In this Forum session, Peter W. Dunn, a founding member and spokesperson of the Isaac Brock Society, speaks on the human consequences of FATCA, discussing the HEART Act as well, illustrating these consequences with examples of the financial, emotional and physical hardships sustained by persons the US Treasury Department defines as “US persons,” although they are not resident in, and in some cases not even citizens of, the United States.

This is part 8 of the 9 part FATCA Forum.  Calgary411 and I are preparing the transcripts and they will be posted on Brock as they become available during the coming days.

The text of Mr. Dunn’s presentation follows below and the transcript is also online as a PDF document.

MR. JOHN RICHARDSON:  Okay. So, we’re back at it.  And the, I guess, final section of the day, possibly final speaker of the day is a person of, I think, tremendous importance in terms of having created awareness on this whole issue in Canada, having provided a community for people who have been so desperately affected by this.  I mean, you know, there are the tax issues, there are compliance issues, there’s the fear factor, there’s the emotional fallout.

And I’d like to introduce you, after giving a brief introduction, to Peter Dunn, who is the, if not the founding member of the Isaac Brock Society, certainly I would say the voice and continuity of the Isaac Brock Society.  Peter is a PhD Divinity from Cambridge University.  He has lived in Canada since I believe 1986.  Am I right on that?  More or less.  Hales from Anchorage, Alaska.

And I don’t think it’s – you know, it’s one thing, you know, you can go through a day like this and talk about FATCA in a purely technical sense as though it’s a clinical kind of thing, but behind the whole FATCA thing, behind the whole citizenship-based taxation thing, are an awful lot of people and families who have been affected by this on an individual basis.  And Peter Dunn and the Isaac Brock Society have done more than all of the other participants combined to provide a meeting ground for these people affected by it, a voice, et cetera.  And so, there are a number of issues that he’s going to talk about and engage you in.

And please join me in welcoming Peter Dunn.

MR. PETER DUNN:  Thank you, John.

I have these prepared notes, but I think I’ll just talk a little bit about my experience.  John wanted me to talk about the experience of relinquishing myUnited Statescitizenship.  Let me explain why I did that.

In 2010, my lawyer handed me an article about the HIRE Act [correction:  the HEART Act (2008) not the HIRE Act (2010) was meant].  Now, nobody’s bringing up the HIRE Act here.  What is the HIRE Act?  It was what I call the New Berlin Wall, which said that if you had over $2,000,000 in assets or $134,000 in tax liabilities that you would become what’s called a covered expatriate and there would be consequences for that, including anything above $600,000 in capital gains would have to be paid – well, let me explain, you have to first mark-to-market all of your assets, and then anything above $600,000 in capital gains, you would have to pay very steep taxes on, 45 %, I believe if I’m not mistaken.

Now, my assets were a little bit less than $2,000,000, maybe a lot less than $2,000,000.  However, I’ve been a do-it-yourself investor for the last few years and I noticed that I was doing not so badly.  I also noticed that my house – we bought it for $200,000 – in Vaughan is now worth $400,000 at that time.  It’s now worth $460,000.  Thank you zero-percent interest rates.  But I saw that my assets were rising very quickly.  And I also noticed that the US dollar was going down, because when we first bought the house, the dollar was at about $1.35 against the US dollar and now it was on par or slightly above par.

So, my lawyer handing me this article about the HIRE Act [correction: the HEART Act was meant] got me to thinking, you know, maybe this dual citizen – I was just a US citizen at the time.  I hadn’t become a Canadian.  This isn’t really a very good deal for my wife.  She’s Canadian.  There’s no reason why she should have to pay a percentage of her assets if I decide to lose my US citizenship.

So, that very thing, this law, the HIRE Act, which was designed to keep people from renouncing their US citizenship, was the very thing that caused me to renounce my citizenship, because I decided that I better get out while the getting was good.

