Monday, June 2, 2014

Swiss Banks Under Criminal Investigation Brace for Costs after Credit Suisse Plea (6/2/14)

In the wake of the Credit Suisse resolution, Swiss banks on the criminal investigation list (14 includng Credit Suisse) are apparently greatly concerned about the costs they will have to incur to resolve their criminal investigations.  Joshua Franklin and Patrick Temple-West, RPT-Swiss banks risk bigger than expected fines in U.S tax case (Reuters 6/2/14), here.  Excerpts from  the article:
Swiss banks under investigation for allegedly aiding U.S. tax evasion face the prospect of bigger fines than they bargained for that could dent their capital and force some to cut dividends. 
* * * * 
Thirteen other private banks were left scrambling to calculate the possible fallout on their own finances of harsher than expected penalties following the three-year investigation by the U.S. Department of Justice (DOJ). 
The exact size of their U.S. operations is not publicly known and some are clearly much smaller than others, making it difficult to use the Credit Suisse fine as a gauge for the others caught in the probe. 
But the uncertain outcome of the investigation and the lack of detail on how the Credit Suisse penalty was calculated has left analysts with little option but to bump up their most pessimistic estimates for future fines. 
Even a penalty exceeding what they have set aside by $200 million would have wiped out about 40 percent of the collective 2013 profits of the three smaller Swiss banks known to be targeted by the probe who publish accounts, according to Reuters calculations. 
The banks all boast capital ratios well above regulatory minimums, but these ratios would fall by between 0.3 and 2.6 percentage points in the event they were each fined $200 million more than their current provisions, the calculations suggest.
The article says that not all of the 13 still under criminal investigations are publicly known.  My recently revised list of the 14 (including Credit Suisse) is here:  List of 14 Swiss Banks Under Criminal Investigation (Federal Tax Crimes Blog 3/9/14), here.  I encourage readers to advise me if there are any inaccuracies on this list.  All of the banks mentioned in the article (not complete list) are on my list.

40 comments:

  1. Edelweiss,


    I have advised Mr. Temple-West of your comments. I have no idea whether or what he will do with them.


    Thanks for the comments.


    Jack Townsend

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  2. No Edelweiss you are not the only one ...see all the posts under 3/18 FATCA the new worldwide standard.... but Jack Townsend is living in a different world hiding behind "conveniences" and "brain freezes" !! Sometimes common sense is such a rare and envious quality that is not taught any more in university.

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  3. These discussions around FATCA, which focuse on compliance costs and denial of banking services, while important, get too much air-time. FATCA is a bad law other reasons, a fishing expedition that raises issues about fairness, privacy rights and in certain countries, safety of expats (allowing 3rd parties to create and maintain lists of Americans, their financial resources and other private information might seem benign in places like the UK, Canada and Germany, but I cannot imagine expats in Beirut or Kabul are too keen on it). Also, what is really needed is more lobbying and discussion around making the offshore initiatives more efficient and fair for people to come into compliance, in particular expats and immigrants. I would imagine if the IRS developed a less punitive regime, then many of the loudest voices in the anti-FATCA debate would become softer. Indeed, if FATCA were to disappear tomorrow, the compliance issues, the IRS offshore initiative and the punitive penalties would still be there. True, the collection efforts might be less effective, but given time and funding (say the funding that would have gone into FATCA data analysis), the IRS could still engage in a pretty painful enforcement effort.

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  4. Jack,

    As you are fully aware, these banks, investment funds, etc. are signing up so the US Govt does not withhold money from their US transactions. If they do not sign up for FATCA then their transactions will be hit with withholding penalties. They are not doing this so they can then accept US clients... they are doing this so a portion of their funds are not stolen by the US Govt. This initial signup will then come with an affidavit "NO US CITIZEN ACCOUNTS. NO WITHHOLDING NECESSARY."

