Friday, November 9, 2012

Commissioner Shulman Retires After Five Years of Service as Commissioner

Mention retiring Commissioner of Internal Revenue Doug Shulman and some Americans abroad see red and misdirect their anger at him over FATCA and the IRS’s new focus on FBAR-only audits and enforcement. Last week he gave his goodbye speech and listed what he considers to be his accomplishments over his five year tenure. Six of seven items listed by him are soft and gooey government "management-speak"- type things like sensitivity to the work force and the techno-challenges the IRS faces, but front and center was surely the single thing Mr. Shulman wants to be remembered for: the IRS muscle flexing in the international enforcement arena.

During Mr. Shulman’s tenure, the financial world witnessed two developments: the almost complete capitulation of the Swiss banking industry to the IRS, and what has been essentially a world-wide muted objection to FATCA itself, and the fact that for the most part, the international financial community is rolling over by spending billions of dollars to make their IT systems compatible with the reporting requirements of FATCA.

For decades, IRS management has been worried about the Service’s ability to do its job efficiently if everyone was permitted to continue to file paper returns. E-filing has helped here but the IRS still has a long way to go. In this regard, the IRS was surely bluffing when FATCA came on the scene and the agency announced that every bank in the world had to become a withholding agent for the U.S. government and enter into a separate FFI Agreement with the IRS National Office by January 2013. It would be hard to imagine Congress authorizing the IRS to hire the number of people necessary to make that happen at all.  And while that date has been pushed back more than a year, the real action with FATCA is in the area of intergovernmental agreements, or IGA's. Just yesterday, the Treasury Department boasted in a press release that it was engaged with 50 separate countries to negotiate a country by country exchange of information agreement under which there would be an automatic exchange of information between the US and each country so that bureaucrats all over the world could find out which of its respective citizens might be playing fast and loose with undisclosed bank accounts and avoiding US taxes on the one hand or foreign taxes in their own respective countries.

What Mr. Shulman is likely most proud of is the fact that under his watch, the international financial community has taken a giant leap forward to establish a virtual international banking data base available to US law enforcement agencies and "FATCA Partner" countries.




20 comments:

  1. Your blog is a report card - what about giving him a grade.

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  2. Just one more of those "good willed" folks at IRS who have turned lives of US Citizens (and former citizens) topsy turvy.

    Shulman may not have been the architect of FATCA, but he sure was an enthusiastic builder in his proclamation of honest law-abiding Americans whose only crime is to live outside Us as tax evaders and tax cheats.

    Good Riddance!

    Anonymous: I give Shulman an F, especially in "good will."

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  3. Stephen you are correct on Expats feelings about Shulman. He may not have passed FATCA or FBAR into law, Congress did, but his discretionary administration of the OVDP penalty regime have had indelible impacts on lots of minnow Expats. It was all unnecessary, if only FBAR compliance, and not penalty extortion the main objective.

    In the beginning, these programs were US homeland evader directed. US persons abroad were not in focus at first. He could have moderated the impacts early, but did not. He ignored the TAS reports to Congress. He stonewalled Nina Olson's TAD on of 2009 "bait and switch"! He only reluctantly created 'Opt Out' relief later, and than a belated narrowly defined 'low risk' program that is full of risk.

    Congress after 2 years, has done nothing to reign him in, so now are complicit in these impacts around the world, with the increasing numbers of those shedding their citizenship.

    How is this good for America? How is the anger now directed back at the homeland a positive development? You can dismiss as hyperbolic or over-the-top, but it is what it is. There is a direct 'cause and effect' line to his discretionary administrative policies. Does America really need thousands of negative marketing agents around the world advising people to stay away?

    Now he will soon find a new high paying job probably defending or advising the victims of his programs. Hate to be so cynical, but there you go. He altered my view of this bureaucracy forever.

    At its mid to lower levels, there are good and decent people at the IRS, just doing a job. The 'best and the brightest', if I recall your words. However, somewhere in leadership combined with the worlds worst tax system for complexity, there are real systemic failures in administrative execution of a fair and just tax collection effort.

