Patricia Moon posted part I:
In Part II, the author argues (among other things) that FATCA is nothing more than a continuation of the “FBAR Fundraiser“.
Here we go …
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Reposted with permission of Tax Connections.
Written by Gary Heald | Posted in FATCA • Gary Heald
In FACTA Part I, I argued that in light of the Joint Committee on Taxation (JCTX-5-10),[1] Congress failed to engage in the necessary due-diligence to reasonably relate FATCA to the collection of tax revenue lost through “tax schemes” and “tax evasion” by U.S. persons with foreign financial institution accounts. Congress operates as America’s legislative fact-finder. They are charged with determining whether relevant and reliable evidence negates the underlying policy-purpose for a particular law, when presented with evidence to that effect. JCTX-5-10 was directly relevant because it offered a direct answer to the question of “how much” FATCA revenue. As for reliability, the Joint Committee on Taxation produces some of the most reliable evidence on The Hill, and this was no exception to that general rule. Congress knew FATCA would collect less than one-half of one-percent of what was sworn to during the Ways and Means hearing estimates.[2] They also knew that even after ten-years, FATCA would not fully-fund the Hiring Incentives To Restore Employment (HIRE) Act (and that does not take into account the costs for implementation and renewed requests for additional expansion and implementation funding).
In Part II, I want to touch on three related areas of concern. First, and as has been discussed by more than a few other people, the $10B that the IRS collected between 2009 and 2016 included a disproportionately low amount of tax revenue coupled with a substantial amount of penalties associated with FBAR. Further, alongside a disproportionate amount of penalties, FATCA and Offshore Voluntary Disclosure Programs (OVDP) illegally filled the gap left by Qualified Intermediaries (QI) pooling, forcing foreign financial institutions to report on the account value of U.S. persons in violation of their own law, and if reproduced domestically, in violation of our own laws as well.[3] Finally, FATCA has become a continuation of the IRS war on FBAR perpetrated by Treasury’s Financial Crimes Enforcement Network (FinCEN), federal law enforcement and the intelligence community all of which sought to curtail the use of secret foreign bank accounts for illegal purposes (e.g., tax evasion as well as securities manipulation, insider trading, evasion of Federal Reserve margin limitations, storing and laundering funds from illegal activities, and acquiring control of U.S. industries without detection by the SEC) [4] by establishing a worldwide-financial-industry informant system.[5]
According to the U.S. Treasury, FATCA and Offshore Voluntary Disclosure Programs (OVDP) increased individual reporting to the IRS by 19% ($75B), resulting in an overall increase in taxes, interest and penalties of $10B.[6] My-oh-my that sounds like a success. In fact, the exact language “Updated data shows 55,800 taxpayers have come into the Offshore Voluntary Disclosure Program (OVDP) to resolve their tax obligations, paying more than $9.9 billion in taxes, interest and penalties since 2009.” Neither the 10-year $8.7B JCTX-5-10 FATCA estimate, nor Treasury’s reported $10B increase in taxes, interest and penalties breaks down how much of that $9.9B collected, was from tax revenue, interest or penalties.
Back in April of 2017, Associate Dean and Professor William Byrnes at Texas A&M School of Law wrote a piece for Wolters-Kluwer entitled: Is FATCA ‘Much Ado About Nothing’? Is FATCA’s Tax Revenue Going to Offset its IRS and Industry Costs? In this piece, Professor Byrnes noted that “according to the Government Accountability Office Report of 2013[7], for small accounts of less than $100,000 that over a six-year period had only an average of $103 tax owing (that equals $17 a year additional tax revenue), the IRS imposed a FBAR penalty of $13,320 (i.e., $2,220 a year FBAR penalty on average for $17 dollar tax understatement, in additional to the tax penalty and interest).” Calculating that penalty as a percentage of the non-reported income reveals that just a little over one-half-of-one-percent of the total revenue collected was in-fact tax revenue (0.0076), for the smaller accounts. As you will see below, the larger accounts pay half or less the penalty percentage on average of the smaller account holders. That means, on average, their tax revenue was about 1.5% -2.0% of the total revenue paid.