So, I immediately applied for Canadian citizenship.  Now, I was going to do that anyway before the next PR card came up, you know.  I hate filling out paperwork.  That’s the biggest thing I hate.  And so, the five pages of the PR card form – form, forms, I hate them – I decided next time I’m just going to apply for citizenship, then I’ll never have to apply for another PR card.

Well, I did it.  I applied for citizenship,  And in 2011, February 28^th, I became a Canadian citizen.  And I went up to the judge and I said to her, “I want you to know that I’ve become a Canadian citizen, but at this moment I also relinquished my United States citizenship,” because becoming another citizen of another country or making a pledge to a foreign power is considered an expatriating act, that if you do it with the intent to lose your United States citizenship, then you lose your United States citizenship.  So, you have to have the intent to lose it.   And I did so.  And I went up to the judge.  And Andrew was videotaping it, so we know that we had a record that I said to the judge I was relinquishing myUS citizenship.

And the reason why I did that was because there’s now a $450 charge to renounce your US citizenship.  And that’s because you have to engage the services of a United States consulate officer to accept your renunciation.  So, they think that’s worth $450, which is quite a violation of the Universal Declaration of Human Rights, which says that no one shall be denied the right to change their nationality.  So, the United States, which was one of the nations which was most instrumental in creating the Universal Declaration of Human Rights, never ceases to violate those rights, particularly when it comes to their own citizens.

So, that’s my story of why I relinquished my United States citizenship.

I have to say that one of my motivating factors is the protection of my family.  I mean I have my wife Cathy and four cats.  We don’t have any children but still that’s family.  And my wife is the owner of a Canadian company.  They overhaul wheels and brakes and airplane propellers and she employs, along with her brothers and her parents, over 30 Canadians.  And I don’t understand why a Canadian employer should be exposed to taxes from a foreign country.

So, in order to protect my wife, I had to relinquish my birthright.  You realise it’s a birthright.  If you’re born in a country, you have a right to live there, okay.  But because of the stupid idiots in Washington, I had to give up my birthright.  Okay.  That makes me angry.  Okay.  That makes me very angry.  But, okay, I accept it.  I love Canada and I’ll fight for Canada and I’ll defend Canada.  If any Americans try to cross the border this time in the War of 2012. I’ll be there.  Hopefully —

—        LAUGHTER

COMMENT/S FROM AUDIENCE (off microphone): (inaudible).

MR. PETER DUNN:  Well, James, he’s good.  I say as long as y’all come up here friendly-like, we’ll be okay.

But I’ve said that many times, that my loyalties have changed.  My loyalties belong to Canada.

And let me say that I was trying to hide in the shadows, just like all of the other people at the Isaac Brock Society.  They all blog there or they comment using aliases.  There’s numerous reasons why they do that.  That way they can reveal certain private details of their experiences as Americans living in Canada or Switzerland or Hong Kong, New Zealand– people from all around the world are commenting and blogging at the Isaac Brock Society.  We have had 34,000 comments so far in just one year, 1,000 blog posts, and we’re keeping abreast of the issues of the United States taxation, the Foreign Bank Account Report and the FATCA law.

And let me tell you a little bit why I came out of the shadows, and this is one of the reasons why I have spoken to numerous reporters in the United States; not so much in Canada, but American reporters seem to be much more interested in my story.  It’s because I’m one of the few people that’s willing to come up with my name.  Oh, yeah, my name is Peter Wallace Dunn.  I live, you know, you can find where I live.  And I’ve had the audacity, if you will, to stand up and speak out against this.  Most people are afraid to.

But a few months ago, over a year ago, Jim Flaherty came out with his announcement that, you know, when – If you’re a Canadian citizen, we will not collect taxes from you, okay, and if you’re a resident of Canada, no matter what your citizenship is, we will not collect Foreign Bank Account Report fines or FBAR fines.

