– from Star Wars: Episode V – The Empire Strikes Back (1980)
February 1, 2013
Two weeks after the release of purportedly final regulations on foreign financial institutions (FFIs) to implement the Foreign Account Tax Compliance Act (FATCA), the predictable (and predicted) chorus of hosannas from compliance vendors is in full swing. Faced with 544 pages of mind-numbing and confusing mandates (up from the draft of “only” 388 pages of last year), vendors literally banking on a FATCA compliance goldmine are renewing their call for FFIs to fall into line and pay up.
While the FATCA compliance vendors are no doubt doing quite well for themselves. It comes at the expense of firms (some of which expect to spend $100 million each to comply with FATCA. They already have dozens of employees solely devoted to that task) – and of course of consumers, onto whom these expenses will be shifted. It isn’t clear that FATCA itself is doing as well.
Why? Because the U.S. Treasury Department’s ability to enforce FATCA directly, on each and every FFI on the planet is highly questionable. Instead, they need the active cooperation of foreign governments who have to be scared into signing intergovernmental agreements (IGAs), whereby the foreign “Partner” (as euphemistically termed in FATCA-talk) will enforce this American law against its own institutions and citizens.
So far, however, Treasury’s actual achievement in obtaining signed IGAs continues at a slow pace, as noted by Nigel Green, CEO of deVere Group. This is a particular problem with respect to major countries in Europe and elsewhere which require at least the appearance of even-handedness in the form of the so-called “Model 1” version of the IGA, which promises data exchange with the U.S. based on “reciprocity.”
Pretense of “reciprocity” exposed
No one who has read “Model 1” IGA (such as the agreement signed with the United Kingdom, unsurprisingly the first country to submit to Washington’s diktat) has any illusions that the supposedly “reciprocal” agreement is anything of the sort.
While pursuant to Article 2(a) of the IGA the non-U.S. “Partner” governments must force their FFIs to provide what amounts to FATCA’s entire spectrum of invasive and expensive-to-collect financial data on “U.S. persons,” wherever they may be resident, the American side promises (pursuant to Article 2(b)) to provide only information on certain interest “Partner”-country residents derive from domestic U.S. institutions.
What is the reason for the mismatch on what is supposed to be a two-way street?
The Treasury Department claims it is providing under Article 2(b) of the IGA only information pursuant to authority they already have under current law. (As will be further discussed below, even that claim is already subject to challenge from some in Congress.)
But that’s OK! Under Article 6(1) of the IGA, the Treasury Department solemnly promises the “Partner” government (here, the UK) that the asymmetry between U.S. and “Partner” obligations is only temporary:
Reciprocity. The Government of the United States acknowledges the need to achieve equivalent levels of reciprocal automatic information exchange with the United Kingdom. The Government of the United States is committed to further improve transparency and enhance the exchange relationship with the United Kingdom by pursuing the adoption of regulations and advocating and supporting relevant legislation to achieve such equivalent levels of reciprocal automatic exchange. [emphasis added]
It would be hard to suggest with a straight face that the “Partner” country officials who negotiated this deal actually believe this commitment any more than the U.S. officials who made it. Chances of implementation and passage of such legislation are slim to none, and they all know it.
But at the same time, it’s important that the public façade of “reciprocity” be maintained that this is a genuine, mutually beneficial exchange.
What’s really going on: It’s one thing for the officials on both sides to acknowledge with a wink and a nod behind closed doors what’s really going on – the capitulation of the “Partner” to a unilateral U.S. demand, backed up with the threat of sanctions. But letting the whole wide world know that is another thing entirely.
In particular, it’s essential that citizens of the “Partner” country be kept in the dark that their government is not only compromising their sovereignty (par for the course) but is sticking them with a massive bill for higher consumer costs and for tax funds used to enforce FATCA domestically – and not even getting much of anything in return.
Recently, however, somebody blabbed:
Although the United States has committed to achieving reciprocity regarding the exchange of financial transaction information under the Foreign Account Tax Compliance Act, domestic banks are not subject to the same reporting requirements as are their foreign counterparts, an Internal Revenue Service official said Jan. 25.
