It seems a convergence is about to transpire; the IGA will soon pass, FATCA is 10 days away and the IRS’ recent “easing-up” on penalties. I started wondering just how much of that “easing-up” has to do with our efforts, and what a great PR move the IRS just made, etc. Will it really make a difference and so on…..
I think now is a good time for all of us to sit back, take a breath and look at where we were, where we are, and where we would like to be moving towards. I am particularly interested in the less-than-obvious observations Brockers and Sandboxers have about what has contributed to any one of those stages.
Someone at the IRS just made a brilliant move. As if it hasn’t been hard enough to get everyone to listen, i.e., friends, families, media, CDN govt, IRS and the Congress, it will now become a lot harder. Imagine how many times we are going to hear “What are you complaining about, no penalties to be afraid of, etc etc. Not much progress seems to have been made in putting a dent in the misconception that Americans abroad are not the same as Homelanders stashing money in tax havens. In spite of the enormous amount of time Brockers and Sandboxers have put into responding to endless articles and putting up with endless abuse from those who either do not know how to read or cannot think outside the cliché box or else just enjoy being unkind.
What about all the time and energy put into researching, trying to get questions answered without the bias of the compliance industry, govt etc. I was recently cautioned/reminded about the fact that no one should advise anyone to break the law. I still do not see anyone here doing that; we are looking at what options are there and sharing that information. Back to Expat Forum days, Ladyhawk’s amazing post Why I Will Not Renounce”. The “mass” renunciation meeting in October 2011. The horror of seeing OVDP morph into OVDI; Shulman’s refusal to acknowledge Nina Olson’s TAD. Actually renouncing. Watching Mona Lisa do a complete 180 turn as the reality of this miserable mess forced her to do what she absolutely felt was wrong for her to do……..
So much effort and participation…the protests, the Information Sessions, the We Are Not a Myth Campaign, appearances in front of FINA, the list goes on and on. I find this aspect to be truly inspiring and amazing, that we have managed to come together and hopefully, have made a difference.
I guess what I am saying/asking is:
What moments/events are the most memorable for you?
Which ones have made you the most angry?
Which have given you hope?
Do you think we have played a part in the change of IRS’ direction?
Do you think we have been able to help people?
What kind of direction should we be looking at?
and whatever other questions come up………….
Of course we will continue with the Charter Challenge. Of course we will continue to argue that Accidentals should not have to waste money to become compliant so that they can renounce. And that CBT needs to be abolished. I just wonder how all of you may be feeling/thinking before the next wave hits.
The IRS is determined to get US persons abroad into compliance. Those who want to retain US citizenship have to decide if the compliance costs are worth it.
For the rest of us, ex-citizens or soon to be, the issues are (1) for the US to let people who want to renounce go easily and leave us alone afterward, (2) to get our governments to oppose US CBT and pressure them to change it, and (3) to get our governments to stop violating our privacy and discriminating against us based on national origin.
Absolutely, I agree. It is every deemed *US Person* in Canada that is collateral damage — from those like my son to those who have earned a good deal of wealth entirely from their country, ours Canada, and have legally and fully paid their Canadian taxes should be protected under the freedoms set up for privacy and from discrimination from national origin and any other human rights. True tax evasion is another thing altogether; we are taking the fall for many of those who have figured out other ways to do what they do.
I would make the argument we are being rendered stateless: “De facto stateless persons technically have a nationality, but for a variety of reasons they do not enjoy the rights and protections persons holding their nationality normally enjoy”.
These are some random things that I do believe apply to us and as someone mentioned yesterday we just might have a case to appeal to the UN. (It was mentioned about needing to use our names but might there be a legal case for some method of avoiding self incrimination and applying as a say the Issac Brock Group?
I found these random bits of info, there is much more to support our case:
The consequences of the lack of ‘effective nationality’ are the most worrisome and adverse for the stateless person, the reason being that nationality is the principal link between an individual and international law, a bond establishing mutual rights and duties between them. It is a fundamental element of human security and apart from providing people with a sense of belonging and identity; it entitles the individual to the protection of the state and provides a legal basis for the exercise of many civil and political rights.
No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks.
Everyone is entitled to all the rights and freedoms set forth in this Declaration, without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status. Furthermore, no distinction shall be made on the basis of the political, jurisdictional or international status of the country or territory to which a person belongs, whether it be independent, trust, non-self-governing or under any other limitation of sovereignty.