Now, nobody’s talked about Foreign Bank Account Report much.  The Foreign Bank Account Report is a 40 year old law that was never really enforced for about 40 years, until about 2009, when the United States opened up a programme called the Overseas Voluntary Disclosure Program.

Now, this law requires that you report your bank accounts to the United States Treasury, and if you don’t there is a non-willful fine of $10,000.  Now, we’re not sure whether that’s $10,000 per violation or $10,000 per account.  Now, some of you can all count up the number of accounts that you have.  I don’t know, I have about, oh, fifteen.  Could I afford a $150,000 fine for not reporting my accounts?

However, the willful fine is unbelievable.  It’s 50% of your bank account, 50%.  And, guess what?  There’s a six year statute of limitations, which means that not only would you owe any taxes and fines and interest due on your account, but you would also owe 50% of the highest balance of your account each.  So, potentially you could owe up to 300% of your financial wealth to the United States Treasury in willful Foreign Bank Account Report fines.

And let me tell you something.  I am in wilful non-compliance because I said to the United States government on the blog several times I will not come into compliance with this law because this law is a violation of the Fourth Amendment and the Fifth Amendment and the Sixth Amendment and the Seventh Amendment and the Eight Amendment of the United States Constitution.  Okay, I could go through all of those, but I have a blog post on each one of those on the right hand side of the column.

But let’s just start with the Fourth Amendment.  The Fourth Amendment says that in order for the Government of the United States to get information from you they have to tell a judge why they think that you may have broken a law.  And that warrant has to have your name on it and the place that’s going to be searched.  Now, FBAR isn’t that.  It’s just simply, “Hand us your information.  We don’t care who you are.  If you’ve got a foreign bank account, we don’t know whether you committed a crime, but we’re fishing.”  It’s all about fishing.  They’re fishing for information.

So, this is why the Government of Canada must not enter into an Intergovernmental Agreement because they have indicated to the world what they’re going to do with FATCA.  What is the purpose?  Is it to get some fat cat in the United States?  No, it’s to be able to fine people who have bank accounts 50% of their bank account.

Okay.  So, now we were told that we didn’t to give them this information because they don’t need the information.  But they do need the information.  Have you seen the budget deficit in the United States?  Have you seen it?  Well, let’s see.  What was it the last time I looked?  1.7 million dollars is a good – million – trillion.

COMMENT/S FROM AUDIENCE (off microphone):  Trillion.

MR. PETER DUNN:  Well, we don’t know from millions and trillions.  I mean it’s such a big number, what’s the difference.  One point seven (1.7) trillion, that’s what they’re on board to be overspending this year, according to how much they’ve overspent thus far in the first three months.

COMMENT FROM AUDIENCE (off microphone):  (inaudible) 16 trillion dollar (inaudible).

MR. PETER DUNN:  Well, there’s already the 16 trillion dollar debt, but that will never be paid back.

So, okay.  So, getting back to the whole reason why they want FATCA is so that they can get the account information of American persons living in Canada and so that the Treasury Department can then send 50% fines to each person.

Now, how do I know it’s going to be 50%?  Because if you go onto the Voluntary Disclosure Program Fact List of the Frequently Asked Questions on the IRS website, they say, “Why should you enter the Overseas Voluntary Disclosure Program?”  It’s called OVDP.  Why should you enter this?  Because the Voluntary Disclosure, this Program, is a little la-la land where you give up all your rights, just like we’re going to give up all out treaty rights, we’re going to give up all our constitutional rights, our Fifth Amendment right, our Fourth Amendment right and so forth.  Okay.  And then we’re going to tell the IRS all about our bank accounts and how much tax we didn’t pay, and then we’re going to pay all our fines and up to 27.5% fine of our financial assets, in the Voluntary Disclosure Program.

Now, in the FAQ, it says – that’s Frequently Asked Questions – “Why should you enter this program?”  And the answer that they gave is very interesting for the purposes of our meeting.  The answer was, “Because if you don’t, we’re going to find out anyway, and when we find out, you’re going to be paying the bigger fine.”  And how much is the bigger fine?  Fifty percent (50%).