The penalty for FBAR was aimed at criminals and bad actors, but non-criminal benign actors have been impacted the greatest, eroding the distinction between willful and non-willful violations. It is pretty obvious that people who are unrepresented by counsel or have small accounts are perhaps more likely to make inadvertent reporting violations than those who are represented or have large accounts.[8] Under the 2009 OVDP the median offshore penalty paid by those with the smallest accounts was nearly six times the median unreported tax, as compared to about three times the unreported tax for those with the largest accounts.[9] Under the 2011 OVD program, the median offshore penalty for those with the smallest accounts rose to eight-times the unreported tax.[10] This undermines the policy purpose of FATCA further – FATCA is not only mostly FBAR penalty revenue, the penalty itself was designed to be imposed only as a punitive penalty to penalize purposeful tax evasion as well as securities manipulation, insider trading, evasion of Federal Reserve margin limitations, storing and laundering funds from illegal activities, and acquiring control of U.S. industries without detection by the SEC![11] Now, benign reporting violations make up the lion’s share of the penalty income.
For whatever reason, JCTX-5-10 did not break up total-revenue by tax, interest and penalties. Whether the JCT estimate actually included substantial FBAR penalty revenue as the offset base for HIRE, coupled with a small amount of tax revenue collection could be the subject of an interesting inquiry.[12] However, it is more important that the IRS did not to reveal the total amount collected was primarily penalty revenue related to FBAR non-compliance, that FATCA collects very little tax revenue. A good reason not to reveal this information is that it might interfere with petitions for additional implementation funding from Congress.[13] I am not blaming the IRS, really it is an issue with FinCEN, Treasury and federal law enforcement and their need for a more complete informant system, as the Qualified Intermediaries (QI) Program was unable to tie the individual identity of the U.S. account holders to all of the accounts.
What it looks like to me is that the IRS was forced to create a foreign financial institution informant structure to force U.S. persons with foreign financial institution accounts to report FBAR values.[14] Since 1970, when Congress enacted the Bank Secrecy Act (BSA) requiring FBAR compliance federal law enforcement had extreme difficulties enforcing FBAR compliance. In 2002, Treasury reported to Congress that the FBAR compliance rate was at 20%.[15] But by 2003, Treasury issued another report noting that FBAR civil enforcement had been delegated to the IRS noting in the report that “one could argue the FBAR is directed more towards tax evasion, as opposed to money laundering or other financial crimes that lie at the core mission of FinCEN”.[16] Put another way, the inability of federal law enforcement to mandate FBAR compliance caused FBAR enforcement to shift to the IRS because they were well-equipped to enforce compliance. As is made clear from the legislative history in Part I and in the revelation in Part II that the $10B collected was substantially from penalties associated with FBAR, FATCA should reasonably be considered a continuation of the IRS war on FBAR and the magnum opus of FinCEN, federal law enforcement, the intelligence community and others who seek to curtail the use of secret foreign bank accounts for illegal purposes (e.g., tax evasion as well as securities manipulation, insider trading, evasion of Federal Reserve margin limitations, storing and laundering funds from illegal activities, and acquiring control of U.S. industries without detection by the SEC) [17] by establishing a worldwide-financial-industry informant system.
[1] Technical Explanation & Estimated Revenue Effects of the Revenue Provisions Contained in Senate Amendment 3310, The Hiring Incentives to Restore Employment Act (HIRE), JCTX-4-10 and JCTX-5-10.
[2] Evidence revealed an estimated $150B was lost annually through offshore tax evasion in 2009, but by February, 2010 the JCT clarified that all FATCA should be expected to collect over ten-years, was $8.7B Banking Secrecy Practices and Wealthy Americans, House Ways and Means Subcommittee. on Select Revenue Measures, 111th Cong. (2009).
[3] The Fourth Amendment protects against unlawful search and seizure by requiring a warrant be obtained by federal law enforcement agencies, from a judge if and only if they are able to establish probable-cause (with a number of exceptions, but none for bank account values). As a point of fact, FinCEN, the CIA, FBI, SEC, DEA and all other federal law enforcement agencies are bound by the U.S. Constitution. Senator Rand Paul and Congressman Mark Meadows discuss these issues at a hearing designed to communicate the unintended consequences of FATCA to Congress. Available at https://oversight.house.gov/hearing/reviewing-unintended-consequences-foreign-account-tax-compliance-act/.