No one shall be arbitrarily deprived of his property
@Nell: I would not be content to let FBAR or FATCA stand. Who would get to decide what a large balance is? How do you qualify to be considered an ordinary person? All of this is exactly what we have now and it doesn’t work. All of this is merely the politics of envy and imperialism. It would still be an over throwing of the sovereignty of other nations and an out right interference with their internal affairs.
Although many people do not see CBT as an interference with the internal affairs of another country the truth is that it is. Their is no more intimate way in which a government relates to its citizens than through its spending and taxing power. A country’s tax system is the avenue by which the country’s elected officials make real the expressed will of the citizens who voted for them. Unless an expat has land in the U.S. then s/he has no vote. As the new leader of the House said this morning concerning his advice to House members, “vote your conscious and vote your district”. Expats without land in the U.S. have no district. All politics is local.
Living abroad and becoming wealthy is not a crime. If it were so then America has a lot of successful immigrant criminals within its borders.
For those who haven’t heard Calgary411’s son’s unfortunate situation get heckled in the House, here it is on You Tube:
http://m.youtube.com/watch?v=ANqVaEpRi_4
I wonder, how many ‘US persons’ are so far down the path of willfulness, that they no longer care how sweet the IRS makes any new and improved amnesty/compliance program?
On the other hand, no doubt, there will be many who decide that the latest compliance deal is too good to refuse, thus will finally submit all the dreaded paperwork, and get out, once and for all. Who could blame them?
However, I don’t think the IRS is winning any friends with its latest attempt at ‘playing kind’ with its ‘US persons’ living outside the plantation. Even if a whole lot of minnows manage to escape the net with the latest “streamlined’ process, that doesn’t necessarily mean they will all drop out of the fight. Sure, they might have less funds to spare, after paying for professional help to deal with the complications of years of tax and FBAR reporting, but this will make them even MORE ANGRY.
Many of the ‘US persons/ex-US persons’ fighting this battle now, particularly those in more public roles, don’t have a compliance problem – at least not one that they are aware of, as no one can ever be sure. Likewise, I suspect that the soon to be thrown-back minnows, will not go away quietly, and this latest offering by the IRS won’t end their role in the fight. Maybe some will even be emboldened enough to come out from the shadows and take on more public roles.
Anyone who has been affected by FATCA and CBT quickly learns that you can never really escape it without killing it, because ultimately, left unchecked, will hurt ALL Canadians, and all citizens of every country.
I hope everyone continues to support the ADCS – ADSC.
The ONLY thing CBT has had going for it is that no one knew about it!
I concur with Stephen and WhiteKat;
Litigation is the only recourse. Support and fund the work of ADCS – ADSC as you are able. Bolster that with continuing to laud the supportive politicians like Elizabeth May and the NDP MPs like Rankin and Cullen, and others, and plague and afflict the FATCAnatic apologist Conservatives like Adler, and Keddy. Continue to poke Trudeau on his silence and lack of commitment to stop FATCA if elected. There is no excuse for it given the FATCA IGA and the inclusion in the C-31 OMNIBILL.
That is the only way to meet both betrayals – by the US, and by our HOME country.
Even if you are not a Canadian citizen or resident, this fight will have repercussions for other countries too. A good reason to send funds to the Canadian effort – since a win here would have significance for other similar IGA signatories – and call them into question if they are in countries with similar human rights and civil rights structures and policies.
In addition to the US domestic challenge, an EU legal challenge inspired by the resistance in Canada and from inside the US would be fantastic as well. I don’t even dare to dream about bringing this to the UN as MuzzledNoMore suggests, but perhaps it is possible to embarrass the US internationally there. The effects of FATCA and the OECD Common Reporting are significant for small countries and economies – which very well could become of interest at the UN.
Those minnows who have escaped or will, and those who have successfully expatriated, are still subject to the arrogant and unacceptable invasion of their HOME country by the US – Treasury, IRS, NSA, Homeland Security, etc. We in Canada have still been betrayed by the Harper government, and have had a foreign law and its costs foisted upon ALL Canadian taxpayers and accountholders – whether deemed ‘US persons’ anymore or not.
Biting that extended grasping extraterritorial hand that seeks to grab individuals and our legal local earnings and savings is the only way to get it withdrawn.