Now, what do you think?  It’s a good idea for the Government of Canada or the banks to give over our account information to the IRS so that the IRS can assign American citizens – many of whom are – most of whom are Canadian citizens – 50% fines?  I don’t think that’s a good idea, you know.  There’s a million of us, something like that.  I don’t know what the dollar amount would be, but I shudder to think.

You know, when Flaherty came out and said, “We will not collect the FBAR fines,” the United States uses other forms of pressure to try to collect these.  My dad lives in the United States and my brothers and sisters are worried about him because he’s starting to show signs of Alzheimer’s.  Wouldn’t it be nice if I could go visit my dad, but I blabbed off my mouth and now I’m a little bit scared cross the border.  Okay.  So, if it comes to it, I’ll have to ask my sister, who’s a lawyer in Anchorage, to get a – do a search and find out if there’s a warrant for my arrest.  Now, what am I doing?  I’m just trying to get Canadians to be courageous and stand up to the United States.

So, this is what Flaherty said.  He said, “We going to not collect the FBAR fines.”  So, I came out.  I knew my financial wealth was safe because all of my accounts are in Canada.  I pulled all my investments out of the United States or decided to write them off.  Okay.  And so I came out in the open so that people know who I am, and this is how I’m leading the Isaac Brock Society in the sense of I’m setting an example.  I think we should all come out of the shadows.  You’re going to arrest one million of us?  I don’t think so.

But anyway this is – but let me get back to what Flaherty said.  He said this in order to protect Canadians.  I understand that.  It is a job of a government of an autonomous sovereign nation to protect the residents and citizens of that country.   He said this because of the draconian nature of the threat of the United States FBAR fines, FATCA, and so forth.

Now, let me tell you something.  In my view, there’s been a lot of damage done already.  Okay.  So, this level of protection isn’t enough.  Because in my view, what Flaherty was saying is that, “You guys out there.  Stand up for yourselves.  You’re Canadians.  Don’t give in to the pressure.”

Okay.  So, basically Flaherty is asking all of us to be Clint Eastwood, “Go ahead, make my day!”  Okay.  And I don’t look like Clint Eastwood but I think I have a little bit of his attitude. “ Go ahead!  Make my day!  Okay.  Yeah.  Yeah.  Right.  Pay you $3,000.”  That’s the bill I got a few months ago.  I said, “Hell no.  Hell no.  I’m not going to pay one penny.  I might spend the money for a stamp to tell you my reasons why I’m not going to pay you any money, but I begrudge even that.”  Okay.  So, I begrudge paying for a stamp.  We faxed the information.  Eventually they said I don’t owe anything.  Okay.  Great.

But the problem is that we’re not all Clint Eastwoods.  The people that I’ve talked to on the phone are far from it.  They’re worried.  They’re scared.  They want to get rid of the United States citizenship.  But you know I was just talking to one lady.   She said, “But if I do that, then I’m going to have to expose my finances to the United States.”

So, it’s a scary situation for them.  And now FATCA’s come along and scared the hell out of everybody because now – you see, the thing is, before, if you didn’t tell the United States, they didn’t know about you and they didn’t care.  Okay.  If you didn’t file your taxes, if you didn’t file your FBARs, they don’t know anything about you.  I’ve talked to hundreds of people – maybe not hundreds – I’m exaggerating – a half dozen people who say, “I don’t even have a social security number.”  Well, good, you don’t want a social security number, because if you don’t have a social security number, you don’t exist – okay – as far as the IRS is concerned.  And you don’t want to exist as far as the IRS is concerned.  Okay.

So, but they’re afraid.  They’re afraid that their bank is going to rat them out and tell the United Stateswhat they have in terms of assets.  You know, I talked to one lady in Québec.  She had $30,000.  Wow!  The United States is so desperate, the richest country in the world, and they need to know about the bank account of some lady with $30,000!

