– 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<
I wish there had been more time allotted to Jim Jatras at the George Mason symposium. As this article demonstrates there was so much more he could have said there. Instead we had to listen to Herr Deblon drone on about how much he trusted the USA to do right by Germany and other IGA nations even though the American interpretation of “reciprocity” is dubious at best. Thank you Mr. Jatras for your appearance at GMU and for this and other articles like it that keep some hope alive that sanity might prevail and FATCA will be repealed.
Another blog picks up the story….
FATCA Intergovernmental Agreement Exposed as Bad Deal for ‘Partner’ Countries
I am confused by this: “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.”
It would appear that Canada has no intention of putting this through any sort of ratification whatsoever. The sense I have of this is that they have basically signed the IGA and the FFI’s will begin complying at the agreed-upon date.
It reminds me of watching the process of my major professor getting the boot even though he had tenure. What a charade that was.
@Nobledreamer…
Well, not sure about Canada, as you would know better than I, but in the UK, they are, and in NZ, that is what will happen. I read an article somewhere, (will have to look) that Mexico was going to try and find a way ‘ala the US’, and avoid taking this issue to their legislature. I am pretty sure most countries will have though, especially if their laws specifically need changing, but they might look at the U.S. example and see if they can’t find a way to emulate our example, as leader of the “free world” 🙂
Sweden has a large delegation traveling to USA in the next couple of weeks. Likely that their goal is to talk and get happy together, sign, and have champagne.
@NobleDreamer
re “Canada has no intention of putting this through any sort of ratification
whatsoever. The sense I have of this is that they have basically signed
the IGA and the FFI’s will begin complying at the agreed-upon date”
Have I missed something? Has Canada signed an IGA?
@ CanuckDoc
Canada has NOT signed an IGA … yet. Nobledreamer was just doing some wise surmising. All the talks are in secret (shades of SPP, TPP, NAU, etc.) so we can only guess at what Flaherty is doing these days. The long silence since his CRA shalt not collect for IRS statement is very annoying but then if the news comes out that an IGA is a done deal I won’t like that either.
*Canada has not yet signed. RBC for one has stated that they will comply through an IGA or directly if necessary.
@JustMe
Well Canada is a parliamentary democracy and a constitutional monarchy. So I would think Jim’s comment about having to be ratified by parliament means they can’t just sneak it in. But as Em says, they’ve done it before. It really irks me how they snuck in Beyond the Border when they couldn’t get SPP through.
But there’s just the one thing. They will have to change the law regarding the privacy violations. An IGA cannot possibly override existing legislation. I have to wonder how that will go down. And would there be any recourse to getting that IGA nullified if the public gets worked up?
*NobleDreamer
They have to change the law. They can either do that via standalone legislation or as part of a broader bill. One card Elizabeth May and Greens hold is because May does not sit on any of the committees she can bring amendments in the House on any piece of legislation and force an up or down vote by all MPs.
*More comment
Additionally any vote on implementing FATCA “should” be party line. There is no reason in my mind to allow free votes for certain MPs that have a lot of US Persons in their ridings. None of the special dispensations they just give out back in the Meech Lake days. The NDP and Libs(and the government including Conservative MP John Williamson)need to support FATCA or not support it. No playing around. If vote to implement to IGA “fails” Canada Revenue will lack the legal ability to implement it.
To be clear there WILL be a vote in Ottawa(both House of Commons and Senate) to implement FATCA.
*http://www.huffingtonpost.ca/2012/06/11/bill-c-38-omnibus-budget-elizabeth-may_n_1585650.html
At the time, she said, she thought that perhaps the Conservatives were no longer going to use omnibus bills, given they had a majority government.
“They could get anything passed they want without using this kind of stealth mechanism of throwing them in a budget implementation bill,” she said.
“So, I really was not prepared for this year’s budget.”
At over 400 pages, the budget amends some 70 pieces of legislation on everything from environmental assessment to the regulation of charities.
As the lone Green party MP in the Commons, there are few avenues available to May to make changes to proposed laws.