    If leadership can't just make some common sense course corrections to do the right thing, when they plainly can see they are netting the wrong fish, there is no hope.

    His, is a failed Commission, as far as I am concerned. Good riddance, not that Stephen Miller will be any better. It is the nature of the beast, I suppose. They live an echo chamber and have a religious fervor in their single minded 'War on Offshore Tax Evasion, damn the collateral damage. They seem to deliberately put on the ear muffs, so as not hear hear the cries of the minnows they grind up in their processing mills.

    Your comments on FATCA are true enough. The automatic information exchange is exactly what the FATCANATICs want. A global GATCA.

    FATCA begets DATCA begets GATCA.

    What still remains to be seen is if Congress will allow the IRS to usurp their prerogatives, and just apply their bureaucratic regulatory will on a Global community with the IGAs.

    I am pretty that was not Congress's intention. I think you are right that the IRS was surely bluffing at first, but now they have the FCC, the FATCA Complaince Complex, acting as co-enablers and marketers to force FFIs into compliance. The FCC suckles on the regulator teat, and the IRS still says they are going to issue final regulations by year end. Looks like more than just a bluff to me.

    I don't know where they come up with the administrative staff to manage this. It is bound to be a FATCA fiasco. Hell, they can't manage the 1099 homeland audit processes, or the fraudulent ITIN issues, and yet now, they want to be world's FATCA compliance police? Give me a break! They have billions in uncollected taxes on the homeland, and they now want to act as the global tax cop?

    Now, by imposing unilaterally the IGA reciprocity requirements via DATCA on US banks, they are expatriating the cost of FATCA back onto US shores. Will this eventually lead to FATCA Fallout in the US financial services industry? I think it will, but I could be wrong. Time will tell, but if you believe some limited news coverage reported in the Miami Herald, capital flight has already started.

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    1. I just have to add, that in many ways, the IRS and FATCANATICs War On Offshore Tax evasion, (WOOTE) is like our Drone War in Yemen. It is SO SO seductive to think we can solve these problems with unilateral US drone power without serious collateral damage.

      Doesn't work.

      Listen to this: 'The Last Refuge': Fighting Al-Qaida In Yemen http://n.pr/SYiXAW

      Similarly, we think we can close down 'The Last Refuge for Evasion Offshore' with WOOTE using FATCA IGA drones, or just make every one who didn't file an FBAR join an OVDP and kill the offending fleas with penalty hammers.

      It won't work either.

      As we have seen, it just creates so many unintended negative consequences and increases the non compliance with those that permanently leave, NEVER EVER to be a US tax payer again. Great idea!

      They don't go away silently without relating their stories to possible new immigrants looking for the American dream on the U.S. FBAR / FATCA penalty shores. It creates another loss to the U.S. Treasury from a future taxpayer who decides Canada or Australia looks more attractive now for immigration.

      Are there any lessons to learn from our drone war in Yemen, where our 'precision strikes' has not decreased the numbers of Al-Qaida or the threat of terrorism on the homeland?

      It has had the opposite effect by doubling the active members. The collateral damage has even the killed local Al-Qaida opposition, so strengthens the movement!

      Mission Accomplished?

      Will FATCA carpet bombing of the globe be any better with the automatic global GATCA it is trying to create?

      I think not. Currently, Americans are ill informed enough to believe we are winning this drone war. They have no curiosity to really understand what is happening.

      With FWhat?, journalist are lazy enough to just repeat Shulman's Swan Song of Success (SSSS) on WOOTE without ever challenging the narrative, or actually looking at the FBAR and FATCA fallout.


      The FATCA drone war will not improve our tax revenue collection or increase ranks of the willing compliant without lots of expensive collateral damage. You can see it everywhere, if you just look!

      Could any marketing agency create a better negative advertising campaign that has gone viral in the Expat community? Even now it is seeping into the popular US internet media coverage at Huffington Post. Read some of the > 670 comments this story has stirred up as a result. http://bitly.com/Ury4og

      What is the impact of this type of this negative message for the American Dream? Is this a positive legacy result that Shulman is so proud of?

