Friday, July 4, 2014
I saw the letter referenced below on Jack Townsend’s site and included Professor Christians in a tweet questioning the validity of the IRS’arguments regarding IGA’s. I am delighted to see she has taken this further and posted the following today on her blog.
Over at federal tax crimes blog Jack Townsend has posted a letter from the IRS to Congressman Bill Posey, in response to an inquiry the Congressman apparently made about the intergovernmental agreements (“IGAs”) to implement FATCA by other governments (instead of directly by foreign financial institutions, per the law Congress enacted in 2010). Treasury says:
“Your letter also asks about statutory authority to enter into and implement the IGAs. The United States relies, among other things, on the following authorities to enter into and implement the IGAs: 22 USC Section 2656; Internal Revenue Code Sections 1471, 1474(f), 6011, and 6103(k)(4) and Subtitle F, Chapter 61, Subchapter A, Part III, Subpart B (Information Concerning Transactions with Other Persons).”
None of these sources of law contain any authorization to enter into or implement the IGAs. It is patently clear that no such authorization has been made by Congress, and that the IGAs are sole executive agreements entered into by the executive branch on its own under its “plenary executive authority”. As such the agreements are constitutionally suspect because they do not accord with the delineated treaty power set forth in Article II. As Michael Ramsey wrote in a 1998 article, the danger is that if the president seeks to reach agreements outside of his plenary constitutional powers, the agreement lacks domestic legal effect.
Just to be clear, the fact that a document signed by an individual might or might not bind the United States as a matter of constitutional law does not mean that the United States will not honor whatever commitments the individual makes under such an agreement. The contrary is likely the case especially given the predicament Treasury found itself in, coupled with the pitiable small promises undertaken by the US in these “agreements.”
But we should be clear that the analytical terrain we should be traversing is whether the scope of the plenary executive authority can suffice to support as a matter of law the promises made in some 80 or so IGAs (many of which are currently agreements in principle only). We should not be wasting anyone’s time pretending that Congress has authorized Treasury or the Secretary of State to enter into the IGAs. It has not.
So let’s take a look at what these sources actually say.
22 USC 2656 is about the power of the secretary of state. It says:
The Secretary of State shall perform such duties as shall from time to time be enjoined on or intrusted to him by the President relative to correspondences, commissions, or instructions to or with public ministers or consuls from the United States, or to negotiations with public ministers from foreign states or princes, or to memorials or other applications from foreign public ministers or other foreigners, or to such other matters respecting foreign affairs as the President of the United States shall assign to the Department, and he shall conduct the business of the Department in such manner as the President shall direct.
If that is an authorization for the IGAs, it is a vague one at best. Does an IGA constitute “correspondences, commissions, or instructions,” “negotiations”, “memorials or other applications,” or “such other matters respecting foreign affairs”? Under what interpretation of such relevant provisions? Also there is nothing here about the content or scope of the treaty power hereby implicitly authorized. Is IRS saying that with this power the Secretary of State can bind the nation at will on any matter, without the need for the President to seek advice and consent from the Senate prior to ratification? If so this is an extraordinary claim that does not scan with either historical practice or constitutional theory.
26 U.S. Code § 1471 is, of course, part of FATCA. It is entitled “Withholdable payments to foreign financial institutions”. It sets out the reporting obligations imposed on foreign financial institutions and states that the Secretary is authorized to treat a foreign financial institution as “meeting the requirements” of 1471 if the institutions complies with procedures or requirements set forth by the Secretary or is “a member of a class of institutions” identified by the Secretary.
There is explicit authorization in 1471 for the Secretary to engage in agreements with FFIs to implement FATCA. However where is the authorization in 1471 for the Secretary to engage in agreements with other countries to implement FATCA? It is not in the text, certainly.
Therefore to what specific provision of 1471 could IRS possibly refer when it suggests this statute authorizes individuals to sign agreements altering the reach of FATCA on behalf of the United States? There is clearly no explicit authority. Is it implied? If so, by what?
Moreover, many or most of the IGAs have been signed by officers of the Secretary of State, ambassadors, consulates general and others, and not by Treasury. Does s1471 also impliedly delegate its implied treaty power authority to those outside of Treasury who have signed on behalf of the United States? Certainly there is no explicit delegation here.
26 U.S. Code §1474(f), also part of FATCA, is the statutory authorization for the Secretary of the Treasury to
“prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of, and prevent the avoidance of, this chapter.”