So she’s throwing everything she has at this one.
…
[quote shortened–please consult link]
Tim,
Thanks, that’s very helpful info.
*Only the Eurozone countries will have enough power to withstand the US; if the US slaps on the 30% charge, the Eurozones will do the same upon US banks, in true reciprocity.
You may copy paste this to your Congressman
Illegal agreements with governments to track US citizens
The United States Treasury is making agreements with foreign governments which contradict with the legislation (2010 HIRE Act, HR 2847) and all other US laws and principles.
http://www.treasury.gov/press-center/press-releases/Pages/tg1759.aspx
Specifically, the Treasury is completing negotiations with foreign countries. The objective that these countries have been tasked with, is to hunt down and find US persons.
There is no distinction being made with these governments, as to how to treat this confidential data.
There is no distinction being made with these governments, as to the stability of these governments or to their status as allies or not allies (Mali, Algeria, Nigeria, Russia, China, Bahrain, Qatar, nor North Korea are excluded from the demands to register US Citizens).
Agreements will soon be made between the treasury department and the country where I live.
There is no provision in any bill, and especially not HR 2847, which calls upon a foreign government to track US Citizens and report them to the IRS.
There is no justification for a foreign government to track a US Citizen while that US Citizen is in Another country.
This is totally counter to the rights of a US Citizen and to the objectives of the United States of America.
These agreements with foreign governments are being made without ratification by Congress.
These agreements have dangerous and damaging consequences for US Citizens and for the privacy of their most critical information, in each and every country of the World.
PLease ensure that these agreements are stopped immediately. THe agreements that have been signed or “initialed” must be declared invalid.
@Em
Thanks for the kind words and encouragement. BTW, George Mason aid they’ll try to increase the volume on Panel 1.
@nobledreamer
Re: “I am confused by this: “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.”
It would appear that Canada has no intention of putting this through any sort of ratification whatsoever. The sense I have of this is that they have basically signed the IGA and the FFI’s will begin complying at the agreed-upon date.
It reminds me of watching the process of my major professor getting the boot even though he had tenure. What a charade that was.”
One can never exclude that many countries will just ignore their own laws when presented with the US diktat. However, in the cases of Canada, the UK, and in particular Germany, it seems that for reasons of domestic law the IGA might have to be treated as treaty. Even if it’s not, it at least would require passage of domestic legislation to implement it. This would be not only to abrogate data privacy and other protections to allow (really, to require) FFIs to comply without violating them, but more importantly — since under the “reciprocal” IGA the “Partner” country would be enforcing FATCA domestically — it would have to enact its own law (Canadian law, British law, etc) to force Canadian, Brit, etc firms to comply, since these laws don’t currently exist. In my discussions with German lawyers, they havg been very explicit about this, noting that whereas in the US the normal mode is to pass a relatively short statute (look how much shorter FATCA is than the 544 pages of regs) and then let the Executive Branch agency or department fill it out with lots and lots of detailed regulations that have the force of law to implement it, the German model is to enact a very, very detailed statute that would spell out what in the US would usually be left to the regulations.
Now of course some governments may instead opt to let the US law overrule their own law, and let the FFIs comply in violation of existing domestic law and look the other way. Indeed, that seems to be happening to some extent already almost everywhere. But that in essence only works for the Model 2, the non-reciprocal version, where firms report directly to the IRS. To implement the Model 1, where FFIs report to their own governments, since the domestic mandates requiring that don’t currently exist, the “Partner” government will have to do something to start requiring it. In fact, I wouldn’t be surprised if some finance/treasury departments will have to set up entire FATCA-enforcement divisions (at their own taxpayer’s expense, of course) to oversee compliance.
Sweden stated that they viewed it as a new treaty. Hence, they are chartering a plane and going to Washington for drinks and a signing ceremony.
Here is my submission to the Institute of Justice, requesting litigation. Please use it as a model in your request.
general@ij.org
7 million US Citizens overseas need legal help and media coverage.
