Further to Patricia Moon’s comment here yesterday about having been contacted by Stephanie Soong Johnston of TaxAnalysts regarding the European Union’s resolution to open negotiations on FATCA with the US, Ms. Johnston’s article appeared today: EU Lawmakers Vote to Kick Start FATCA Talks With United States. It contains several quotes and observations by John Richardson along with mention of the Isaac Brock Society and ADCS.
” . . . . John Richardson, a lawyer speaking on behalf of advocacy groups the Isaac Brock Society and the Alliance for the Defence of Canadian Sovereignty, noted that only a few countries confer citizenship based only on birth in their countries and that only two countries impose worldwide taxation based only on citizenship: the United States and Eritrea. The United States, however, is the only country to do both, according to Richardson.
Richardson welcomed the EU resolution because it recognizes that the United States is imposing worldwide taxation on people who are tax residents of Europe and have no connection with the United States, adding that the combination of FATCA and U.S. citizenship-based taxation has rendered the citizens and residents of other countries as second-class citizens in their home countries.
“’On a broader level, the EU resolution will be welcomed by Canada and other countries who are suffering the effects of U.S. extraterritorial laws — FATCA and citizenship-based taxation,’ Richardson said. ‘All countries should support the EU resolution and all countries should work together to ensure that U.S. tax laws cannot extend to the tax residents of other countries.’”
I confess I haven’t bothered reading Sophie in’t Veld’s treasure trove. Maybe I should have a browse. I’ve rather taken it for granted the turnaround was a case of “Yes, Minister”, as it certainly does smack of perfidious Albion. If there’s evidence suggesting that the IGA was instead the EC’s brainchild, that would certainly be a turnup for the books.
Doesn’t quite seem to fit, but not impossible by any means.
So I’ve had a look at the first few documents, and indeed it’s clear that discussions were going on between all parties (except, of course, those most affected, but that’s nothing new 🙁 )
Looks like I’ll have to abandon my previous theory (in which I blamed the UK turnaround primarily on Geo. Osborne and the British civil service). Just about every issue mentioned in the G5-US Joint Statement was raised in these prior discussions.
The picture that seems to be emerging from the documents fits a lot better with how one might have expected the Commission to go about responding to FATCA.