    I have done quick searches of the 77000 companies/funds/banks provided at the link and every bank that has refused my business is clearly listed. So the list means nothing other than they are all following the steps necessary to continue to attempt to do US transactions with fewer hassles. You will also note that the vast majority of the 77000 are investment funds and not banks. Investment funds that can't/won't service US domiciled persons because of their lack of SEC registration.

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  5. John Audit,

    I am confused. Once the banks are FATCA qualified, what is the marginal cost of servicing U.S. customers. I think it is only requiring them at account opening to sign the appropriate forms and then reporting annually the results in the account. Since they already have accounting for the results in the account, how difficult would it be for them to program an algorithm for a field where citizenship is answered "yes" and with the annual results? Other countries will start requiring the same genre of information. So, is it your thought that most banks who become qualified going are going to decline U.S. customers -- and by extension, customers from other countries demanding the information -- simply because they don't want to do the relatively little extra work to report the information to the countries? That makes no sense to me.

    No as to your experience that the banks that have declined your business have become FATCA qualified, I just can't speak to that. I would ask whether the declining of U.S. customers is temporary until they have their systems in place? Or is there some other reason that explains their declining the business. For example, I would suspect that if a U.S. citizen has $10,000,000 to deposit, the banks will find some way to accept the deposit and provide appropriate banking services even if they refuse U.S. customers with only $5,000 to deposit. For example, I know that there are financial institutions in the U.S. that have minimums and would not take the latter customer either, even if the customer were in the same country and same city.

    This sort of reminds me of the anecdote about a man asking the woman if she would sleep with him for $1,000,000 and gets an affirmative response. The man then drops down to a minimum offer, say $300. She gets offended, responding "what kind of woman do you think I am." To which he replies"We’ve already established that. Now we’re just haggling over the price." Maybe the banks are, in a sense, just haggling over price. They will get in bed with you for the right amount of money.



    But, we will see. I again urge you and others experiencing this problem to contact ACA. If it is indeed as systemic as you and others have suggested in the comments, then it is the quintessential type of issue to which ACA would devote resources. The key here is whether it is as systemic an issue as some claim.


    Again, I don't doubt the experiences you recount and your sincerity. I just don't have the data to know whether or not it is as systemic as commenters imply in their comments.


    Thanks again for all your comments. I am learning from them. Just not yet persuaded.


    Jack Townsend

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  6. FATCA-DATCA-GATCA : 77, 353 banks have signed up to chase down and identify 7.6 million US
    citizens living overseas, 10′s of millions of immigrants, and a few
    hundred real tax evaders that have been living in a cage for the last 2 years !!

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  7. Please Jack Townsend READ what some of the posters provide here to help you to get out of your mental blockage and state of confusion :
    ..."two ways to be FATCA compliant. One is to implement the client on boarding/KYC procedures to identify US accounts and then to implement incredibly complex reporting systems (different currency, different tax year, different structures and tax treatment for corporate transactions etc.) that overlay US tax law on the local jurisdiction and on each separate jurisdiction in which your customer's have holdings. Such systems were estimated by one of the big four firms (KPMG I think it was) to cost a very large bank $100 million in upfront costs plus the yearly costs associated with ongoing compliance and reporting. That is an enormous up-front cost for the right to continue to deal with US customers when many of these firms have US person customer counts in the thousands or less...."

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  8. The problem with this discussion is that Jack Townsend is far behind in the learning curve about the facts as they play out as of today with FATCA . Statements of "makes no sense to me" ..."we will see"...."I am confused"... can attest to that. Nobody here needs to convice JAT - it is what it is with or without his blessing !!

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  9. If that's the case, and in the event Mr. Temple-West is reading, let me be more precise on the IRS estimate of FFIs. The estimate was 200-400,000 and came from the 27 September 2013 TIGTA report, page 9 (http://www.treasury.gov/tigta/auditreports/2013reports/201320118fr.pdf). So, it's less than 50% of the low IRS estimate and less than 25% of the high IRS estimate.