      The problem with Shulman and those inside the IRS bureaucracy group think echo chamber,(and with Congress in general too), is they always think the BIG expensive programs are the way to a desired objective, i.e. a WAR on Drugs, WAR on Terrorism, WAR on WMD, WAR on Poverty, WAR on Offshore Tax Evasion. We really like our great BIG Expensive WARs, WARs, WARs!

      However, show me one real success for all these BIG WARs that could not have been accomplished for less expense and way less collateral damage? How long can the Empire continue to afford them?

      American needs to learn to be more humble and less hubristic in their efforts. Instead of BIG imperial programs (WARs), start focusing on the 'small stuff', not the GRAND missions.

      In the end, the small stuff is much better at moving you towards an intended goal. The IRS and Congress needs to deploy compliance nudges, not WOOTE with its FATCA or FBAR OVDP drones that come with its over kill and collateral damage.

      The problem for the Shulmann legacy, is he never learned to 'Sweat the Small Stuff' when it came to a compliance mission.

      His 'myopic focus' (his words) on grand automatic global GATCA missions was his error. The big expensive programs seduced him! http://bit.ly/c3XmKG

      Anonymous of November 9, asks, "What about giving him a grade?

      I say 'F' for failure.

      FWhat? Homeland Americans ask in reply.

      Our mission is to inform them.

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    2. I feel every thing Mr. Jut Me written is right except:

      Does America really need thousands of negative marketing agents around the world advising people to stay away?

      If this unholy-jihad continues it will be not thousands but millions of duel-citizens and green-card holders returned to their countries.

      Delete
  4. I can understand that there are times where the application of the iron fist may be relevant. The law is the law, it must be enforced and tax cheats must be brought to justice.

    My main concern with this is the extent of one's understanding of global affairs and the ability to act justly in such an environment. America's international tax system is heavily complicated, prone to error and bordering on the edge acceptability. Using the iron fist to force compliance with a complicated system where high fines are charged for the smallest mistakes, might bring people into the system for the short-term, but for how long? The word "renounce" has become a hit in Google Trends.

    An IRS Commissioner needs to spend time working overseas and filing taxes from abroad, so that they can learn to understand the system and what it actually means. This would help them to realize that an international address is not one which is located in the US, that e-filing also needs to work for those who owe no tax or for senior citizens who live abroad, that high tax processing fees for a complicated system is a non-starter, that Americans who live abroad need to save for retirement and that it is not criminal to do so, that exchange rate fluctuations do not always equate to profit, and that it is extremely difficult, if not impossible, for the IRS to understand each tax situation for each individual in each nation around the globe.

    I used to be in the tax system as a US citizen, but now I'm in the tax system as a non-resident alien, since I need to have a local checking account and a mortgage for my condo. If the IRS understood taxes in an international setting, then it would have ensured that the little innocent fish were not harmed or endangered with its iron fist against the big real tax cheats.

    Since one who renounces their US citizenship to protect themselves from the flaws of US policy may never again be a US citizen according to US law, maybe the US government might learn from this that its number one priority is to protect Americans from being wrongly harmed by US policy, such as the implementation of the iron fist in an internationally setting which is not well understood.

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  5. Not much to add to the previous three comments. Once upon a time US citizens abroad were patriots and assets to the US. No more.

    Form the perspective of US citizens abroad:

    The US has gone from hero to zero!

    This is the Shulman legacy. How he could be seen as anything but a failure is beyond me. He bears 100% responsibility for the OVDI fiasco. The IRS can't function without trust and it will take at least a generation for the IRS to regain the "trust capital" that Shulman has squandered.

    Renounce US citizenship and renounce it now!

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    1. IRS Commissioner confessed that he relay on professionals to file his taxes, because tax code is too complex.

      But how could a duel-citizen small self-employed business man living in remote parts of India can find a cross-border tax expert to file taxes (and pay huge fines for any mistakes he committed few year back like not aware of FBAR when preparing 2007 taxes).