According to Ted Setzer, manager of IRS’s Large Business & International Division, although existing requirements on U.S. banks will provide other governments with similar information required of foreign banks under FATCA, “clearly existing U.S. rules don’t require U.S. financial institutions to provide the exact same information that a foreign institution has to under FATCA.”
Responding to a question about reciprocity, Setzer said the United States had committed to such a concept. However, U.S. reporting rules for domestic banks “are what they are,” and do not require identification procedures identical to those required under FATCA, he said,
“How we get to full reciprocity and how long it takes is something we’ll have to be working on,” Setzer said.
[“Full Reciprocity Under FATCA Is a Work in Progress, IRS Official Says,” Bloomberg Law, 1/28/13]
Some have been critical of Mr. Setzer for having the bad manners to speak something like the truth out where it could be reported to those not familiar with the imbalance solemnized in the IGAs. But putting aside questions of indiscretion and the vague characterization of a time frame for “full reciprocity” – something that clearly isn’t going to happen anytime soon, and probably not ever – it’s nice to have confirmed officially what most people familiar with the details prefer to obscure.
Take the best deal on offer – until we change the deal . . .
Even with this built-in imbalance of obligations, many countries may still regard an IGA as the best protection against direct, extraterritorial FATCA enforcement by the IRS. Indeed, the more burdensome and onerous the regulations, the more terrified FFIs will clamor for their governments to sign an IGA (and push their own citizens and consumers under the bus) to avoid them. This threat was bluntly set out in an unpublished comment by one professional who admits FATCA is “ill-conceived” but still applauds Treasury’s strong-arm tactics, wielding their scary 544 pages as a club.
In retrospect: the parallel track of IGA’s and individual FFI agreements for banks in countries where there is no IGA, really represent a tremendous PR coup for the US Department of the Treasury! On the one hand, the FATCA Regs. which have no substantive applicability to the new procedures under the IGA’s, are a good reminder of how truly miserable the IRS can make your life if you are one of the unfortunate banks in countries where the IGA process has yet to begin. Five hundred and forty four boring detailed pages of what the IRS expects you to do if you indeed have the misfortune of being a bank in a non-IGA jurisdiction which has to enroll and register individually with the IRS to be a withholding agent for the United States government. It is as if the Treasury were saying to the whole international financial community: “just wait and see how tough we can get if you have sign up as a withholding agent. You would be best advised to get after your respective governments to step up and be a player so you can self-certify your compliance with the AML and KYC rules AND NOT have to deal directly with us.” [emphasis added]
Surely, Treasury officials themselves use more diplomatic language when talking with their foreign counterparts. But as with Mr. Setzer, openness is a virtue – in this comment, about the unvarnished threat impelling countries to sign IGAs that are all cost, no benefit.
The Only Benefit: Indeed, about the only real benefit a “FATCA Partner” country can hope to secure in signing an IGA is the prospect of having certain categories of industry or financial products of particular importance declared as a “deemed-compliant FFI or as an exempt beneficial owner” under FATCA, and therefore listed on Annex II of the IGA and relieved of FATCA compliance requirements. This is a significant draw for signing an IGA for a number of countries who want their pension plans exempted from FATCA.. . . which we can do any time we want.
The trouble is, exemption of favored industries of products under an IGA actually is no protection at all.
First, in issuing the final regulations, the Treasury Department already has exempted “certain retirement funds, life insurance and other ‘low-risk’ financial products held abroad, which are not considered havens for dodging taxes, are exempted from reporting their U.S. account holders’ information to the IRS.”
So one might think that the incentive to sign an IGA to protect key industries may be reduced. On the other hand, for some jurisdictions, even the final regulations “confuse rather than clarify” on that point, so some industry is still pushing for an IGA “to provide further clarity” and specifically include “in the annex to the IGA . . . a list of exempt institutions/products.” Or to put it another way, even after issuance of the “final” regulations, vagueness and fear remain Treasury’s key tools for pushing countries into IGAs.