Well, they said, “Okay.  If it’s less than $250,000, then the bank doesn’t have to rat them out.”  Right.  They still have to file FBAR as the FBAR threshold was made 40 years ago when ten thousand dollars  ($10,000) was worth four hundred thousand ($400,000).  But they haven’t raised the threshold yet, so even people with minimal, tiny little assets – it wouldn’t even pay one minute for the government to run on $10,000, you know, not even one minute.

Jim’s going to figure this out.  How long could the United States Government run on ten  —

COMMENT FROM AUDIENCE (off microphone):  (inaudible) seconds.

—        LAUGHTER

 MR. PETER DUNN:  Not even one minute.  I’m sure it’s not one minute.

So, let me tell you a couple stories from the Isaac Brock Society to just give you an idea of why it’s important that we refuse the governmental deal and why it is that I believe that the Tory government – and I’m not being political here – because I don’t care what party it is, Green Party, PC Party, Liberal Party, NDP, Tory government.  I don’t care as long as you’re on our side.  I’m like that guy from the Lord of the Rings, the Ent you know.  He was asked, “Well, whose side were you on?”  He says, “I’m not on anybody’s side because nobody’s really on my side.”  This is what I think.  We have one side in this issue and that’s the Canadian side.

This is why the current government hasn’t protected Canadians enough —

COMMENT FROM AUDIENCE (off microphone):  (inaudible) Progressive Canadian (inaudible)

MR. PETER DUNN:  Progressive.  Progressive Canadian side.  Yes, of course.

— because there’s still some people out there that are not Clint Eastwoods.  They’re not the kind of people that are going to stand up to injustice, but they’re going to try to obey the law.

So, we know somebody.  She goes by the moniker, alias, Calgary411.  And a few decades ago, she moved toCanadaand when she became a Canadian, she was told that she would no longer be an American.  That was theUnited Statesgovernment.  It was telling everybody that.

So, then a few years ago, maybe three years ago, she was trying to cross the border and they said, “Look, lady, you have a US birthplace.  You’re supposed to come into US with a US passport.”  She goes, ”But I’m a Canadian.”  You know that’s how she talks (inaudible) , “I’m a Canadian.”  She’s not Clint Eastwood.  She’s not, “I’m a Canadian!”  And that’s the way you have to answer those guys, “I’m a Canadian!”  If you do it that way, then they say, “Oh, okay.  Okay.”  They back off a little bit.  But she’s, “But I’m a Canadian.”  And so they said, “No, you’re an American.”

Well, there was this one guy that went to the border and they said, “You’re — you’ve got a US birthplace.  You’re supposed to come here on a US passport.”  And he said, “I’m a Canadian.”  And they said, “Look, sir, you’re an American until we tell you you’re not!”

So, she went and got a passport, even though she didn’t think that was right.  She got a US passport.  And then after the fact, she found out about all these compliance issues, about taxes, and she’s supposed to file her taxes and her FBARs, and everything.  And so, she spent the last two years trying to figure out what to do.  She spent thousands of dollars in legal fees, figuring out what’s she going to do about renunci – now, she’s renounced her citizenship.  But this is a terrible situation.  I mean, you would – I almost weep sometimes when I read the stories of people.

And she has a mentally disabled son and she can’t renounce for him.  They say that he’s not mentally competent, therefore he can’t renounce, but you can’t renounce for him either.  So, he’s going to be a US citizen for the rest of his life.  So, when Calgary dies and she leaves her money to her son, will he have to file FBAR reports?  These are questions that the government should ask?