[4] Taxpayer Advocate Annual Report to Congress (2014). Citing to 31 U.S.C. §§ 5314, 5321; 31 C.F.R. §§ 1010.350, 1010.306(c); FinCEN-Form 114, Report of Foreign Bank and Financial Accounts (FBAR), http://www.fincen.gov/forms/bsa_forms/.
[5] Part III will include an impact statement through my lens, of some of the lesser discussed issues.
[6] Internal Revenue Service, “Offshore Voluntary Compliance Efforts Top $10 Billion; More Than 100,000 Taxpayers Come Back into Compliance,” October 21st,2016 available at https://www.irs.gov/uac/newsroom/offshore-voluntary-compliance-efforts-top-10-billion-more-than-100000-taxpayers-come-back-into-complianceIn fact, the 10BB likely results from the UBS-driven initiatives that resulted from normal investigatory techniques such as whistleblowing, prisoners’ dilemma, Congressional hearings, and John Doe summons enforcement.
[7] GAO-13-318, Offshore Tax Evasion: IRS Has Collected Billions of Dollars, but May Be Missing Continued Evasion.
[8] Id at 4, P. 85.
[9] Id at 4, P. 86.
[10]Id,
[11] See FN4 and accompanying text above.
[12] The government should be able to more precisely re-estimate future income tax revenue generated from FATCA. The re-estimate should not include anti money laundering related penalties associated with FBAR, because that is not tax revenue from U.S. persons evading tax though the use of an FFI.
[13] Ibid at 11. The hearing, in part, is prompted by an IRS request for an additional funding for broadening and implementing FATCA.
[14] I’m not alone in believing this. Dennis Kleinfeld, a prominent tax attorney in southern Florida, wrote an article for NewsMax (a well-respected conservative media outlet) which came to a closely-related conclusion. The article is available at https://www.newsmax.com/finance/deniskleinfeld/republicans-fatca-gop-trump/2017/06/04/id/794044/. Dennis states that the greatest concern is the complete loss of financial privacy, by treating everyone holding a financial account anywhere in the world as a U.S. tax evader , requiring all U.S. persons to report to the U.S. government even the smallest financial details, or be subject to civil and criminal penalties.
[15] U.S. Department of the Treasury, A Report to Congress in Accordance with §361(B) of the Uniting and Strengthening American by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, 6 (Apr. 26th, 2002). The estimate of required FBAR filings was based in part on the number of credit and debit cards held by U.S. citizens and residents to access funds in offshore accounts. See Taxpayer Advocate Annual Report to Congress (2014).
[16] Cite to 2003 Treasury Report – sending FBAR to IRS. I do not disagree that the IRS is a better enforcement body generally than
[17] Ibid. at 4.
I stated long ago at IBS that FATCA is the enforcement mechanism for FBAR and was told that such was not the case. This is the second well researched posting here that I have seen in recent months making the case that FATCA is indeed FBAR’s enforcement mechanism.
Then we have this.
“The penalty for FBAR was aimed at criminals and bad actors, but non-criminal benign actors have been impacted the greatest, eroding the distinction between willful and non-willful violations. It is pretty obvious that people who are unrepresented by counsel or have small accounts are perhaps more likely to make inadvertent reporting violations than those who are represented or have large accounts.[8] Under the 2009 OVDP the median offshore penalty paid by those with the smallest accounts was nearly six times the median unreported tax, as compared to about three times the unreported tax for those with the largest accounts.[9] Under the 2011 OVD program, the median offshore penalty for those with the smallest accounts rose to eight-times the unreported tax.[10] This undermines the policy purpose of FATCA further – FATCA is not only mostly FBAR penalty revenue, the penalty itself was designed to be imposed only as a punitive penalty to penalize purposeful tax evasion as well as securities manipulation, insider trading, evasion of Federal Reserve margin limitations, storing and laundering funds from illegal activities, and acquiring control of U.S. industries without detection by the SEC![11] Now, benign reporting violations make up the lion’s share of the penalty income.”
Which is why I keep warning that we need to look more at how things are actually implemented and not so much at how they are suppossed to be used.
