toy Poodles all share the same ancestry, but authorities agree that the Standard is the oldest variety. Often used for truffle hunting, the smaller poodles were preferred as they did less damage to the edible fungus. The European continent had known the Poodle long before it arrived on British shores, but the English were aware of the Poodle since Prince Rupert of the Rhine, in company with his Poodle, came to the aid of Charles I in battle. The Poodle was also favoured by Marie Antoinette who, it is rumoured, devised the elegant lion clip to match the uniform of her courtiers.

by Marion

“Kundalini Yoga” by Shakta Kaur Khalsa is one book that I thought I bought for the pictures. Tranquil illustrations of serene aesthetes in white, sitting in relaxed meditative poses; in particular the Yogic ‘mudras’ or hand positions and mysterious spiral diagrams of chakras were compelling. Never having seriously contemplated exercise in any form, the pages on gymnastic like lotus postures were quickly skipped.

After thoroughly reading the book I was astonished to find that Kundalini Yoga is not about a series of contortionist exercises or New Age waffle, but rather about connecting with a basic personal (non religious) spirituality; almost a way of life. It was gratifying to learn that Kundalini Yoga is a system that effectively confers peace and calm into our modern fast-paced everyday lives. Not many philosophies are able to make that practical transition.

Yoga

The word ‘yoga’ comes from ancient Indian Sanskrit and it means ‘union’. This refers to a union of body, mind and spirit. Yoga is not a religion but a science that originated 10,000 years ago. Antique scrolls from Tibet record some of the oldest records of yoga. Yoga has its origins in many ancient cultures, particularly India, which has been synonymous with its preservation for thousands of years.

Yogi Bhajan

Kundalini Yoga was never taught publicly until 1969 when, in a challenge to the previous age-old tradition of secrecy, Yogi Bhajan brought it to the United States. His reasoning being, “I am sharing these teachings to create a science of the total self. It is the birthright of every human being to be happy, healthy and holy.” This began the spread of Kundalini yoga through the Western World. Yogi Bhajan, PhD, is head of the Sikh faith of the Western Hemisphere, also the founder of 3HO (Healthy, Happy, Holy Organization) a worldwide non-profit foundation.

Awareness

Kundalini Yoga, the Yoga of Awareness, consists of simple yogic techniques that can be enjoyed by everyone, regardless of age or physical ability. It is not about becoming a pretzel, rather about reaching a level of clarity and transcendence in daily life. It is a complete science that includes breath control (pranayama), yoga postures (asanas), sound and chanting (mantras) and (dhyana) deep meditation. It is designed to provide the experience of highest consciousness through the raising of the Kundalini energy (the energy coiled at the base of the spine awaiting stimulus to unfold).

Kundalini

“Kundalini” is a Hindu word meaning, “sacred transformative energy that awakens consciousness,” literally translated as, “the curl of the lock of hair of the beloved.” It is a metaphor describing the flow of energy and consciousness (God consciousness or Divine consciousness) that already exists within each one of us. This merging of individual consciousness with Universal consciousness creates a “Divine union” called “yoga.”

Trained teachers

Khalsa emphasizes the importance of a teacher, “Personal guidance from a trained teacher, and the experience of group yoga classes are just as important as the guidance from this book.” The book is intended as a complement to instruction from trained teachers. There is an international directory of Kundalini Yoga teachers (IKYTA), email [email protected]

Asanas

Of the Asanas, the posture that naturally appeals, is ‘Sukasana’ or Easy Pose. This is sitting on the floor with the spine straight, with the legs folded in front. Knees relaxed out and down towards the floor and the heels central on the floor, one inside the other (none of the impossible figure-8 leg twisting as in the “Lotus” pose). For the determinedly less than pliant bodies like mine, it is a relief that some of the yoga and breathing exercises may be done while sitting in a chair. Sit with the spine really straight, in a meditative pose, the feet on the ground and hands in the lap.

Mudras

Mudras are hand positions conveying spiritual connection, notice the position of the hands in Buddha statues, they are distinct and reveal different meanings. Khalsa states, “Thousands of years ago, yogis mapped out the hand areas and their associated reflexes. Mudras are a technique for giving clear messages to the mind/body energy system. Each mudra applies pressure to different areas of the hands and fingers, associates with a certain area of the body or brain, and represents different emotions and behaviours. The mudra which is used with most meditative poses is the ‘Gian Mudra.’ The tip of the thumb is put together with the tip of the index finger. This stimulates knowledge and wisdom within and increases receptivity and calm.”