Oh, how about this story?  Bubblebustin, that’s her moniker.  You know, nobody wants to use their real name.  I talked to her on the phone.  She sold her house inVancouver.  You know,Vancouver real estate’s gone up a lot.  It’s nice if you bought a house forty years ago, I guess.  And it’s a bit too much because her personal allowance for the United States taxation, from their point of view, is $250,000.  Her house in Vancouver was worth more than that.  And she didn’t know about taxation, that she was supposed to file her taxes in the United States.  So, she entered the Overseas Voluntary Disclosure Program.  And in the process of doing her taxes, she found out that she had to pay $70,000 in United States taxes and fines for the proceeds of the capital gains on her house.

Now, I don’t know if you know this, but in Canada– you probably all know this – your primary dwelling is – there’s no capital gains tax on it.  So, if you’re a US person in Canada, this is what you can be sure.  The few tax breaks that you get in Canad awill be taxed by the United States, because you didn’t pay taxes in Canada, then you didn’t pay enough taxes.  And even the foreign tax credit that they give you isn’t enough to cover the taxes on the house.  So, she had to pay $70,000.

Now, the thing that gets me mad about this is that the house is in Vancouver.  What does that have to do with the United States?  The person lives in Vancouver.  She works in Vancouver.  Her money is all made in Canada.  Why should she pay any taxes to the United States.  I don’t understand that.

Then there was the story of Late Loyalist.  This is just to give you another angle.  Not a very wealthy person.  He had some money from an inheritance that went into an account and then it went out to pay debts, probably his mortgage debts.  Okay.  And he didn’t know about the compliance issues either.  So, he entered into the Voluntary Disclosure Program and he ended up paying only a 5% fine.

Now, this is one of the things.  If you’re a Canadian – or if you’re living in another country and you didn’t know about your filing obligations, your FBAR filing obligations or you didn’t even know you were an American, you’re what they call an Accidental American, you didn’t know you were an American – I mean can you believe this? – you’re supposed to file stuff even if you don’t know that you’re an American.  I mean this is how ridiculous it is.  Come on.  This is funny.  This would — this is really – John —

MR. JOHN RICHARDSON:   (inaudible) that note, the position of the IRS and the Voluntary Disclosure Program – are you ready for this – is that if you did not know that you were a US person and you can satisfy the IRS of that, then they will permit you to come into compliance by paying only 5% of your world assets.  So, just in case the message isn’t clear, stay out of the Voluntary Disclosure Program.

MR. PETER DUNN:  Yeah, stay out of the program.  And I guess because they didn’t think he was wilful or anything, they decided to give him the 5 % fine.  So, his fine was under $3,000.  So, you can see he’s not a rich person.  Because all you have to do to figure out what his wealth in his bank accounts was is to simply take 3,000 and divide it by .05.  Okay.  You don’t come up with a big number.

Now, the interesting thing about it is he had to get a mortgage on his house – or get a second mortgage on his house in order to pay the lawyer’s fees, which were over $21,000.

Okay.  Do you think Flaherty is protecting – is the government of Canada protecting people?  And these are not wealthy people.  These are people who are having to take mortgages on their houses in order to pay their legal fees or their accountants or their taxes.   Okay.

So, I just wanted to bring this angle of the story in, because we’ve had some really, really smart people talking about lawyers and the law and international law.  I mean I’m just amazed at how smart the people are who have talked today, including Jim Jatras.  I’m so thankful that you’re here.  But I want the Progressive Canadian Party to know the stories on the ground, how people are suffering already.  Okay.  This is suffering, I think, in the thousands.  Why is it in the thousands when there’s a million Canadians who are allegedly US citizens?  It’s in the thousands because most people, the media, they’re not paying attention to this issue.  Okay.

When FATCA comes through – that is if FATCA is implemented, then this will be in the hundreds of thousands of people that will be suffering because of the United States citizenship-based taxation.  People living in Canada, they’re your neighbours, they’re your relatives, they’re people that you know.  And we need to protect them.  This country needs to protect its residents and its citizens.