“The penalty for FBAR was aimed at criminals and bad actors, but non-criminal benign actors have been impacted the greatest”
It’s good that he’s on our side, but I wonder why he makes such a big understatement. It’s not even news any more. Does he know about this:
https://isaacbrocksociety.ca/2013/04/27/gao-report-reveals-ovd-minnows-paid-up-to-129x-more-in-penalties-than-in-tax-owed/
He’s giving the history of FATCA, hence the title,
“legislative-history-reveals-fatca-had-nothing-to-do-with-collecting-tax-revenue-from-u-s-persons-with-foreign-accounts-evading-taxes”.
But even with the repoerted upon record of FATCA’s take and FBAR fines for minnows, there are still those who argue here that FATCA is not the enforment mechanism for FBARs, so it seems that there may be info in here that is news to some.
Would be nice if these ‘investigative’ journalists https://www.icij.org/blog/2018/07/irs-spent-380m-but-took-limited-or-no-action-on-offshore-tax-dodges/ did some actual investigation, and acknowledged that FATCA is a sledgehammer https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2247615 pounding ordinary people like ‘accidentals’ already paying full taxes in their non-US home country where they actually work, earn, save and live. AND help pay for the US FATCA free lunch – the admin costs and denial of local banking and foregone opportunities paid for by the rest of the world just so FINCEN and the IRS and the FATCAnatics can pretend that they’re uncovering US resident billionaires – while not actually resulting in the recovery of US taxes owed. Particularly because it is a fishing expedition that serves to punish minnows and small fry who are less likely to owe the US taxes, who pay fully to their home country, and whose accounts are local and legal and under the oversight of their home government and its own tax agency.
Where is the acknowledgement that those renouncing/relinquishing are mostly ordinary people whose only remedy for US extraterritorial arrogance and greed is to sever even the most tenous of involuntary USness? The evidence is easy to find that the growing numbers are NOT US homeland resident billionaires, ex. http://isaacbrocksociety.ca/2018/05/07/1102-names-in-late-as-usual-irs-list-of-certain-ex-citizens/ and at the IBS compiled reports of actual relinquishers and renouncers http://isaacbrocksociety.ca/renunciation/ . But instead, the same old bs is trotted out that it is tax dodgers and evaders hiding money in the Caymans that are giving up their US status.
If the ICIJ cared to, it could look into why FATCA is abhorrent to the non-US countries the US extraterritorially foisted on the rest of the world – without reciprocity – via extortionate means – at the end of the FATCA witholding threat weapon.
Why doesn’t the ICIJ do some real investigation into FATCA and US extraterritorial CBT?
ex. looking into why there are objections, and they are not coming from US homelanders hiding money ‘offshore’.
http://isaacbrocksociety.ca/2014/07/28/human-rights-complaint-on-behalf-of-all-u-s-persons-abroad-has-now-been-submitted/
http://isaacbrocksociety.ca/2015/02/17/adcs-adsc-litigation-updates-key-actions-milestones-and-timeline-estimates/
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-%2F%2FEP%2F%2FTEXT%2BMOTION%2BB8-2018-0306%2B0%2BDOC%2BXML%2BV0%2F%2FEN&language=EN
https://petiport.secure.europarl.europa.eu/petitions/en/petition/content/1088%252F2016/html/Petition-No-1088%252F2016-by-Mr-J.R.-%2528French%2529-on-the-US%25E2%2580%2599-Foreign-Account-Tax-Compliance-Act%25E2%2580%2599s-%2528FATCA%2529-alleged-infringement-of-EU-rights-and-the-extraterritorial-effects-of-US-laws-in-the-E
https://www.icij.org/blog/2018/07/irs-spent-380m-but-took-limited-or-no-action-on-offshore-tax-dodges/
“….The IRS hoped U.S. taxpayers hiding money abroad would declare their assets for fear of being ratted out by their agents.
And, after the law’s original passage, the rate of Americans renouncing their citizenship, and thus no longer subject to FATCA’s tax provisions, accelerated after the law’s passage, according to Bloomberg News.
But such extremes measures may have been unnecessary. The TIGTA determined the IRS had taken “limited or no action on a majority” of measures to enforce the offshore tax law included in a so-called “compliance roadmap.”….”….
Even the IRS’ own Taxpayer Advocate has noted the problems with FATCA.
We can expect no more accuracy in the reporting of “Our” issue than can be found in the reporting of any other issue.
@badger: If the ICIJ cared to, it could look into why FATCA is abhorrent to the non-US countries the US extraterritorially foisted on the rest of the world – without reciprocity – via extortionate means – at the end of the FATCA witholding threat weapon.