There is no authority expressed in this provision for the Secretary to enter into agreements with other governments. Does IRS suggest that an IGA constitutes “regulations” or “other guidance”? Under what interpretation of that characterization does the Treasury interpret the promulgation of either regulations or other guidance as an authorization to negotiate an agreement with a foreign government?
26 U.S. Code § 6011 is entitled “General requirement of return, statement, or list,” and it states the parameters under which a person must make a return “[w]hen required by regulations prescribed by the Secretary.” There is authorization in 6011 for the Secretary to require taxpayers to fulfill various reporting requirements, including electronic reporting. There is no authorization in 6011 for the Secretary to engage in agreements with other countries to implement 6011.
What provision of 6011 is IRS suggesting confers the authority to negotiate agreements with other governments without Senate advice and consent? Does IRS mean to imply that each and every authorization that Congress gives Treasury for the prescription of regulations is an implicit authorization for Treasury (or its implied designees in other departments) to conclude agreements with other governments? If so, this is a surprising claim of executive power that is inconsistent with the treaty power described in Article II of the constitution. I would think Congress would like to know under what interpretation of Congressional direction to the Secretary to issue guidance, IRS or Treasury would conclude that it now holds the power to make treaties on behalf of the United States.
In other words, if IRS stands by this authorization it is suggesting that any tax code section that authorizes Treasury to regulate implicitly contains both a treaty making power as well as the power to delegate authority to departments other than that specifically charged with implementing the statute. That is not a plausible claim.
26 U.S. Code § 6103 is entitled “Confidentiality and disclosure of returns and return information” and it provides that “returns and return information shall be confidential,” with exceptions provided by statute. There is authorization in 6103 for the Secretary to engage in agreements with taxpayers to implement 6103 (for example in the case of advance pricing agreements). There is no authorization in 6103 for the Secretary to engage in agreements with other countries to implement 6103. Therefore, as with 1471 and 6011, to what specific provision of 6103 does IRS refer, and under what interpretation of the authority given by Congress in 6103 to enter into agreements with taxpayers does IRS find the authority for anyone to enter into agreements with other countries?
26 U.S. Code Part III, Subpart B is entitled “Information Concerning Transactions With Other Persons” and it contains 26 US Code §§ 6041 through 6050W—a very broad set of statutes involving information reporting, none of which explicitly grant anyone the power to bind the nation to anything. Certainly nowhere in the subpart appears any express authorization for Treasury to enter into agreements with other governments in respect of s1471 or otherwise. Therefore the same questions I have raised with respect to 1471, 1474, 6011, and 6103 would seem to arise here.
In short I see no express authorization anywhere in any of these authorities for the Treasury to enter into the intergovernmental agreements. Moreover there is no precedent for such agreements, and they are being signed by US officials who are not members of the Treasury. Does it not seem at least noteworthy that an enormous network of bilateral tax agreements has been established, a network that dwarfs the existing tax treaty network in size and scope, all without any explicit Congressional authorization, and without any regard to the Treaty power clearly laid out in Article II of the Constitution?
And why not cite the TIEA power?
I would add that is not at all clear why any list of authorizations for an individual to enter into agreements with other governments on behalf of the United States would not include 26 US Code § 274(h)(6)(C)(f), which has long been relied upon to by Treasury to find the authority to enter into tax information exchange agreements (“TIEAs”) that were not expressly authorized by the statute (because they are not listed in Section 274 as beneficiary Caribbean Basin countries). This statute has clearly been abused by Treasury in extending it way beyond what Congress intended. However, the fact that Congress has not complained suggests that it has acquiesced to the overreach.
That makes the TIEAs good precedent for those who want to defend the IGAs as a matter of law. In omitting this, the only plausible source of support for the authority to bind the nation without the advice and consent of Senate, does IRS suggest that Treasury now backs away from this authority? If so, why would they do that? The answer is of course that IRS believes that if necessary the TIEAs can also be considered sole executive agreements, and as such a TIEA “does not need Senate or other congressional approval.” This is an official claim that the IRS doesn’t think Treasury or anyone needs even s.274 as a cover: the executive can simply act alone to achieve its tax goals through international agreements.