So, if you read the stories about – we had this one thread, “Has your life changed since you found out about FBAR and US taxation?”  People wrote, “I can’t sleep anymore.”  “I’m on anti-depressants.”  “I feel like killing myself.’

Okay.  Is it suffering when you feel like killing yourself?  I mean how do you measure how much suffering people are going through?  I think it is.  I think it’s suffering.
Okay.  So, they’re not rounding us up and taking us down to Guantanamo Bay and torturing us?  But if you actually push people into the situation where they’re so depressed that they can’t eat or they can’t stop eating and they feel like killing themselves, then you’re torturing them through another means.

And I’m sad.  I’m sad about that.  And I would really, really appreciate it if the government of Canada stood up for the people that live in this country in a way that protects Bubblebustin, Late Loyalist and Calgary411, because they’re not all Clint Eastwoods, they’re not all people like me that stand up and say, “Go ahead!  Make my day!”

—        APPLAUSE

 MR. JOHN RICHARDSON:  Fantastic, Peter.  A great trial lawyer, American trial lawyer, Moe Levine, his whole life he tried personal injury cases and he used to give these amazing closing addresses to the jury.  And what he frequently would close with, if somebody was badly injured and their life had changed, he’d say, “You know, it’s not what you take from somebody.  It’s what you leave them with.”  And this is incredibly effective and he often had the judges crying.  “It’s not what you take from somebody.  It’s what you leave them with.”

And what Peter’s described here with these particular people really would be just the tip of the iceberg.  What the US government has unleashed – I opened this today by showing you a one-minute clip of President Obama talking about overseas bank accounts and trying to equate them all with tax cheats – has been nothing short, but, you know, just a reign of terror on people, who are really, I think, unable to protect themselves.  And interestingly, the ones that are most worried are the ones that are most likely to be law-abiding to begin with.

And this is the result of what they would call citizenship-based taxation, which I would call the immorality of citizen-based taxation.  And I think that on the ground one needs to understand that what FATCA really is, is an attempt on the part of the US government to force other countries, to force other countries, to actually enforce the immorality of what this has become.

Now, I am of the opinion – and this is my personal opinion, but is something that I think is worth developing – that I think that one can say that citizenship-based taxation per se may be okay, it may not be a human rights issue, but the way the US is applying citizenship-based taxation to your friends, your neighbours, people who have lived in this country all of their lives, and if you see the effects that Peter has talked about is, if it’s not there, it’s moving perilously close to a massive human rights violation.

There’s a million people affected in Canada, if you just look at their US person-ness, so to speak.  Add to that their families.  You know, you talk about these fines that people have paid, these legal fees.  These are things that come out of families that include far more than just so-called US persons, and this cannot be ignored.

It is absolutely essential that people understand the relationship between FATCA, the relationship between a proposed IGA, and this issue, that what any country does who acquiesces in this is to simply participate, turn a blind eye, participate in something that I believe has reached the point – when people are talking about killing themselves, they can’t sleep et cetera – into a massive human rights violation, a massive human rights violation.

And I think that it’s a good thing to actually close with what Peter said today because, you know, the technicalities of this are one thing – the compliance costs, the big four accounting firms – but behind every one of these things is a real person whose life has been turned upside down.  It’s like, it’s almost like one of those then-and-now moments (inaudible) have to live with this stuff.  And it’s incredibly difficult.

Make sure that you try to explain, that you tell everybody in your community about what the government is proposing here, because not only is it essentially turning the sovereignty of the country over to a foreign power, but it’s doing it in a way that is going to guarantee massive, massive suffering on the part of innocent hard-working people.  Their only crime has been to save for retirement, investing in mutual funds, trying to invest responsibly.  These are the people who are suffering.

Peter, that was great, motivational.  I think we’re more or less at the end of the day, subject to any questions.

Thank you for coming.  And as I said earlier, I really think that this is – that we are seeing a, you know, what’s a significant moment and sort of a sea change in history.

Thank you.