Secondly, an IGA provides no protection at all for one additional, simple reason: they are written on sand. The U.S. unilaterally can cancel the IGA at any time with one year’s notice, for no reason whatsoever, and leave the “FATCA Partner” and its FFIs faced with ‘original FATCA’ and the full 544 pages of regulations! Under Article 10(2):
Either Party may terminate the Agreement by giving notice of termination in writing to the other Party. Such termination shall become effective on the first day of the month following the expiration of a period of 12 months after the date of the notice of termination.
But surely the American side wouldn’t do this . . . would they? After all, some governments believe an IGA binds the U.S. in a manner comparable to a treaty obligation (here, from an unpublished response to a constituent from a working group in an aspiring IGA “Partner” government):
Any intergovernmental agreement would be an extension of the existing double tax agreement and would build on its information exchange mechanism. Once any tax treaty has been signed and is in force, it cannot be changed unilaterally – all changes must be made by mutual agreement or by renegotiation. This rule would also apply to the intergovernmental agreement. [emphasis added]
Such assurance is entirely illusory, for at least two reasons:
First, from the U.S. side, an IGA is considered an “Executive or Competent Authority Agreement,” which emphatically is not a treaty or binding on the U.S. in the same way a treaty is.
Treasury deftly has come up with IGAs – which are not even provided for in the FATCA statute – as a way to cajole other countries into enforcing FATCA on themselves while bypassing Congress entirely.
By contrast, for many “Partner” countries, especially those with parliamentary systems (unlike the U.S.), the IGA must be put through treaty ratification procedures and then legislatively codified in domestic law.
In a nutshell, the “Partner” would lock its obligations into stone, while the U.S. “obligations” amount to the whim of the U.S. Treasury Secretary.
Second, as noted above, the right of the U.S. to terminate the IGA under Article 10(2) amounts to an effective ability to change its terms at will. (Of course the “FATCA Partner” has the right to terminate as well, but as the party seeking protection from the threats of the other party, that’s unlikely.)
Once an IGA is signed, the Treasury Department easily can come back in a year or two and say, “Alright Partner, we want to cut back on our over-generosity on Annex II and require compliance of your precious pension plans and some other FFIs we earlier agreed to exempt. Oh, and we want to lower the reporting amount from $50,000 to $10,000. If (now that you’ve capitulated anyway and recognize who’s in charge around here) you balk at changing the rules or at our revocation of some temporary concessions, you can just go back to Square One and comply directly with the 544 pages of regulations. It’s your choice – Partner.”
Any guess which way the “Partner” will jump?
Congressional action could be fatal to IGAs – and to FATCA too
With Treasury’s choosing the Executive Agreement ploy for the IGAs, in large measure to deal Congress out of the equation, it might be supposed there’s no danger from that quarter. That may not be the case, however.
It must be remembered that for several years Treasury already has been engaged in a running gun battle with some key members of the House Committee on Ways and Means, notably Oversight Committee Chairman Charles W. Boustany Jr., M.D. (Republican, Louisiana) and Congressman David G. Reichert (Republican, Washington) over requiring U.S. banks to report interest on accounts of non-resident aliens (NRA).
The argument over the authority and impact of NRA (Non Resident Alien) interest reporting precedes Treasury’s efforts to pressure other countries into FATCA IGAs. But the two issues dove tailed last year, notably with publication of an IRS bulletin citing as “authority” for faux-reciprocal reporting to “FATCA Partner” governments under the IGA the same disputed regulatory and statutory application claimed by the IRS to justify NRA interest reporting.
In a significant push-back from industry, in December 2012 the American Bankers Association (ABA) wrote to the Treasury Department, stating that that powerful industry group – . .
strongly objects to the NRA reporting automatic exchange provision included in the U.S.-Mexico IGA. Moreover, since there is no indication or evidence suggesting that the Treasury conducted the required due diligence for entering into such an automatic exchange relationship, we strongly recommend that Treasury reconsider this automatic exchange relationship with Mexico.