At the end of the day, it is clear that Treasury saw a real and serious need to work with other governments to make FATCA work. There is no disputing that fact, and indeed it is a step toward multilateral cooperation which should be celebrated if only it weren’t so lopsided, and if only it weren’t being accomplished via the threat of economic sanctions for all the world’s tax havens except the United States itself. But no amount of need or want can sidestep the constitutional delegation of powers among the branches, and the treaty power is no exception: nor should it be. At least one Treasury official has already conceded that the explanation for the IGAs is that they are “executive agreements”, not Article II treaties.
IRS and Treasury should therefore just admit that the IGAs are simply “sole” executive agreements—not authorized by Congress but entered into by the executive branch under its sole discretion.
This is a tenuous position and it ought to fail constitutional scrutiny but for the fact that in the past, Congress has acquiesced to this exercise of power by the executive and it is likely to do so again, especially given how little has been undertaken by the United States in these IGAs. As Lee Sheppard pointed out in a Tax Notes article two years ago, “An executive agreement depends on the good will of the parties to enforce it.” And as Susie Morse also pointed out in Tax Notes last year, Treasury is very likely to try to enforce their part of the IGAs.
Since the US side of the IGAs is to deliver very modest undertakings that Treasury also believes can be done without congressional approval (namely, extending the longstanding s. 6049-based information exchange with Canada to other countries), this is probably true; all IGA promises to alter the law in the future should be seen as what they are, unenforceable promises that are beyond Treasury’s control and so won’t be delivered.
Therefore honesty is still the best policy for Treasury. Instead of citing non-existent statutory authority that is easily refuted by simple reading, Treasury should own what it is doing outright. These are sole executive agreements, they lack statutory approval, they undertake very little on the part of the United States, but they are an effective way of pretending to be cooperative so that other countries can save face as they submit to the threat of economic sanctions that is FATCA. There isn’t really any reason why Treasury shouldn’t acknowledge this reality, since it is, strictly speaking, of Congress’ own making.
Posted by Allison Christians at 8:34 PM
cross-posted with permission
Good work, Tricia, and of course, Allison. Thanks for analyzing all that, Allison, and formulating your opinion — quite detailed legal description:
Like the fox is guarding the hen house;
Like putting the inmates in charge of the prison;
Like putting the lunatics in charge of the asylum;
Like asking a thief to guard the bank vault;
Like expecting the wolf to guard the sheep;
Like asking your kids to hand out the Halloween candy;
Like hiring an alcoholic to be your bartender;
Like using a monkey to watch your bananas.
(found when I googled the Mr. Fox analogy)
…and every country falling over itself to not miss the U.S. deadline to have the thief guard their treasuries.
Thank you for this review – so what is the net result? Are the IGAs attack able and by whom?
Allison Christians is a rockin’ angel. Thanks Tricia. I sent it to Solomon Yue at Republicans Overseas.
Grateful thanks Allison for laying that all out so clearly, and to Tricia for the tweet it responded to, and for posting it here for ALL to see.
The Emperor has no clothes. The US has never intended FATCA as a multilateral or bilateral treaty between equals. The US has never intended to do other than extort Canada and all the other countries of the globe, while protecting the US as a tax haven, particularly and notably Vice President Biden’s home state of Delaware, along with Nevada, Wyoming, Texas, Florida, etc.
The Canadian government knows that, and so do the other governments who have signed IGAs and chosen willful blindness or pure willfulness in their characterizations of their actions towards their own citizens and legal residents – contrary to the Master Nationality rule, and contrary to their duty to protect the best interests and security of those living inside their own borders rather than inside the US.
The Canadian government did not have to pass the FATCA enabling legislation in the Omnibus Budget Bill C-31 (part 5). And it could have held hearings in Parliament, made the issue open for public debate, but it chose not to. It chose to impose an unconstitutional US law on Canadians.
Our own federal government is lying to us. They are trying to sell the FATCA IGA as something other than what it is – the product of extortion (and a trade off for achieving perhaps some other kind of backroom deal like the pipeline?) , and borrowing US Treasury propaganda and lending credence to the lies that the US federal government is selling.
One can only hope that the spotlight will eventually be so bright that it pins down all these ‘representatives’ in both Canada and the US. I picture them in a lineup, with their hands crossed as they try to shelter their pitiful shrunken nakedness from the truth – that they have been lying to the people, in order to achieve their own political and ideological goals – in conflict with the fiduciary duty and duty of care they owe citizens, no matter what immoral and unethical things they have chosen to do and say in pursuit of their own self or party interests.