The US is not our friend. It never will be. It’s interests and ours must always diverge at some point. That is clear in the statements by the latest US Ambassadors. They clearly state what they intend to get from Canada. Sometimes they throw in some meaningless disingenuous pap to make it go down better with the Canadian masses, but really, it is about whatever furthers US interests.
We need to act to protect Canada and Canadians against the US.
I am still very very angry. I am very thankful for IBS and Maple Sandbox – and other websites like http://renounceuscitizenship.wordpress.com/ and now ADCS – ADSC, and all those who have maintained them – with countless hours behind the scenes.
Even now, I feel sick about FATCA and CBT, and continue to have trouble sleeping and enjoying life because it has infected not only my mind and wellbeing, as well as my personal home and family, but now, also has invaded my HOME country – with the active collusion and betrayal of the Harper Conservative government. I also know, and continue to meet people who are affected but unaware, or who are significantly affected but for whom no real clear remedy exists.
Grateful thanks for all those here at IBS and Maple Sandbox and elsewhere who have made such a difference in this fight and supported those for whom no other help was available.
@badger
“I don’t even dare to dream about bringing this to the UN as MuzzledNoMore suggests”. WHY?
Can’t we try?
@MuzzledNoMore
I’m in for trying a gazillion pronged attack. We can only fail.
@Charl, I think that MuzzledNoMore has made a very valid and interesting suggestion. I just don’t know what that would entail. I think that embarrassing the US in front of the UN, with reference to the burden that FATCA imposes on the smallest of economies (as well as all others like Canada) re costly automatic reporting at threat of extortionate economic penalty by the US, is very valid.
It would be ideal if someone in the EU would try to bring this up for a legal challenge there, and great if some kind of raising of the issue at the UN could happen. I just don’t know how that would happen or who would take it on. Even being able to lodge some kind of petition there? Need to look into it further, as I have seen efforts like these http://www.cbc.ca/news/canada/montreal/arthur-porter-makes-human-rights-complaint-to-un-1.1874039 http://www.duhaimelaw.com/2014/04/14/un-passes-protocol-allowing-children-to-file-human-rights-violations/ http://www.ccrjustice.org/newsroom/press-releases/survivors-file-u.n.-complaint-against-canada-failing-prosecute-george-w.-bush-torture http://www.ctvnews.ca/advocates-take-complaints-about-aboriginal-children-to-un-1.716053
but don’t know how best the civil/human rights violations of FATCA, and the issue of extortionate economic sanctions would be raised at the UN, the process, etc.
@badger
I came across this just noodling around:
Top UN official hails adoption of ‘missing piece’ in human rights protectiont
18 June 2008 – The top United Nations human rights official has hailed the adoption of a new legal instrument which will enable people to submit complaints on violations of their economic, social and cultural rights to an international human rights body.
“It will provide a way for individuals, who may otherwise be isolated and powerless, to make the international community aware of their situation,” she added, calling the adoption of the text by the Geneva-based UN Human Rights Council “a highly significant achievement.”
Ms. Arbour noted that the lack of a complaint procedure for economic, social and cultural rights has been “a missing piece in the international human rights protection system,” since the Covenant
Along with the burden for smaller countries might we also be suffering: “De facto stateless persons technically have a nationality, but for a variety of reasons they do not enjoy the rights and protections persons holding their nationality normally enjoy”, which is also a human right.
I also think the IRS having the ability to deem who is and is not willful violates: No one shall be arbitrarily deprived of his property.
I agree with the others about litigation. This may take a long time to do but in my eyes… we must fight for our future generations. I don’t care what others say… we have been labelled… 2nd class citizen worldwide… no matter where we go… And I know what its like to be a 2nd class citizen… u contribute to the society but u are treated like an unwanted element. but to slap salt on the wound.. my own country has done it to me also. It maybe too late for my generation… I may not be around for the resolution of this situation… but I can say… I tried the best I could… I am angry that not one country stood up & say… no… Instead… they are jumping on the band wagon… thinking that the US will help them… but surprise… the US won’t. The one thing that will grow will be the underground market… u push people into a corner.. they will do whatever it takes to survive… The US may have won this fight… but they have not won the war… we must… with all our friends do the best we can to defeat this common enemy… I was never political… but this cause has made me open my eyes to the evil of the world… our govts
Tricia poses some interesting questions and I have been doing some reflecting this weekend as a result. I think my answers to Tricia’s questions are pretty much along the same line as most of us here but I’ve had some other thoughts about where we are and why. I could be all wrong but that wouldn’t be the first time, won’t be the last. Here’s my take on the bigger picture.