Please help stop these Illegal agreements with governments to track US citizens
The United States Treasury is making agreements with foreign governments which contradict with the legislation (2010 HIRE Act, HR 2847) and all other US laws and principles.
http://www.treasury.gov/press-center/press-releases/Pages/tg1759.aspx
Specifically, the Treasury is completing negotiations with foreign countries. The objective that these countries have been tasked with, is to hunt down and find US persons. The foreign government is INSTRUCTED by the Treasury department to collect and collate the data. Negotiations are being made with Qatar and Bahrain, for example.
There is no distinction being made with these governments, as to how to treat this confidential data.
There is no distinction being made with these governments, as to the stability of these governments or to their status as allies or not allies.
Agreements have already been reached in the country where I have worked and lived.
There is no provision in any bill, and especially not 2010 HIRE Act HR 2847, which calls upon a foreign government to track US Citizens and report them to the IRS. And there is nothing in the US Constitution which allows the US government Treasury department to INSTRUCT AND TEACH foreign governments to track and collate the most private personal information of US Citizens.
There is no justification for a foreign government to track a US Citizen while that US Citizen is in Another country.
This is totally counter to the rights of a US Citizen and to the objectives of the United States of America.
These agreements with foreign governments are being made without ratification by Congress.
These agreements have dangerous and damaging consequences for US Citizens and for the privacy of their most critical information, in each and every country of the World.
PLease ensure that these agreements are stopped immediately. THe agreements that have been signed or “initialed” must be declared invalid.
7 million US Citizens overseas, without formal organization, are desperately looking for legal help and media coverage.
*Mark Twain
I do fully expect Sweden to be one of the “next” countries to sign before even France or Germany. Why that is I don’t know its some type of Scandanavian pro transparency thing. Remember Denmark and Norway have already signed.
Swedish Culture is for the tough turks to put up a big front. Then they go to the table and have coffee and cookies together with the enemy and give away the farm. They will destroy dissenters in their own camp Before they would take on any confrontation with anyone sitting on the opposite side of the table.
At this stage they have shown lots of dissent. They will talk some jibberish in Washington next week, then they will sign.
When it is all done, the media might make some complaints.. This will make themselves feel better and it will give themselves an image that they have “Fri TV”. Being cooperative is more important than not getting screwed.
search words
Sweden Swedish Sverige Zlatan fotboll Nobel Victoria Estelle kultur fritid semester sommar recept sex kärlek vm em bandy vasaloppet 2013 cykel idrott politik moderaterna vänster centerpartiet folkpartiet Reinfeldt Salin Anders Borg
*Like I said Scandanavians are consensus driven people. Many people especially Americans assume Canadians are too. That is not necessarily true look at the fighting over Meech Lake, Oka, and Charlottetown(three rather traumatic “Canadian” political fights largely unkown outside the country). What the banks are afraid is if given a choice the people of Canada will blowup FATCA just like they blew up Meech and Charlottetown.
More on what Meech and Charlottetown were below for non Canadians.
The Canadian Bankers Association and other business groups spent millions of dollars on commercials seen above in failure to try to get a Yes result in the referendum vote.
Results? One must look inward to see what can be done to create success. Have I done what is necessary? Apparently not. Yet.
Swedes are also seriously major wusses. You can’t appeal to them based upon their manhood, because they have none. They will fight you violently to protect their wussness. Their Point is that they are Swedish and they do things the way Swedish do it, even if it means that doing the Swedish way is to give away 10’s of thousands of Swedish Citizens to Another country.
They fought the Russians based upon sovereignty so that the Russians wouldn’t march through to fight the Germans. Then they cajoled the Germans with access, gave over a few Jews, sold transmissions for Panzers, and mined iron for the Nazi war machine. Giving away data on a hundred thousand Swedish Citizens will be nothing for them
Just sent the link to Jim Flaherty’s FB via PM.
1389AD posted a link leading to these videos on another thread but I think this might be a good place for them too.
James Jatras – FATCA, why foreign banks won’t take Americans – Part 1/2
James Jatras – FATCA, why foreign banks won’t take Americans – Part 2/2