Of course the likelihood that the Treasury Department will reconsider information exchange with Mexico or any other country dragooned into signing an IGA is about as great as chances for Congress to enact legislation providing for fully reciprocal information exchange: virtually zero. However, that doesn’t mean that Congress can’t or won’t consider measures to block even the limited data promised to “Partner” countries under the “Model 1” IGA.
These concerns about NRA interest reporting and mandates on U.S. domestic industry under the IGAs are still short of moving toward FATCA repeal – so far. But they do show how out of touch with political realities in Washington are Treasury’s purported commitments to prospective “Partner” governments.
Simply put, as bad a deal for “Partner” countries the “Model 1” IGA already is on its face, Treasury cannot be sure of keeping its promise of even the meager “reciprocity” spelled out in it as Congress increasingly focuses on FATCA costs boomeranging back towards the US.
What needs to be done next
As accurately stated in the ABA letter,
“there is no indication or evidence suggesting that the Treasury conducted the required due diligence for entering into such an automatic exchange relationship” with Mexico.
Indeed, there is no indication or evidence any such due diligence was performed at any step along the way for FATCA at all, either before its enactment in 2010, or for the impact of the 544 pages of regulations on the U.S. and global economy, or on the costs and effects of the IGAs.
Instead, there is every indication and evidence of the exact opposite: That FATCA will not succeed in policing “tax cheats” or raising significant revenues but will trigger a host of deleterious consequences. If that’s not “the worst law most Americans have never heard of,” what is?
As a bad deal for all concerned, the IGAs should also be seen as a “weak link” for undermining FATCA and working for its repeal before its worst features go into effect. For that to happen, as Center for Freedom and Prosperity President Andrew Quinlan has written,
“it’s time for more Americans to hear about FATCA and the damage it is preparing to do – if not already doing – to the world economy.”
This means that foreign governments need to stop helping to save FATCA from its own fatal flaws by signing IGAs that cannot provide promised protection for cherished institutions. Instead, they should tell Treasury in clear and principled terms that they will not allow their domestic firms to comply with FATCA, and that they’re prepared to respond with WTO and other remedies if IRS tries to apply sanctions (notably FATCA’s 30 percent withholding threat for “recalcitrance”).
Finally, firms faced with wasting untold millions of dollars to comply with FATCA need to stop pressing their governments to sign IGAs and instead help get rid of it by supporting the repeal campaign in the United States.
Source: http://www.repealfatca.com/index.asp?idmenu=4&title=News&idsubmenu=112<
@ Northern Shrike, it has also been pointed out that those who are truly trying to ‘hide’ their assets will just move them to any jurisdictions and countries who are not signing on to FATCA.
Which makes it seem bizarre to focus the big FATCA stick on the ordinary local accounts of those in Canada. We have no reason to ‘hide’ money inside Canada, and our Canadian accounts are open and transparent to the CRA. Of course since FATCA is part of the US master plan for tax domination and assessment of the world, and the new FATCA reporting by US taxable individuals comes with the suspension or extension of existing statutes of limitations, and all sorts of other neat enforcement tricks, it plays other roles – not just ‘tax haven’ identification. It also works in tandem with the FBAR.
Since FATCA is entirely skewed to US benefit, even if there was a move to have some sort of universal equivalent, it would have to be designed to give other countries equivalent input and benefit – rather than just bearing all lopsided implementation and compliance burden of this entirely made-in-the-US deal.
And Prof. Allison Christians notes this loophole in FATCA :
“…Translation seems to be: no big stick on payments that go to state-owned financial institutions. That, I take it, describes China’s entire financial system, including Hong Kong and Singapore. Tell me if I am wrong about this, because I truly want to know. If I am right, then FATCA moves tax havens around on the board but doesn’t actually end the gravy train for tax cheats.