Mantras

“Mantra,” which means mind projection, is a technique for regulating the mind. Not only does it empty the mind of extraneous thought it attunes into an energy of higher vibration frequency. “A powerful mantra is ‘Sa Ta Na Ma,’ (with the a pronounced like ah). In this meditation, sequentially press each of the fingers in the following way as you chant. ‘Sa’ - press the tips of the thumb and the index finger together - for Wisdom. ‘Ta’ - the thumb and the middle finger - for Patience. ‘Na’ - the thumb and the ring finger - for Energy. ‘Ma’ - the thumb and the little finger - for Communication. One of Kundalini Yoga’s classics, this meditation is perfect for the beginning or end of the day. In a most profound statement Khalsa says, “This meditation brings the realization we are channels for truth, and that to maintain grace in the most ungraceful moments is the true human worth.”

Healing Foods

An entire chapter in the book is devoted to healing foods. Believing that, “The food we eat is one of the three great pillars of total health,” Khalsa recommends unprocessed whole foods, cold pressed oils, fruits, vegetables, legumes and grains and plentiful water. Interesting recipes are included.

Staying relaxed

Khalsa gives marvellous tips for staying relaxed throughout the day with the essence of Yoga to keep you uplifted. Noting that, “The real tests in life come when we are faced with challenges in our workplace, our homes, or in the many roles we play throughout the day.” She suggests, “In the car, take a deep breath before driving. Say a prayer or affirmation of protection as you turn the key. Hum along with relaxing music. Chanting and singing elevated music will release tension and open the heart. At the office, get up every few hours and stretch down to your feet. Roll your head around on your neck slowly in both directions. Anytime you feel tired or depressed drink a full glass of water.

“Take a break from the computer every few hours and put a cold wet paper towel on face, eyes and back of neck and wash your hands in cold water. While walking, choose a mantra (or positive affirmation) and chant in time to your step. Go out into nature and have a conversation with yourself and your Creator. At home, keep elevating music playing softly day and night. Recognize when you begin to feel out of balance emotionally or mentally. Drink some water, go to a private place, take long deep breaths and talk to yourself as your own best friend.”

“Kundalini Yoga” (ISBN 0-7513-0863-3) is a book I am glad I was attracted to. It was a learning curve and comes recommended. More information on Kundalini Yoga can be found at web sites <www.kundaliniyoga.com> and <www.yogibhajan.com>

by Richard Bunch

From Clive Peterson, Pattaya: A recent experience concerning the sending of attachments prompts me to write to you. I was waiting for some very urgent Pathology Reports from the laboratory in a well known Pattaya Hospital. The reports were to be scanned and then urgently e-mailed to me as attachments. The hospital staff did eventually manage to send the attachments to me, although they had great difficulty in so doing. When I finally received them, I could see what the problem had been. The attachments had been sent in TIF format and were each exactly 2.66 MB in size (they were only one A4 page attachments). When I sent them on, I reduced their size by opening them and then saving them in jpeg format. The sizes reduced to less than 60 KB and 40 KB respectively.

Perhaps you would be kind enough to give some step by step tips on the best way of reducing the size of scanned documents, bearing in mind that many people seem not to understand ‘zip’ and when faced with a very large file they cannot easily send as an attachment. It could also be worth giving an overview of different file formats such as bmp, etc. I am sure that other doctors of different disciplines to yourself would be most appreciative, as would the patients concerned, especially if time is of the essence.

Computer Doctor replies: I can appreciate it would have been somewhat difficult and time consuming for you to receive e-mails with such large attachments; it would have probably been quicker to have physically gone to the hospital!

Anyway, whenever sending files by e-mail it is both desirable and etiquette to reduce them to a manageable size. How this is achieved is rather dependant on both the type of file to send and the use the recipient has for it. One of the best ways to send information (which is what you had) whether or not it contains images in addition to text is as a PDF file produced by Adobe Acrobat. Although the full version is required to actually produce the PDF file, only the reader is required by the recipient and if it is not already installed on the recipients PC then it is only a small free download from the Adobe website http://www.adobe.com/products/acrobat/main.html

Just think of the number of manuals that are installed by programs and available on the Web that are in this format. To produce the PDF file all that is necessary is to select the output printer as Acrobat PDF Writer, give it a file name when asked and that’s it. The PDF file, however, cannot be changed by the recipient; this can have both advantages and disadvantages so if changes are required then a different option needs to be found. In the case of text documents the best solution is to ZIP the file using a utility such as WinZip, this also is a simple exercise and can be either achieved by using the ‘Wizard’ or ‘Classic’ interface. On the other hand if the file is an image/graphic then the best file type would be JPG at an acceptable quality level, there are many programs that will do this but one of the simplest methods is to open the image in Adobe Photoshop, reduce the physical dimensions if necessary to something not larger than A4 then select the Save For Web option. This will then show the file sizes and download times in several different qualities and formats, you then select which one is appropriate and save. Remember the smaller the file size is the less the quality will be so if the recipient wanted to print a photograph of say the new baby and the quality wasn’t appropriate it would look really grainy and pixilated.