      Delete
  6. Just Me is correct! IRS needs to get the homeland USA broker-dealer banks, hedge funds and equity firms' accounts properly audited before casting an international net ensnaring hard-working, middle-class expats. IRS can launch audits on 'regular' Americans with no political fall-out. Not so when they start to pick on large banks and the 1% holding 40% of the wealth. And this problem appears to be non-partisan. Obama wants to go after tax cheats, but perhaps with the recent financial crisis and a suffering economy, maybe he and Treasury officials are unwilling to push US banks or make a public spectacle of embarrassing audit results. THAT's when you'd get the attention of mainstream press. And I really don't think they care who renounces citizenship. The numbers of individuals who would go through with it are simply not threatening enough to change policy.

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  7. While Shulman was harassing overseas Americans of no significant consequence....

    The IRS admitted that they have failed to collect $385 billion domestically;

    The IRS admitted that members of the Federal government owe over $3 billion in overdue taxes;

    The IRS admitted that 22 of them worked for the White House;

    The IRS admitted to paying over $22 billion in fraudulent rebates;

    The Federal Reserve said that illegal aliens and drug dealers in America sent over $150 billion in cash out of the country via Western Union and others;

    The Joint Tax Committee's analysis showed that FATCA would raise a mere $800 million in annual revenue to Treasury;

    The International Bankers Association reported that implementing FATCA would cost over $10 billion;

    More overseas Americans have been forced to choose between keeping their citizenship and being harassed forever after, or living a normal live with access to simple things like A BANK ACCOUNT!

    Does the image of using a howitzer to kill a gnat come to mind?

    Is this what constitutes "success" by the IRS?

    Heaven help us all if the IRS wants to continue this idea of "success"!!

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  8. A number of people have commented on my blog of November 9, 2012 that I did not give Mr. Shulman a grade on my IRS report card and that while Mr. Shulman did not invent FATCA he sure made life miserable for Americans abroad. As a former IRS insider I must say that on a pass/fail basis he certainly passed. But I would also add this prediction: do not think for one second that Mr. Shulman’s successor is going to have one ounce of less enthusiasm for the IRS enforcement efforts in the international arena than he had. Everyone should fully expect the next Commissioner to pick right up where he left off. The IRS has been behind the curve for decades on international enforcement and real tax cheats have been laughing up their sleeves at how silly the IRS has looked for the past six decades when it came to following untaxed dollars oversees. Those days are over. Anyone who thinks there is going to be a savior emerging from the IRS in the form of a new Commissioner is seriously delusional. FATCA is the future. Bank secrecy is dead. Get used to it. The unintended consequences of FATCA and FBAR enforcement must be addressed but people should be realistic about government, (both ours and those abroad) and what it is willing or able to do.

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    1. Steven: You clearly spent too long working for International Robbery Society.

      You are the one who needs to get used to the fact people born in US have every right to live elsewhere, become citizens of other countries (where they are responsible,law-abiding taxpayers) without being stalked, harassed and screamed at by their country of birth. I know of no other civilized country which does this. In fact, not even uncivilized nations do this.

      The Foreign Attack To Control All is just one more example from United States of Arrogance.

      Please go back and read the points Anonymous made. Why isn't International Robbery Society going after the tax cheats living in US--especially the ones they know about right in White House or Mitt Romney's offshore accounts. Oh wait, that would have political consequences at home.

      You and I can agree on one thing. Shulman's successor will not make a bit of difference. Those intelligent, highly educated "good willed" folks can't see anything beyond US borders except attack.

      That especially applies to the folks in Washington. I remember how you told us about all the moral people there. Have you talked to Holly Petraeus in the last few days? I bet she thinks differently.

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    2. "The unintended consequences of FATCA and FBAR enforcement must be addressed but people should be realistic about government, (both ours and those abroad) and what it is willing or able to do."

      Could you elaborate on that statement?

      Does that mean that the US government is either "unwilling or unable" to address the 'unintended consequences' that you and we know are harming expats abroad who owe no US taxes, and whose savings and accounts are all legal and already taxed and registered in the country where they live?

      The US Congress and the IRS has the power to recognize our legitimate savings accounts and to exempt countries like Canada who have extensive reciprocal treaties, and who could not possibly be described as a tax haven.