We think we are the prime targets of this FATCA pogrom by the USA but we are likely just amusing bits of collateral damage to those who developed this devious plot. We play a small but yet essential role in their big play to achieve their ends by any means. The US military goal is “Full Spectrum Dominance” but this could well describe the US economic endgame as well. I believe the true objective of FATCA is to put all the financial institutions in the world under the control of the USA (or more accurately, under the control of those who control the USA). The mass registration of FIs everywhere is a key component in all of this. Since FIs have a symbiotic relationship with their governments, the USA gains control over both.
The game is quite simple, although the simplicity is cleverly hidden in complex US diktats and gobbledegook. If Country A is giving the USA grief in any way, the USA will use its worldwide “Total Information Awareness” network to pinpoint some hapless US persons living in that country who aren’t jumping precisely enough through ever-changing, ever-higher IRS regulation hoops. These US persons will be called out as tax evaders! Their banks subsequently will be called out for harboring tax evaders! The banks will then be threatened with 30% withholding penalties! Country A will be, in essence, under economic sanction! Country A will therefore see the light and will align its policies with the USA. It will no longer be giving the USA any grief and what will it matter to either Country A or the USA that some US persons are destroyed in the process.
For a weaker and poorer country, the USA still has its tried and true tactic of finagling that country into deep debt doo-doo so that it can confiscate the country’s resources and enslave its people in a effort to pay off the debt. This strategy was revealed years ago by John Perkins who wrote “Confessions of an Economic Hit Man”. For a stronger and wealthier country, the USA now has FATCA which will keep it under control and as a nice bonus make it’s FIs less competitive with US FIs.
What I would do is heap scorn on all the FATCA capitulating countries by issuing them all a CLS — Certificate of Loss of Sovereignty. Canada would be given Certificate Number One.
Well so much for the bigger picture as I may rightly or wrongly see it. Time to get back to the smaller picture and the task of completing my husband’s emancipation from the USA now that he has that precious CLN. Time also to renew and maintain my focus on the Alliance for the Defence of Canadian Sovereignty.
For me, the turning point was the end of an NPR news story.
http://www.npr.org/blogs/parallels/2014/02/20/275937138/why-more-americans-are-renouncing-u-s-citizenship
“Officials from the Treasury Department, the State Department, the IRS and Congress spoke on background for this story. None would talk on tape.
They all generally agree on the facts of the situation. Even so, there is very little pressure to change it. As one Senate staffer pointed out, nobody in Congress represents overseas Americans. And government officials think this law is succeeding at catching the tax cheats. That may be worth the side effect of losing a few thousand American citizens every year”.
What gets me is that they think that they are losing only a few thousand citizens every year. On paper, I am still the same citizen and, unlike most people, have reasons for remaining so, but my whole attitude towards the U.S. has changed and they don’t see that. I used to be really motivated with students who really hated the U.S. to get them to at least stick to some facts, which at times was extremely difficult (I had one student one year who loved al qaeda and thought that everyone in the U.S. hated all muslims. Fun). I am not sure how effective I ever was, but I don’t have nearly the motivation I used to have. if the government thinks it is protecting U.S. citizens abroad, I think the reverse is at least as true in some cases.
@Em
Quite possibly this is a financial services power grab. I suspect that after all of the bank secrecy jurisdictions have been broken into, OECD enthusiasm for FATCA will wane, since FATCA is not the OECD standard and having two standards is costly. I foresee the EU taking the U.S. to the WTO at some point, since there are some highly questionable aspects about U.S. policy (such as those penalties for foreign mutual funds and the burden of those weird indica). The WTO is the most powerful international organization by far and sees RBT as the standard.
@recalcitrantexpat
An overseas voter (or perhaps their parents) needs to have had an address in the U.S. to determine the voting district, but there is no property requirement. Relinquishment may be a better option for people who have not voted since acquiring another citizenship. People who have been voting in presidential elections should be voting out bad incumbents in the midterm primaries that are going on now, since that is when they are most vulnerable.