If that in turn is true, then the application of onerous compliance and filing issues on americans living in high tax countries to try to hunt down tax cheats who will not even be there seems particularly troublesome.” from her blog; Thursday, January 10, 2013 ‘FATCA will/will not work: discuss’ at http://taxpol.blogspot.ca/2013/01/fatca-willwill-not-work-discuss.html
This article ‘Little incentive for China to implement Fatca’ by author: Justin Lee
(Source: Asia Risk | 08 Feb 2013) says; “There is little incentive for Chinese authorities to sign an intergovernmental agreement (IGA) to enable China’s financial institutions to comply with Fatca, as any benefits to it from an exchange of information with US tax authorities are likely to be minimal, say consultants.”
http://www.risk.net/asia-risk/news/2241791/little-incentive-for-china-to-implement-fatca
badger wrote:
“Of course, problematic also to that part of the treaty is the US treating ex-greencard holders who are no longer US ‘residents’, have never been US citizens, and whose permanent resident rights have expired, equivalent to ‘citizens’ in respect of lifelong taxation and financial reporting.”
Exactly! If they can make tax and report demands on those who have no “benefits” whatsoever of US citizenship, including actually being able to live in the USA again without going through the entire greencard application process again, it makes you wonder who else in the future — anybody who ever set foot in the USA at anytime? — anybody with a distant relative in the USA? — anybody who ever ate a slice of American Pie or sang the song?
@Em, the US is working towards taxing the entire world, and FATCA is just a ‘babystep’ in that direction.
It is all about the US cornering all the chips. Except I’m wondering how that will work with such a huge and growing domestic debt, plus the large portion of that debt that is held by China?
What would China get in exchange for entering into a FATCA IGA? And what would the US be willing to give up?
@Badger
I don’t have any of the IDs needed to post on Prof Christian’s blog but I’m not sure where she’s headed with her assertion that the banking system in China is an arm of the government and that there is therefore no stick to beat them with.
“Subsection (a) shall not apply to any payment to the extent that the beneficial owner of such payment is—
(1) any foreign government, any political subdivision of a foreign government, or any wholly owned agency or instrumentality of any one or more of the foregoing…
(3) any foreign central bank of issue…”
She cites the above to suggest that China’s financial system can’t be subject to the withholding provisions. I’m sure it’s still true that the Chinese government owns large stakes in the “big four” but they are all publicly traded companies. I would have thought that having the government as a shareholder (even a very large shareholder) doesn’t put them in either 1) or 3) above.
@Em, I don’t know anything about banking.
Below might be some explanation:
See;
‘China’s Banking System: Issues for Congress’
Michael F. Martin
Specialist in Asian Affairs
February 20, 2012
“China’s banking system has been gradually transformed from a centralized, government-owned
and government-controlled provider of loans into an increasingly competitive market in which
different types of banks, including several U.S. banks, strive to provide a variety of financial
services. Only three banks in China remain fully government-owned; most banks have been
transformed into mixed ownership entities in which the central or local government may or may
not be a major equity holder in the bank.”……..
http://www.fas.org/sgp/crs/row/R42380.pdf
And:
Bulletin – September Quarter 2012
The Chinese Banking System
Grant Turner, Nicholas Tan and Dena Sadeghian*
http://www.rba.gov.au/publications/bulletin/2012/sep/7.html
…” The institutional and regulatory arrangements for banking in China differ from those in many other banking systems. The Chinese Government is still extensively involved in the banking system through its majority ownership of the largest Chinese banks and the Chinese authorities retain considerable influence over banks’ lending and deposit-taking activities. These arrangements mean that incentives within the Chinese banking system differ from those in banking systems that are predominantly privately owned and controlled.
The Chinese Government has majority ownership of banks that account for more than half of Chinese banking system assets, mainly through equity stakes of around 60–90 per cent in each of the five largest commercial banks. The government’s equity shareholdings are owned by Central Huijin (a subsidiary of the sovereign wealth fund, China Investment Corporation, which invests in financial institutions), the Ministry of Finance and, to a lesser extent, some state-owned enterprises. In addition, the government is the sole owner of the three policy banks and has controlling stakes in a number of smaller commercial banks. As majority owner, the Chinese Government appoints the senior management of these banks. “…
Let me make a comment that is only partly germaine to present discussion.