      The US could have made the threshold for FBAR reporting much higher - similar to the FATCA form.

      The US could have assisted new immigrants to the US to know of the pitfalls of holding preexisting accounts outside the US - far in advance of welcoming them to the US.

      The US could have helped to educate and publicize the existence of 3520s and FBARs in the countries where millions of duals and US person live - right next door in Mexico and Canada.

      The US and IRS could have refrained from cutting in-person IRS assistance at embassies and consulates right next door where millions of duals and US persons live - in Canada. But it chose to - and admit on the websites that it is due to budget cuts.

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    3. It claims it wants 'compliance', but makes it so complex that we are paying thousands for 'experts' - which are scarce where we live. In other countries, the supplementary documents submitted must be translated into English by professional translators - at great cost.

      Does that mean that accepting that there will continue to be the same unthinking and disproportionate and unjust burdens borne by those who owe zero tax to the US - and that you are advising us that this is just the price we'll have to accept for the accident of being born US citizens living abroad in another country?

      What do you think is a reasonable and ethical burden for us to bear?

      If things are either going to continue as is, or get worse, then the US and IRS have learned nothing from what the Taxpayer Advocate Nina Olson has told them repeatedly, and described in detail in her reports to Congress.

      As many of us as possible will renounce as we become able because we believe that things will continue in the same vein - and as we owe no US tax, we are not renouncing for tax reasons - we are renouncing because we are being persecuted for no reason. We are not US residents hiding assets in the Caymans. We already report and pay taxes in full to one government, where we live and where our assets are produced. We pay taxes there that the US does not even acknowledge as taxes.

      We receive no US services, and have no effective US representation - many of us cannot even qualify to register to vote from abroad - because many states do not allow it.

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    4. What effect will our experiences and perceptions of this
      present situation have on the US?:

      We will avoid US investments, will buy no US property, vacation elsewhere, shop on our own side of the border or world only,and lobby our non-US governments for the remainder of our lives, to be suspicious of any and all dealings with the US - as it has demonstrated that if it treats those it claims as it's citizens this way, it knows no ethical limits and cannot be trusted. If a country persecutes its 'own' children, and the disabled and taxes their education and disability savings abroad, then what can a stranger expect from the US? We will pass on our experiences, beliefs and concerns to our children, friends, family and political representatives - and urge them to do the same.

      If an institution cannot even get a system corrected that generates threatening 3520 letters in the tens of thousands - scaring the recipients - who owe nothing, then there is a serious problem. http://www.accountingtoday.com/news/aicpa-widespread-problem-erroneous-irs-letters-63822-1.html http://www.aicpa.org/press/pressreleases/2012/pages/erroneous-irs-letters-to-taxpayers-filing-foreign-trust-form-is-widespread-problem-aicpa-tells-irs.aspx

      If an institution cannot protect the personal information it is entrusted with - it cannot be trused with our banking and financial information.http://www.networkworld.com/news/2012/080312-identity-theft-may-cost-irs-261374.html http://www.accountingweb.com/topic/tax/tigta-report-irs-taxpayer-data-vulnerable-hackers

      And if we take your word for it as an insider that nothing will change, then we are done for, and the only recourse is to remove ourselves from the unjust and unethical threat that the US represents to us and our families.

      There is no logical or reasonable future for us as US citizens born and living abroad. Our homes are not inside the US, and never will be. We did not 'leave' to seek lower taxes. We were born abroad. We studied and married abroad. We are being punished for no justifiable reason.

      The money we spend being 'compliant' is spent on professionals outside the US - it doesn't even create US jobs.

      If we continue to owe no US tax, yet incur expensive fees every year - for life, then what has the US gained? Only enmity and ill-will.

      Explain to me again where the evidence is that we must suffer so that the US can maybe catch one homeland evader, for every thousand of us that it persecutes for nothing.

      Compliant-despairing-and-unwilling-to-remain-UScitizen

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    5. "and real tax cheats have been laughing up their sleeves at how silly the IRS has looked for the past six decades when it came to following untaxed dollars oversees".