Everyone should be making young people and others aware of the greencard holder tax traps.
Interesting description, Em:
Is that a step up from invisible or the reason we are invisible — not given the time of day by the Conservative government and the media? I’m just mulling it around in my mind, trying to figure out what THEY (the powers that be) really do think of *US Persons in Canada*. It appears as if some would like to show us the door, sorry we ever showed up here to take our parts in the society of the country we chose in which to live, work, pay our taxes and be contributing members. Could someone come out from behind the Conservative facade and give us the straight skinny?
Charl quoted a UN official (I think Louise Arbour) who said: “De facto stateless persons technically have a nationality, but for a variety of reasons they do not enjoy the rights and protections persons holding their nationality normally enjoy” — the part, “do not enjoy the rights and protections persons holding their nationality normally enjoy” applies to Americans abroad.
The America Diaspora as a group, which it is, has no direct representation in congress and do not enjoy access to US public goods and services. The US taxing them without them enjoying representation and without access to US public goods/services is a human rights abuse. No honest person can argue to the contrary.
Ah, just found it, here’s the UN press release:
http://www.un.org/apps/news/story.asp?NewsID=27069&Cr=arbour&Cr1#.U6dftk3YeUk
@FromThe Wilderness
You are right, it works both ways for us. We do not enjoy the rights and protections the US residents have but now we do not enjoy the rights that Canadians without an IRS branding have. I truly think we have a case, do you? I also think we have a case for a few other human rights violations. MuzzledNoMore brought up this idea of going to the UN, I am curious as to what grounds Muzzled was thinking of.
@ Charl
I can see several possibilities for a case in “The Universal Declaration of Human Rights” but I just don’t know how much weight this document carries, especially in the USA. Remembering that the US Constitution was called a G-D piece of paper by Bush Jr. and it appears Obama thinks the same (even though he’s been smart enough not to say it like Bush did), then the UN declaration would probably be sloughed off as having no consequence by the USA.
http://www.un.org/en/documents/udhr/
I realise that you do not need to own real property in the U.S. in order to vote in the federal election for president. But my point and is that no expat can truly be said to actually be a constituency member if there is no real property or if you do not have your own immediate family who lives in the Congressional district and therefore receiving benefits. I don’t believe that you can even vote in Congressional elections without an address.
I think that it is as mistaken to vote based upon an address that isn’t yours or once was yours, as it is to vote for president based on a forced citizenship in D.C.
For an expat to vote in a U.S. election outside of having met one of the above conditions is otherwise a waste of time and in fact a misrepresentation of one’s political situation with respect to the American government.
@EM
Maybe I am wrong thinking but I feel making a fuss anyway we can has value. There are so many countries involved in this that they too may support us if we can make a stink somehow, esp the small countries that this will REALLY hurt. And if your earlier reflective post has validity, which I truly believe it does, all the more to go to the UN. So what if the US will not acknowledge it if the remainder of the universe acknowledges it. Maybe someone with power someplace will finally freaking listen, the US can be exposed or at least the issue made more broadly known. If so many individuals plus countries are hurt maybe someone will listen. Maybe someone can stop this. I’m just thinking….throw everything at it that we can, maybe something will FINALLY stick. We can add to our comments….Canadian challenge, US challenge, UN violation submission.
@all
Do you think we should try? We can only fail. If indeed we decide yes, then there is the problem of them not accepting anonomyous submissions. Under the name of Issac Brock, someone who is “out”??? ( This is also a human rights violation in that we are all too terrified to even write our name down….that must violate something).
@ Charl
IF submissions could be anonymous then sure enough I think it’s worth a try. We could sure use some FREE legal advice on this though — the procedure, the protocols, etc. And you are right, this even violates what should be our right to use our own name without the fear of punitive measures being taken against us by a foreign government.
Posted on another site:
1) The taxes are not worth the value being returned.
I don’t have a problem paying taxes, so long as they go to something worthwhile. I will end up paying around 33% – an entire 1/3rd of my income – in my 2013 tax return. Yes, I am getting a refund, but when I am paying tens of thousands of dollars and not getting the services I should receive for that investment in my country, celebrating the return of a few hundred dollars seems absurd.
Where is my benefit from my government for all of this? Do I have free healthcare? No. Do I have a world class education for my child? No. Do I have any kind of guaranteed income should I lose my job? No.