FATCA addresses the question, How do we stop money illicitly leaving the US? FATCA, despite IGAs, is basically a go-it-alone solution.
A different question, requiring a different solution is, How do we keep illicit money coming into the US?
First part of the solution is to refuse investment from countries lacking transparency, in particular the known and notorious tax havens. Investors from outside the US, i.e. from non-tax havens, would be required to provide their tax identification number from the country of their residence, which would receive information on those accounts, just as does the IRS. This is much easier to effect than tracing money once it has left the borders. It is in a sense doing GATCA instead of FATCA. Other countries (think UK, France, Japan) would be encouraged to reciprocate.
For individuals, this is conceptually pretty simple, at least from industrialized countries with transparent tax systems. Corporations would quickly find work-arounds, a different question.
I know that in the real world, things aren’t so simple. The chief reason it won’t happen, however, is that the US has actively encouraged tax evasion by non-resident aliens, while fighting tax evasion by its own citizens.
My humble thoughts…
@northernshrike re; ” The chief reason it won’t happen, however, is that the US has actively encouraged tax evasion by non-resident aliens, while fighting tax evasion by its own citizens.”
You’re right. Consider comments by Florida Senators and Florida banks;
“The political distrust of efforts to reduce U.S. bank secrecy can be seen in the Florida congressional delegation’s March 2 letter to Obama.
The letter says the IRS proposal to require U.S. bankers and money managers to report interest paid to foreign depositors “would likely result in the flight of hundreds of billions of dollars from U.S. financial institutions.” People from other countries put their money here, the lawmakers said, because their governments are unstable and they worry that if information about their bank accounts gets out, they could be left vulnerable to political terrorists or for-profit kidnappers. and hearings where they state that the US deliberately sought foreign depositors, and encouraged ‘foreign non-residents’ to park their money in the US.”
See; http://www.scribd.com/doc/55599503/REV-Fla-Delegation-Letter .
The IRS has not charged any actual bankster executives when illicit money owned by foreign non-resident depositors is discovered hidden in US bank accounts on a large scale, and it appears that none of these investigations even went to trial. The banks settled, but still made a profit.
See: …”Even as the U.S. Internal Revenue Service crusades against Americans using offshore banks to hide money, these tax experts say, the United States itself serves as a massive haven for international tax cheats.
“We’re the biggest tax haven in the world,” says Robert Goulder, editor-in-chief of U.S.-based Tax Notes International. “People joke about the Cayman Islands. The biggest haven is an island, all right. It’s either Manhattan or Great Britain.”
Jack Blum, a former U.S. Senate investigator and an authority on offshore tax shelters, says U.S. bankers “sell tax evasion to citizens of Central America, the Caribbean, all over Latin America.” The U.S. government hasn’t put a stop to it, Blum says, because bankers and politicians don’t want to stop the flow of foreign cash into the United States.”… from http://www.publicintegrity.org/2011/05/18/4638/irs-crusades-against-americans-hiding-money-offshore-latin-american-tax-cheats-flock
also:
http://wikileaks.org/gifiles/docs/1115826_re-us-bank-dirty-money-.html
http://www.justice.gov/usao/fls/PressReleases/100317-02.html
http://www.guardian.co.uk/world/2011/apr/03/us-bank-mexico-drug-gangs
Someone else is beginning to understand that Model 1 Signatories will probably get little useful information from the US
http://www.fatcalinks.com/home/viewpoints/IGA/Model1-IGA-Analysis
@badger
Thanks for those links and laying out the hypocrisy so clearly.
@Just Me,
I first got on to that angle because of your early warnings about DATCA, and your reports of the political and bank manouverings originating out of Florida.
There is so much public evidence of US hypocrisy – I only scratched the surface!