      And the current situation is a cure for that? So to correct an image problem, the IRS spends scarce funds and personnel hours poring over the ordinary ins and outs of our local accounts? When first of all, our local accounts are already registered with the Revenue agencies in the countries where we live? How can that be 'hiding' assets, when mostly it is already-taxed wages, and joint accounts with our non-US spouses, and already-taxed and government issued savings that are to see? The interest - if there is any is controlled by our local tax agency - and automatically issued by our local bank. We have to report that on our home country income tax, and submit the slip with the return. Do drug lords do that? Do tax cheats do that?

      The US just wants revenue anyway it can get it - and is inventing reasons to exert power - but over the already taxed law abiding majority - because it can't capture the more wily criminals. And when it does find some wrongdoing - with US banks assisting, it settles - like with Wachovia and the accounts held by drug lords - later bought by Wells Fargo with the help of IRS tax breaks http://www.southernstudies.org/2012/07/mexican-drug-cartels-and-the-us-banking-industry.html ..." This staggering sum of money has been funneled through U.S. financial institutions, almost always in violation of U.S. laws, and at times even with the cooperation of American federal agencies.

      In fact, if the Mexican drug cartels were a sovereign nation, they would qualify to be part of the G-20, ahead of Indonesia (GNP: $845 billion) and behind South Korea (GNP: $1.1 trillion). Yet, this is the cumulative sum of money that Mexican drug cartels have funneled through the U.S. economy.

      A New York Times story published last month reporting that federal authorities busted a cartel boss accused of laundering $1 million a month pales in comparison to the hundreds of billions of dollars that drug organizations have moved through U.S. banks.

      Who cares about a $12,000,000 a year operation when one American bank was found to have laundered $378,400,000,000 before it was caught? After federal prosecutors started criminal proceedings against the bank, it agreed to hand $110 million over to federal authorities, for allowing banking transactions with proven connections to drug smuggling operations. And the same bank subsequently paid the government a $50 million fine for failing to monitor cash used to ship 22 tons of cocaine.

      In other words, the bank paid $160 million to make the case go away. No bank official was ever charged with a crime, and the monies ended up dispersed throughout the United States.

      The bank? Wachovia. The year? 2010.".... http://www.southernstudies.org/2012/07/mexican-drug-cartels-and-the-us-banking-industry.html

      US banks deemed "too big to fail" and treated to bailouts by the IRS and Treasury. Banks and their customers outside the US? Forced to comply with FATCA.

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    6. Steven,

      I can certainly agree with your assessment, that Stephen Miller will be just the same. He was one of the biggest apologist for the offshore effort, or that was my impression. I saw him as the 'enforcer' from afar. Then again, without inside information it is very hard to know.

      Nothing will change, and I agree that a Global GATCA is being cemented in place. The FATCANATICs dream of a "no place to hide" world, where the bureaucrats of the International Revenue Service have all knowledge, and BIG DATA rules the world is coming. The NSA will probably play a role with that huge data processing and storage facility they are building in Nevada. These guys want total informational awareness, and capital flows are part of their mission, or at least that is how I see it. It all seems inevitable, or so they would have you believe.

      That is unless Obama or Congress reigns them in. I don't see that happening yet. These FATCANATIC guys are an arrogant bunch, full of hubris. You have to wonder if they are really going to get all the staff they need in this fiscal climate for contract administration and auditing the entire world for FATCA compliance? I don't think so, but that won't stop them from trying.

      They may under estimate the creative ways individual actions will develop to circumvent all these attempts of control. Like the laws of physics, for every government action, there is an equal and opposite individual action that happen. It may make their efforts futile in the long run. They won't win WOOTE (War On Offshore Tax Evasion) any more than they have won the WOD (War on Drugs)

      Also, DATCA could be the straw that breaks the camel's back, with the problem of regulatory authority over reach. Just like our imperial Military over reach with our endless wars on foreign shores, the Empire comes up against a hard reality at some point, they can't police the entire world's population of financial assets and fund transfers, try as they might.

      With DATCA the cost of FATCA is coming home to roost. This is piling on top of Frank Dodd, and this additional complexity will have another unintended consequence in killing off a lot more smaller banks as 'Too Big Too Fail' become even stronger. Who else can afford the data processing infra-structure necessary to be compliant any more?