No, instead, I have a country which is the only one in the world to tax its overseas citizens. A country that bails out banks who prey on those who just want a home to raise a family when they become insolvent – but when it happens to me, and I short sell my home, the IRS is there, ready to tax me on “phantom income” – forgiven debt.
I have a country that spends billions on fighting wars for political gain, but does nothing when there actually is evidence of WMD use against others. A country that hemorrhages so much money on military spending, it must turn around and take loans against my child’s future – her income – in order to continue to pay for programs we don’t need.
2) I’m tired of people being surprised that I’m American because I have manners, common courtesy, and the ability to see the other side of issues.
Seriously, the number of people I meet who think Americans are rascal-riding land whales (like in the movie Wall-E) with handle-bar mounted machine guns, a sack of Big Macs in the front basket, a clinical addiction to NASCAR, and a passion for the modern day artist that is Jerry Springer – it’s just too much. I’ve been introducing myself as Canadian because apparently I’m so polite, that’s where they mostly assume I’m from.
3) The fact that none of this is ever going to change, regardless of what party is in charge, and the fact that the American government continues to shred the constitution a little more each year, until it doesn’t even matter anymore.
You may not think of America as a police state, but it is. Nobody’s going to come grab you in the middle of the night, unless you’re reported as a terrorist of some kind. At that point, just forget about “police work” and get ready for the SWAT team.
Nobody is going to take your children way from you, unless Child Protective Services is called, and someone decides – for whatever reason – that it’s “in the child’s best interest” to be removed.
Nobody is ever going to interfere with your access to medicine, unless you’re trying to get something that isn’t ridiculously expensive from another country; in that case, get ready for being charged as a drug trafficker.
Nobody is going to freeze your bank accounts, passport, and other means of movement, unless the IRS believes you haven’t given them enough money. Suddenly you have debt to prove isn’t there, and it will all get “sorted out” at the blistering fast speed of government efficiency. Or you could just pay the amount they say and it all ends quickly.
4) The fact that the future for my child in the US is so dark.
All this debt, and it’s going to fall on her and her children. She’s broke, and she doesn’t even know it yet. Disgusting.
Well, I count myself fortunate that I don’t own a home in the US – it affords me the ability to even consider leaving it all behind. There’s so much propaganda about how wonderful America is but, when you look at it without those rosy lenses on, what you really see is horrifying.
@Em and @Charl, I feel gagged from openly criticizing the US govt because even after my still open statutes of limitations close, I could face harassment at the border (where all my family still are). I may never come out into the open, as a result. And this by a country with supposed constitutional protections for free speech.
I recall that that outspoken critic of FATCA in the European Parliament (sorry but can’t recall her name) faces harassment every time she tries to travel to the US. I resent all the stealth!
Smoke and mirrors. It’s just an excuse for the IRS/Treasury to pat themselves on the back – not for their newfound benevolence, but for their new trick to lure even more unsuspecting USPs into their trap. If the USA have been successful in getting any message across, it’s this: the USA are not to be trusted.
It’s great to see all the discussion about the possibility of contacting the United Nations! I just looked up the Optional Protocol to the International Covenant on Economic, Social and Cultural Rights on the UN website to see if I could find clear instructions about “how to make a complaint”. (I know I saw that statement about having to use your own name somewhere but do you think I can find it now?! ….) There is plenty of information about the establishment of a complaint procedure but no information at all (that I could find) with reference to how to go about it.
Here is the link: http://www.un.org/en/events/tenstories/08/humanrights.shtml
There is an email address for Rupert Colville, at the Office of the United Nations High Commissioner for Human Rights. I didn’t have to sign my name so I went ahead and requested information about how to file a complaint. I figure it can’t hurt to have it in our back pocket so we can use it when we’re ready.
My initial hope is that our complaint would be heard and dealt with in much the same way as was the Eritrean matter. Eritrea has not stopped its diaspora tax any more than the U.S. would stop theirs if put in the same position, but the U.S. would, indeed, be embarrassed as the full light of international censure shines on its dirty little secret. Out of that embarrassment a willingness to move to RBT might well emerge. A complaint would also serve notice to those countries that have been so anxious to sign up to FATCA that doing so has effectively encouraged the United States to engage in a human rights violation and thereby made violators out of all of them.