Haha. Remember like five years ago, we wrote in and asked ICIJ to do exactly that, and they pretended to pay attention? The blogger there even said, “I intend to follow up on this inquiry in upcoming postings.”
https://www.icij.org/blog/2013/12/mystery-fleeing-americans/
https://www.icij.org/blog/2013/12/americans-abroad-denounce-offshore-tax-laws-unintended-consequences/
In one ear and out the other, looks like it was. The phrase “Americans abroad” has not appeared on the ICIJ’s blog since then.
OVDP is a real easy way for drug dealers and traffickers to pay taxes and turn black money to white. For only 30% penalty (tax), black money can be made white. It’s the ultimate and cheap method for drug dealers to operate. The other industries have to pay corporate tax and personal tax on their profits. OVDP is a discount over that.
OVDP: The best tool for money laundering yet!
@Mark Twain notes:
Absolutely correct. OVDP has been “in effect” an alternative tax compliance system for untaxed revenue. The effect has been to allow those in the cash economy (including organized crime and drug dealers) to get their money into the system (if they want to).
FATCA seems more to me like it’s aimed at making use of the USC CBT Midas touch (turning foreign money into US money, as with the transition tax) than catching criminals. Why else would the IRS be using the FATCA reports to build a database of US citizens’ retirement savings? Why did the IRS include same-country accounts, if not to get FFIs to feed them information about USCs’ foreign-source assets and income?
And I have to differ with the writer about blame. I do blame the American IRS.
However; if he’s aiming towards calling for the repeal of FATCA by the Republicans, as per the Newsmax article cited, I’ll drink to that. Don’t care why they do it if they’d just damn well do it.
“OVDP: The best tool for money laundering yet!”
Good point. But for one-time use?
FATCA reports also can’t easily be tied to the individual identity of the US accountholder if the US accountholder doesn’t file US tax returns and doesn’t sign W-9 / hand over SSN. But one big difference between FATCA and the QI system is that the QI system only requires US-source income to be reported. (https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=1791&context=njilb)
To the Americans, this non-reporting of the foreign source income of a US citizen is tax evasion. US citizens are supposed to accumulate capital in the US, not in foreign countries.
When the UBS scandal first broke, it seemed to be about US-resident USCs sending US-source money to Switzerland; but it turned out most of the accounts that got turned over just belonged to USCs resident in Switzerland.
To any normal country, that would be seen as showing that they had over-estimated the tax-evasion problem; but to the US, it was instead confirmation of widespread tax-evasion by US citizens hiding money in foreign bank accounts.
FATCA hits who it’s aimed at. I thought at first, and for quite a long time, that USCs with local accounts were “unintended victims” – favourite glib lie of US legislators – but openly building a database to target expats’ assets is simply not consistent with that view. And nor is the fact that innocent expats are the main group that gets reported on.
And FATCA’s not there to enforce FBAR, IMO. The FBAR penalties don’t touch non-filing expats – who make up the huge majority of US citizens holding “foreign” accounts.
“And FATCA’s not there to enforce FBAR, IMO. The FBAR penalties don’t touch non-filing expats – who make up the huge majority of US citizens holding “foreign” accounts.”
While that is true, it is the FBAR fines that account for the largest share of the revenue FATCA has brought in. FBAR is also an asset reporting regime. That is where the asset database comes in handy. Anyone caught not reporting their assets via FBAR but are having those assets reported by their FIs are in for huge FBAR fines.
Yes. It is true. No ifs, buts, or howsyourfathers. FBAR penalties don’t get imposed on non-filing expats, who are by far the largest cohort of US citizens holding non-US accounts. So I find it hard to believe FATCA was designed to enforce FBAR penalties.
“ut one big difference between FATCA and the QI system is that the QI system only requires US-source income to be reported. https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=1791&context=njilb”
The article says:
“The QI system requires foreign banks to enter into Qualified Intermediary Agreements with the IRS, to identify and document any customers who hold U.S. investments or have received U.S.-source income into their offshore accounts, and withhold income tax from payments of U.S.-source income received by foreigners.”
The IRS as well as TD Waterhouse call that a pack of lies. They say the QI system requires non-US banks to identify any customers who have US citizenship and withhold US income tax from payments of non-US-source income received by US citizens.