      Will that be enough for reconsideration of what Congress has wrought? Time will tell, but the fatalist in me says probably not, as hell they didn't even know what they were passing, let alone be able to identify the collateral damage blow back.

      I can't argue with the hard reality assessment of yours that "Anyone who thinks there is going to be a savior emerging from the IRS in the form of a new Commissioner is seriously delusional. FATCA (GATCA) is the future. Bank secrecy is dead. Get used to it."

      I don't like the message, but I am a realist.

      I would hope that there was some balls left in the international Financial Community somewhere to stand up against the flat 'take-it-or-leave-it' diktat from Washington when it comes to IGAs. China maybe?

      With recent propaganda coming out from Treasury, about negotiations with 50 countries, they’ve managed to sell the idea that "FATCA as an established fact that needs to be dealt with on its own terms, it’s not open to revision or withdrawal. Resistance is futile."

      The FCC, or the growing FATCA Compliance Complex, is co-opted. They are now just acting in cooperative manner with the marketing arm of the IRS and spreading the message, "hurry up, you must comply".

      I have to hand it to the FATCANATICs. They must have that same genes that accompanied Cortes during his 'divide and conqueror' campaign to take over in Mexico from the Aztecs. Have ever so few men conquered such a large nation? Then again, the Spanish empire did not survive forever either. This battle will probably outlast the LCUs I have left.

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    7. Steven,
      You advise us that;
      "The IRS has been behind the curve for decades on international enforcement and real tax cheats have been laughing up their sleeves at how silly the IRS has looked for the past six decades when it came to following untaxed dollars oversees. Those days are over. Anyone who thinks there is going to be a savior emerging from the IRS in the form of a new Commissioner is seriously delusional. FATCA is the future. Bank secrecy is dead. Get used to it. The unintended consequences of FATCA and FBAR enforcement must be addressed but people should be realistic about government, (both ours and those abroad) and what it is willing or able to do."

      Well, Bank secrecy looks to be alive and well, thriving at home in the US - ex. Florida, Texas, Nevada, etc. http://triblive.com/news/allegheny/2825138-74/tax-united-states-secrecy-money-countries-havens-accounts-foreigners-haven#axzz2EQvWRUCY "..... Even as U.S. regulators cry loudly about other countries operating foreign secrecy havens that allow criminals and tax cheats to stash cash in hidden offshore bank accounts, experts say America does the same thing. Foreign investors, in all, have parked $14.5 trillion here, according to a Treasury Department report.

      The United States ranks fifth among the world’s largest money laundering centers, according to Tax Justice Network International, a London-based organization that traces illegal money flows..."

      ..."That’s not our problem, argues Alex Sanchez, president of the Florida Bankers Association. Secrecy was meant “to encourage the flight of capital to the United States. ... It’s good for the United States.”

      "Sanchez contends it’s not the business of the IRS or American banking officials to help other countries catch criminals. “I’m not the world’s policeman,” he said."

      So, Steven, how to reconcile this baldly stated and public position by US bankers, that hiding accounts in US banks is great and necessary, as long as it is US banks doing it, and square that reality with the US and IRS assertions that for everyone else in the world, even having any local, and ordinary non-US bank accounts in their country of residence (and already reported to one government) is a bad and evil thing which must be punished with layered penalties - even when no US tax is owed, and the assets are all legal, post-tax, and reported to the home country's tax agency?

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  9. @Just Me: They also didn't win the war on WMD (Weapons of Mass Destruction). Why? Because there weren't any--despite insistence of George W. and Colin Powell.

    United States of Arrogance always shoots first, asks later. That's exactly what they are doing with Foreign Attack to Control All. They are bombing the honest law-abiding citizens and former citizens living elsewhere while ignoring those evading taxes at home--like moral, intelligent, highly educated federal civil servants, White House staff, Timothy Geithner and Mitt Romney.

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  10. FATCA attempts to turn every bank on Earth into a drone that shoots down US persons and destroys families, affecting non-US persons as well.

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