Neither the US nor the Canadian government is worthy of respect in light of their actions on FATCA.
Please please dig up the funds to make the Alliance for the Defence of Canadian Sovereignty move forward quickly now. http://www.adcs-adsc.ca/About_ADCS.html
Even if you are living outside Canada, Canada is the first line of defence to defeat FATCA as the unilateral, indefensible, extortionate weapon of economic threat and destruction that it is, and that it was always intended to be.
This is our only avenue to ensure that ethics and justice rule, not US might makes right.
Today it is FATCA imposed unilaterally. What will it be tomorrow?
@All…
I checked Townsend’s blog tonight, and did not see that anyone had posted this Allison response to that letter, (unless they have, and they are in moderation), so I went ahead added the reference for others to see. (and it is in moderation)
Also posted it on most of the FATCA Compliance linkedin groups plus a few direct tweets to Posey and Rand Paul.
@Steve
Yes, they are attack-able, and it is the hope that Jim Bobb will find some of these arguments useful in his legal battle..
http://bit.ly/Q8xlYg
This is the way to make an extremely bitter pill digestible. It is sugar-coated to appear all sort of GOOD things instead of blackmail, pure and simple.
Well, as Prof. Christians’ post points out, Treasury certainly has the statutory authority to enter into agreements with its own taxpayers. So obviously the U.S. government must be reading the term “taxpayers” to include “foreign governments”. Seems perfectly logical: every government in the world is already being taxed by the U.S., whenever the IRS buffalos a member of the American diaspora into paying U.S. taxes on the unemployment payments, government contributions to disability accounts, or general cash handouts which those governments fund out of their own tax dollars.
So clearly foreign governments fall under the definition of U.S. taxpayers. But don’t worry, little satrapies! The U.S. has a Taxpayer’s Bill of Rights to make sure you don’t get mistreated.
Just posted the following tweet:
https://twitter.com/USCitizenAbroad/status/485367182134476800
@Eric
That is a truly frightening prospect.
Well, another opportunity to plug Allison’s blog…
Is FATCA the Worst Part of the Internal Revenue Code?
@Justme
No …CBT is the worst part of the code.
Yes, @Polly, it’s actually CBT that is the main problem for us.
Allison gets another mention here:
Has Treasury Changed Its Position Regarding Capital Flight Resulting from FATCA? http://wp.me/pA2Cl-12T
Constitutional law didn’t stop the Americans from invading Iraq so why should they worry about the legalities of persecuting parking meter terrorists like us?
@Bubblebustin; @Just Me; @Polly; @Moaner –
The Canadian IGA makes FATCA Canadian law ; The Canada-U.S. Tax Treaty makes US CBT permissible under Canadian law.
While there is momentum to upend the Canadian IGA, upending the Canadian IGA should be the focus. However, revision of the Canada-U.S. Tax Treaty needs focus as well.
Example, as the Canadian-U.S. Tax Treaty does not exempt from U.S. taxation Canadian retirement accounts, the U.S. laws in regards to these accounts extend over Canadian territory as if Canada were a sovereign part of the United States. Canadian retirement accounts – incentivised by the Canadian government to help Canadians save for their retirement – get their benefit neutralised and penalised when treated by the IRS as “unqualified pension plans” as if Canadians have a choice of putting money in these “unqualified pension plans” and plans deemed qualified under U.S. Law ( 401K savings and IRA and Keogh may only be accessible by U.S. residents). Generally, the best tax breaks of either country get cancelled out by the other, under the tax treaty.
The Canada-U.S. Tax Treaty needs revision to include specific mention for Canadian tax residents: exemption from US taxation of Canadian retirement accounts, Canadian family home, proceeds of Canadian life insurance, Canadian mutual funds, and include a very significant exemption threshold from taxation – a blanket exemption – for other Canadian income and assets. Exemption may also be made against FIBAR and nonfiling penalties for Canadian tax residents.
The existing Canadian-US Tax treaty has many holes in it. One example is the new ObamaCare tax which gets put on top of all other taxes paid (and your gain in your pension account over the year gets included on top of your income to reach the threshold for this tax). This Obamacare tax law was written in a way to be exempt from any tax treaty credits!