“FBAR penalties don’t get imposed on non-filing expats, “
“Don’t” is not “can’t” nor is it “won’t”. The IRS seems to like getting several years of noncompliance documented and then move in for the kill.
Besides enforcing FBAR fines, which already exist, or a wealth tax, which does not, what else would this data base of assets held by by USCs be used for?
“The IRS seems to like getting several years of noncompliance documented and then move in for the kill.”
Don’t heroicize the IRS. It’s a corrupt under-funded agency of a failing superstate. The post at the top of this thread is talking about why the US politicians dreamed up FATCA. The writer suggests FATCA was created to force non-US-resident USCs to report non-US bank accounts and penalize those who don’t, yet that’s not what FATCA does.
FATCA threatens banks, the banks threaten the customers; some non-filers respond by “coming into compliance” and signing up for FBAR penalties.
But most don’t. Some renounce; the majority carry on not filing US tax returns or FBARs.
“They say the QI system requires non-US banks to identify any customers who have US citizenship and withhold US income tax from payments of non-US-source income received by US citizens.”
Got a link to where that’s stated? I know very little about the QI programme.
I said: “Got a link to where that’s stated?”
Never mind, found it. Thanks for the correction.
“Never mind, found it.”
You found a link? Please post it.
In 2003 the IRS answered questions by e-mail, and that’s all I have on that particular topic. In 2003 it was amazing. Even though the answers were ugly, they were on-topic and the IRS employee really answered my questions.
Not an IRS link.
“a so-called backup withholding tax of 30%5 is levied on a wider range of sums paid to insufficiently identified persons that are, or are presumed to be, subject to U.S. tax on their worldwide income (U.S. persons, essentially, U.S. citizens and U.S. residents)”
http://www.mondaq.com/germany/x/18833/Corporate+Tax/266+US+Withholding+Tax+IRS+Issues+Final+QI+Audit+Guidelines
All the “sovereign” nations are now us empire territories/colonies. Canada–what a joke.
If the FATCA and/or CBT repeal with massive changes does not appear on pt deux of Trump’s tax plan. It’s. Over. And instead of someday talk, rich lawyers selling fear, the usa empire tax “compliance” (bend over and pay us) industries selling agita, poetic statements lifting passages to try to tease hairs in a moronic empire, what’s the pt?
Renounce. The us empire hates you. You’re fungible. They want $ for imperialism and endless enemies/war. 400yrs+ of this feces. All reasonable and appropriate paths lead to: RENOUNCE. AVE.
Perhaps, the society can create a fund to help those unfortunate, to cough up the huge $2,350 us empire renounciation fee? Highest in the world…..so called “freedom” and eating propaganda from a dying empire that stood for NOTHING, other than: get money, get more money, and imperialism.
@jon
Your message is too simply simplistic. What if you can’t afford to cough up or just refuse to submit to extortion. Are you doomed to eternal damnation .If you have no other recourse ,of course you go for renunciation. If you live somewhere where you can get around it ,then all you do is bend over and crack them a smile.
Dear Robert Ross–appreciate the response.
What if one CANNOT get around the hu$tling us empire for their endless manifest destiny? The US hates those that leave. There’s a very good reason why the us empire has employment at whim/will doctrines, no mandatory vacation time, monolinguistic, us “education” sucks, etc/etc///–keep the corporate slaves at bay and down on the farm.
One is us tax subject; basically, owned by the US empire until they die for taxes –CBT. If one refuses to comply–good luck trying to getting a mortgage, mutual fund, life assurance, etc…as a US tax subject, one is toxic.
Also, the huge us empire renounciation fee-racket is a small glimpse into what the us was really abt.
Is there a society or foundation that will help those pay the huge us empire renounciation fee ($2,350 CURRENTLY), and help those break free of the us CBT racket?
My opinion is that all the chanting, energetic speeches, letter writing, someday talk, “social” yammer, is akin to pounding sand. the usa empire does not give a rip. It’s. Over. Except to break free of the us empire and live an ontologically full life.
@Jon
The ” american empire ” will not get ride of its CBT and IMHO most of the people on IBS realize this .
But if you have blind faith and like having it dashed continually, well ,good luck.
As for the renunciation fee ,if demand dictates price ,the fee will go up.