Send your questions or comments to the Pattaya Mail at 370/7-8 Pattaya Second Road, Pattaya City, 20260 or fax to 038 427 596 or e-mail to [email protected]
The views and comments expressed within this column are not necessarily those of the writer or Pattaya Mail Publishing.

Richard Bunch is managing director of Action Computer Technologies Co., Ltd. For further information, please telephone 0 1782 4829, fax 0 3842 6335, e-mail: [email protected] or see the firm’s website www.act.co.th

Second Wind

Confusing new airport security measures and mobs of disoriented passengers in international airports served only to make my recent trip to the USA more of an adventure than I had first planned. But when does a writer shrink from adventure? Bulldozing my way through Chicago’s O’Hare International mouse-maze only made me more determined to catch my plane and arrive at a city in which I had never travelled before.

Atlanta, Georgia is a big corporate city, and after hosting the Summer Olympics a few years ago that success funded a facelift of a town which before had few distinguishing features. I found the center of town rather attractive and appealing. A few high-rise office buildings gleamed in the sunset as we flew in for our landing, and I was excited about meeting my friends who were there to pick me up. Since I actually had not seen them for nearly 20 years, I was smart enough to suggest we exchange recent photographs through email attachments before I arrived. Plans had been made for me to stay with an old friend who was recently divorced and was now a single parent of a teenage son, whom I had never met (the son, I mean). A younger brother who was 9 years old when we had last met would be in the greeting party, and an elderly uncle who was now 84 had agreed to join the reception committee. Naturally I was wondering if we would recognise each other at the baggage claim.

To be perfectly honest, I had been downing champagne since my boarding in Chicago. Unfortunately I had slept through most of the meals on the Pacific crossing from Tokyo, and the two and a half hour flight to Atlanta did not serve food. Starving and slightly drunk, I had visions of being so ‘blotto’ when I landed, that I would be left standing in the arrival lounge with my baggage and a terrible hangover, but no friends to claim me. Desperation always evokes courage. I waylaid a passing flight attendant just before the seatbelt sign went on and asked her if she could find something to eat in the galley, since my blood sugar was dropping faster than the plane’s decent. Next to my large and robust American seat mates, I must have looked positively cadaverous. Short flights across the USA do not serve food...okay. I got the message. But my disappointment was so alarming, she offered me a package of saltine crackers from her handbag. She couldn’t accept a ‘tip’, for that was against policy, but little did she know I would have traded my Rolex watch for those saltines had she been the least reluctant to part with them.

Fortified with those four stale crackers, I was pretty sure I could make it under my own steam while we landed and filed through the arrival area. Not sure how many calories are in a few bite-sized biscuits, I hoped they would fuel me far enough to find my luggage and my long, lost friends. The nice thing about American airports is the ample supply of wheel chairs. Of course you must book them in advance. But I figured if worse came to worse, I would just fall in a heap to the floor and lay there until a good Samaritan came along and scooped me up.

Little did I know that the Atlanta airport is just as big and confusing as any other in the nation. I trudged along with the crowds of disembarking passengers, who all looked like they knew exactly where they were going. Then we all came to one of those idiotic ‘trains’ which are supposed to transport passengers to their various areas of choice. Swarming into the cars, we grabbed what handles and straps we could snatch before the train took off with a jerk. As a seasoned ‘straphanger’ I held on tight, but the old lady next to me fell into my arms and scattered her handbag and its contents on the floor.

Good manners precluded that I help her scoop up the mess. Unfortunately in the melee I missed the garbled directions pouring out of the speaker that told us which stop would take me to my baggage claim and I inadvertently rode the train to the end of the line...and then back again. Right where I started. I was too proud to cry, by I swore under my breath like a sailor. Would my friends still be there waiting? Would they have the good sense to check the airline’s manifest if I didn’t show at the appointed place? Would I be eligible for permanent residence in Atlanta’s international airport? Would they at least grant me a green card till I was rescued? Now that! might be a possibility worth looking into. Still vowing not to cry, I stayed on the train and gave it another go. This time, I would keep my ears open and ignore an exploding bomb if it would get me to the proper exit. I was also determined to sober up and eliminate all cocktails on my future flights.