The retirement account taxation is another example. If your income is over $105,000 you are considered a “high earner” and get taxed on the change in account value each year which gets put on top of your other income to determine a U.S. marginal tax rate that the U.S. wants to tax it at every year. If you are below US$105,000 income the U.S. wants to tax these accounts at the marginal rate when the money is taken out- similar to U.S. 401K and IRA. (Who knows what happens if you are a “high earner” one year but not the next or next many years).
Here is the rub: the Canadian-US Tax Treaty does not have provision for credit against Canadian tax for any U.S. tax paid on Canadian retirement accounts – as the U.S. tax is not considered on “foreign” income. Nor is there any credit against U.S. tax with any Canadian tax paid on Canadian retirement accounts. Plus Canadian law does not have special provision for withdrawals from retirement accounts to pay for the U.S. tax liability.
The way the tax treaty works is that each tax is considered its own silo. For instance, with earned income the extra Canadian tax paid on income compared to the U.S. tax (as the Canadian income tax rates are higher than in the U.S.) may not be used as a credit against other taxes the U.S. has but Canada does not – such as U.S. tax on Canadian pension accounts, family home, and death tax.
In my opinion, the Canadian-U.S. Tax Treaty represents the Canadian government giving up some of its sovereignty to the U.S. government in regards to Canadians who happen to be U.S. citizens. It does not have to be this way. Canada should stand up to the U.S. in regards to its right as a sovereign country for self determination of its own people free from interference by another sovereign country.
@JC, you make very good points re;
“….. However, revision of the Canada-U.S. Tax Treaty needs focus as well….”
I agree. The Harper government minions (aka Conservative MPs) keep parroting the line that Canada doesn’t have the power to change US tax law, and that they ‘respect’ the US right to make its own laws.
However, they cannot argue that it is not within their powers and responsibilities to see to it that the Canada US tax treaty does what it is supposed to do – protect Canadians from egregious double taxation. Particularly the points you raised, and the criminally negligent and utter lack of any protection of our legal local registered Canadian savings from US extraterritorial taxation. There is NO acceptable justification for the US to claim benefit from taxing and penalizing registered accounts that are tightly controlled and regulated in Canada, fulfill worthwhile important social and fiscal policy goals of Canadian society, and are partly funded by ALL Canadian taxpayers because of tax deferrals, tax grants, and tax exemptions – which all come from the Canadian fisc. The US taxation of the education savings of Canadian children and the financial security of those with disabilities are shamefully allowed by this Canadian government, despite their long reign in power – with the responsibility for tax treaty terms. The fact that the Harper government signed the FATCA IGA, yet neglected to get ALL registered savings EXEMPTED from US taxation is a glaring failure of their fiduciary duty and duty of care for all Canadians. It is not in the interest of Canada to allow a foreign country to claim the ‘right’ to tax and penalize those Canadian assets as not only taxable funds, but as ‘taxable (and heavily penalizable) foreign trusts’.
This is a point which Conservative MPs should and can be pinned down on. We did not ask them to change US laws. We asked them not to make US laws enable inside Canada. And, to meet their duty to protect Canadians and to negotiate treaties which do so. They failed on both counts.
And the Liberal leader, and the Liberals as a party have not promised to ameliorate this situation either.
When the US is perceived as going after the retirement funds of grannies living in non-tax havens like Canada, there will a general perception that the US is so desperate for cash that NOTHING will be safe. It’s all about confidence, and once that’s gone, it’s a foregone conclusion that investment will leave the US. We need to get more stories out there – like Patricia’s, like mine: IN ORDER TO BAIL THEMSELVES OUT OF RECORD DEBT, THE US IS AFTER OUR AFTER-TAX RETIREMENT FUNDS IN CANADA! NO ONE IS SAFE.
@Badger
Canada should claim right for the US to respect Canadian law, and Canada should not be too timid to act in the interests of Canadians first, rather than acting in the interests of the US government first.
@Bubblebustin. There is big hypocrisy to U.S. government laws. They let their multinationals hide from tax using “legal” means yet go after its overseas citizens in a way that they must pay far higher total tax, pay far more in tax compliance, and face really ruinous noncompliance penalties than U.S. homelanders. I believe GE does not pay any federal income tax. Plus there is some law that the multinationals only pay tax on their earnings when they bring the money back into the United States. That law would be nice to have for individuals.
So how do we build momentum in regards to getting the Canadian-U.S. tax treaty revised? In regards to the U.S. taxing retirement accounts and others listed, by allowing this to happen, the Canadian government is allowing discrimination against those Canadians who happen to be U.S. citizens. I have written a few letters to press and politicians.