The Dubious Legal Pedigree of FATCA intergovernmental agreements (and why it matters)
http://bit.ly/WZKphF
Allison Christians column in Tax Analysts’ Tax Notes International is here [gated], http://bit.ly/WZLs13 or you can download a pdf here. http://bit.ly/WjkUI6
She argues that the IGAs have a dubious legal pedigree because they are not treaties, not congressionally-authorized executive agreements, and not interpretations of existing agreements; therefore they are sole executive agreements–entered into by the executive branch with no authorization or oversight from Congress.
This puts them on very shaky ground in terms of the constitutional process for binding the US internationally, and I argue that this is both unhelpful to other governments as a practical matter (IGAs override the statute, so if they fail, then what) and an unnecessary muddling of the rule of law, which should make other governments wary (if you have a process in place to bind the US under international law, why aren’t you using it).
@ Just Me, if we can grasp this, and Prof Christians can write so clearly about it that even non-academics with no background in this area can understand what she is saying, how likely is it that our respective governments don’t know this? Governments are full of lawyers. Often, significant numbers of those elected to government are lawyers. Not many likely specialized in the area of international taxation, but, if we can ask logical questions, and track down information – so can they. They have research teams.
Does the UK, Germany, Canada and others not have people who have dealt with the existing US tax treaties before, and know about the savings clause, and the next in time rule, etc. ?
Do other governments not suspect that they will be shown up for fools, or patsies, or worse if they sign the FATCA IGA?
By now, in Canada, how could Minister Flaherty and Harper not be aware of similar information that we have found and posted here? It is easy to search the internet, it is easy to search the databases they must have access to, they have lawyers giving them official opinions, and even if they have no motivation to help us, surely they don’t want to go down in history forever as the fools that signed on to FATCA and signed away Canadian taxpayers and Canadian assets, and gave the US the key to the vault?
It looks as if Germany may have realized this re the faux US ‘reciprocity’, and didn’t the UK say that they reserved the right to get a better deal if anyone else achieved one? Well, that other clause (can’t remember the name), that basically said – the US can change all the terms of the FATCA agreement however it wishes, and it still binds the other parties to the un-negotiated changes – that looks like something only an idiot would agree to.
Are we to believe that our governments are so full of stupid people that no-one has discovered, and discussed any of this? Could they possibly be that blind and that motivated to sign on?
It really beggars belief that we can see all this, but no-one in our own governments can?
Here is a definitive exchange between a dual citizen and the Swedish parliament. It should definitely show where Sweden is going and gives an indication of how OECD members are officially thinking.
The site is not accepting the entire piece, so let’s try it one conversation at a time
FROM SWEDISH CITIZEN TO (50+) IN SWEDISH PARLIAMENT (RIKSDAGEN)
Swedish banks are lobbying Sweden to allow USA to demand private data from Swedish banks—-For Swedish banks to spend billions of dollars to satisfy US legal demands upon banks and Sweden.
This law will report the most private financial details of Swedish Citizens, living in Sweden, who unfortunately were born in USA, whose parent is AMerican, or who still has an active US green card.
Sweden is going over to USA during the next few weeks to sign an agreement that breaks all Swedish laws. The agreement is not Bilateral—it gives Sweden nothing—zilch-null
http://www.swedishbankers.se/web/bf.nsf/$all/87D71CF8A96F41D7C1257AD80035D35E?OpenDocument
It works like this:
http://www.youtube.com/watch?v=DRP0O-lxzPU
Here is a radio clip about what is happening to Canada Citizens.
The same is happening to Swedish Citizens. Sweden has been talking to the bank lobby–who wants to have the Swedish government break discrimination laws, rather than the banks. Sweden has been talking to USA, who wants to have USA laws enacted in Sweden. Sweden has not had a single discussion with the Swedish citizens who are affected by these actions. Will you help change that?
Are you concerned enough to protect Sweden from foreign government intrusion?
Call me and have a detailed discussion about how to protect Swedish citizens living in Sweden from the laws of foreign countries being enforced inside Sweden.
If you act next week, it will be too late.
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