by John D. Blyth, P.O. Box 97, Pattaya City 20260

Frenchmen again

Last week I had things to say about three French-built locomotives used on the Great Western Railway from 1903 onwards. I do just want to make one more comment. Another writer on railways, the name is irrelevant as he is long dead, wrote that these three were ‘failures’. Now all can have their opinions, but I think he was wrong, if only for three reasons. Firstly, they were in regular service for 20 years with nothing more drastic than the provision of standard boilers and superheaters. Secondly, the same writer recorded a run from London to Lamington, 83 miles in 98 minutes, with a very heavy train for the period of 455 tons hauled by one of the larger Frenchmen. I find it easy to recall occasions when I would have been delighted at such a performance with a more modern engine with half the load! Thirdly, the authorities chose to use the small Frenchman for the inaugural run of the non-stop Cornish Riviera Express, 245 miles via the old route via Bristol non-stop. At the time, this was the longest non-stop run by any train in the world. ‘Failures’ disappear very quickly. And, too, ‘failures’ do not do well with man-sized trains.

No. 40 North Star as built as a 4-4-2, later converted to 4-6-0; Churchward’s first ‘divided drive locomotive’.

It is not the practice to put ‘failures’ on epoch-making runs as that with the Riviera. Just 50 years later I was on the platform at Newton Abbot to see the anniversary trains pass through, both hauled by King Class locomotives with at least some features in common with the little 4-4-2 that had taken out the very first non-stop train.

Churchward: what next?

‘GJC’ had decided that there was a place for both 2-and 4-cylinder locomotives for different types of express trains. He had more or less his 2-cylinder version, so what was coming for that with 4 cylinders? It was ‘North Star’, an ancient G.W.R. name. Like the ‘Frenchmen’, it was a 4-4-2 when a 4-6-0 might have been expected. A nice mixture of British and French practice! The drive was divided between the two coupled axles. Like the Frenchmen, the outside cylinders set well back and those for the inside cylinder set well to the fore. ‘GJC’ was a staunch believer in equal lengths of connecting rods. The valve gear was between the frames and was of an almost unique scissors type. This was based on the Belgian Stevart gear, much used in small coastal steam-ships but unusual in railway practice.

This made the movement of one valve partly dependent on movement of parts of the gear on the opposite side of the engine. Why it was not used again has not been explained. There is known to have been an objection from the engineer on another railway but more likely is the fact that the two sides of the engine were inter-dependent and were one side to fail, the engine could not move at all under its own power. ‘North Star’ kept this device until 1929 (22 years) and no record of any failure seems to be known.

‘Star’ Class No. 4060 of later build, working a Northbound train along the famous but troublesome coastal section near Teignmouth, Devon.

Long afterwards, the draughtsman who had developed it was heard to comment that he couldn’t understand why it had never been used again! The remainder of the ‘Star’ Class as they became known had an inside Walschaerts gear needing just one eccentric (whilst a Stephenson gear which ‘GJC’ might have preferred would have called for two for each cylinder). In due course North Star was converted to a 4-6-0 following one or two rather nasty bouts of wheel-slip that caused some damage. I am rather surprised that ‘GJC’ persisted with 4-coupled locomotives for so long: about the same date as North all 14 in all had in due course to be converted to 4-6-0s.

Seventy-three of the ‘Star’ Class were built up to 1924. Only small differences in dimensions, plus of course the provision of superheaters made any one differ from another. In due course all were numbered in order of building from 4000 upward. Their names were of celestial objects for the first eleven only. The rest of the class took names of prominent or titled people and the last few named after sacred buildings.

In 1910, No. 4005 Polar Star ran on the L.N.W.R. main line between Euston (London) and Crewe and showed the northern line how things ought to be done! Churchward’s classic remark at a directors’ meeting may have been a spur to this move. When asked why the L.N.W.R. could build three locomotives for the price of two at Swindon, he replied, “Because one of mine could haul two of their bloody things backwards!” At the same time as the G.W.R. locomotive went north one of theirs was used between London and Exeter on ‘Star’ duties and was hopelessly outclassed. I will also just note in passing that the G. W. R. sent, with the locomotive, a full set of working drawings - had they so wished the L.N.W.R. could have built a ‘Star’ of their own. Who could have foreseen the day when they might be asking the Great Western to build them some very similar (but larger) 4-6-0s - and were refused?

A number of ‘Stars’ were withdrawn after relatively short lives as money was available in a renewal fund. Some others were rebuilt into the next ‘size’ of 4-6-0, the ‘Castle’ Class’ that became standard from 1923. Most had functional working lives of upwards of 40 years. And most of that down fighting as it were still turned in first class work. Records show that the intention was there to convert all to ‘Castles’ but the intervention of war stopped the programme, thus it was never completed.

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