@JC
Although I am behind the efforts of Canadians, not everybody here is Canadian. Many of us live somewhere else.
Pingback: The Isaac Brock Society | Canadian retirement plans of “U.S. persons” subject to double taxation
The Canadian government will do nothing until there is outrage amongst Canadians period. So far, nothing is working……
@JC…
As I always say, there is one tax law for Paper People (Corporations) and a different tax law for DNA People (you and me). Maybe we should all incorporate and hire a room full of tax attorneys and CPS to avail ourselves of the privilege of being paper.
For me FATCA is like playing a pinball machine. The ball drops and the USG gets the data.
Imagine playing the machine:
– oops USG changes rules on US Indicia, I caught that ball goes back up
– OMG the $50,000 limit has been cut to $10,000 you hit the paddle ball goes up
– Credit Unions are now reportable, gosh hit the button ball goes back up
– I ignore a letter from the bank or agree the new terms and conditions unknowingly on internet bank, THE BALL DROPS GAME OVER.
The USG has now grabbed your data.
It’s a battle the USG will wage coming at you again and again, changing the rules as we go along until that ball drops and the pinball machine lights up “USG now has your data.”
FATCA affects everyone whether your solely Canadian or not.
Anytime you touch the US you’re at risk at losing against FATCA.
In future what can happen?
You use you Canadian debit card to buy something on a US website – now you’re a US Account
You make too many withdraws in Florida over 7 months – now you’re a US Account
You send you kid money in the US for his school expensive – you’re now a US Account
You login to you Canadian bank’s internet banking site with a US IP address – guess what?
You call your bank from Florida leaving a US phone number? Guess what.
The US is attempting to control every US Dollar on the planet through FATCA.
Forget the explaining regulations, technical terms, legalese, the ordinary person doesn’t what to hear about this.
They want to know how FATCA affects them in simple terms in their everyday lives. If more and more people start asking the government FATCA questions it puts them in a position to explain. Unfortunately the Canadian Government and sadly other IGA governments remain silent hoping FATCA will blow over.
People want simple messages and they’re open their pockets more.
You now what’s even worse.
Each financial account you have represent a separate pinball machine.
So you’re really have several machines in play at the same time.
Picture it 10 machines side by side and one person jumping left right left, up and down trying to prevent a one of 10 balls dropping or the USG gets your data.
That’s the game every single Canadian, German, Italian, Brit and other IGA countries are playing.
@Don…
Very Good comment…
Unfortunately, FATCA as a subject is boring to most individuals. It gets even more complexes up with all the acronyms that keep it in the elitist category of communication. As John Oliver said, speaking of net neutrality, and I paraphrase, if you want to do something really evil, do it inside something really boring. In this regard the FATCAnatics have been very effective. There is nothing more boring than FATCA buried as an amendment in HR 2874 and the follow on regulations and descriptions. Ask yourself, how many Americans even know what HR stands for? Human Remains? or House Resolution?
I try to find simple messages to get attention, but that is not easy. But I am not the sharpest tack in the box when it comes to langauge creativity.
I recall we had an exercise once here on some long lost IBS thread to come up with simple statements about FATCA, FBAR, CBT that might get attention. I recall there were some good ones, but we don’t repeat them consistently enough to get traction or even remember what they were.
One thing about Bush that I always hated, but was effective was how he keep repeating over and over his war slogans to justify his wars.
“We fight them over there so we don’t have to fight them here.” or
“When they stand up, we will stand down.” or
“They hate us for our freedoms”.
“Bring ’Em On”
See how they have stuck. I can instantly recall them.
We need similar easy sloganeering related to FATCA.
I am always trying new short ones out to see what might stick.
“If you like NSA spying, then you will love FATCA”
“FATCA, evil wrapped up in the boring.”
Lynne has one I have always liked…
“FATCA = Foreign Attack To Control All”
of course James Jartas has one that is the most often repeated in various articles.
“FATCA, the worst law most Americans have never heard of.”
Maybe we should have a separate thread devoted to the subject of better FATCA sloganeering.
We are currently too scattered in our messaging.
What we need is a <a href="” target=”_blank”>Frank Luntz to help us define a good messaging strategy, but with July 1st past, I often wonder, is it too late. https://en.wikipedia.org/wiki/Frank_Luntz