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  10. btw. 20% of the FATCA compliant financial firms hailed from the Cayman Islands at 14,836 registered .....
    In other words, these aren’t “77,353 banks” at all. They’re SPVs which were slow-footed enough to get caught in the “FFI” definition. Basically “77,353 banks” is nothing more than the usual inflationary misinformation we’ve come to expect from IRS “offshore” garbage press releases, just like “$6 billion collected from tax evaders!” (the vast majority of which wasn’t tax but fines, and against which the real tax evaders are now forewarned) and “50 countries signed up for IGAs!” (half of which are dependent territories which aren’t even important as tax havens, and the other half of which are only signed up “in substance”)

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  11. Jack,


    there is little doubt that high net worth individuals will continue to access banking services with little disruption, so yes, someone with liquid assets of $1m and upwards will probably be able to find banking services. People with that level of assets probably represent less than 1% of expats. At the risk of playing into US cliche/class warfare rhetoric, I am not sure that saying because the richest 1% of expats will be unaffected, there is no cause for complaint.
    As to ongoing compliance costs, it is difficult to say exactly how much incremental costs are incurred for the reporting infrastructure, but it is safe to say that the number is not insignificant and represents a losing capex for a few years. Given that many banks are reducing costs, you can see why this might be an easier one to cut.
    As an aside, you have devoted a fair amount of blog space to this issue, much of which has been filled with thoughtful and insightful comment on a respected forum, which is appreciated.

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  12. GlobalCapitalism,


    The real problem is that, if indeed there is a systemic problem (meaning either or both that the commenters do not make a persuasive case or I am not listening (or behind the learning curve, as you say)), this Federal Tax Crimes Blog is really not the place to complain about that systemic problem. This is not a tax policy blog or a blog about how one country gets along with its neighbors or how a country should treat its own citizens residing overseas. This is a blog about federal tax crimes as they are and not as they ought to be.


    It is somewhat like the Obamacare issue. The Republicans have wasted incredible amounts of time, angst and this country's resources trying to repeal Obamacare. That train left the station long ago, yet they still press (although their insistence on the issue will be mooted because, hey, it is not as bad as they complained). So, trying to get FATCA repealed or even substantially modified is not, in my judgment, realistic. It is a pipe dream.


    I do think that problems in the implementation of FATCA can lead to some tweaking in FATCA. That is not possible for Obamacare because one party doesn't want Obamacare to work and therefore is unwilling to make it better (because that would be a concession that it works). But for FATCA, I think the parties (excluding Rand Paul who is a party unto himself) could work together to make it better and less disruptive to the extent that problems are shown to exist.


    So, it seems to me, that if I wanted to have some effect on the ultimate issue of making a full reporting regime more palatable to U.S. citizens abroad, you should be addressing this to groups such as the ACA which has some credibility generally and, I suspect, in Congress as well. But just sitting on the sidelines complaining is not likely to be effective, except that it can set up an echo chamber where various unhappy commenters are really talking to other unhappy commenters and perhaps find some comfort. (As they say, misery does love company.)


    I personally would like the substance of your comments to be effective. I think you can have a better chance for your comments becoming effective by directing them to groups or persons with power to do something about the complaints you raise.


    I will continue to approve all such comments here. Maybe someone with power to do something about the complaints will read the comments here, will be persuaded that there is a problem that can be fixed consistent with the overall goals and design of FATCA (which is not going away), and set about it to make positive, even if incremental, change. I just doubt that this blog is whether persons with such power will spend any time reading the comments or will be persuaded.


    My best to all who have suffered the inconveniences of FATCA.


    By the way I repeat that I can arrange an introduction to at least one U.S. financial firm which can arrange the fun panoply of U.S. financial services in the U.S. for U.S. citizens living abroad. That may not be as convenient as a corner bank that you can walk into, but I can tell you that I have not walked into the bank and the brokerage firm I used in probably 10 years. There are work-arounds. If you are interested in an introduction, please email me at jack@tjtaxlaw.com.


    Jack Townsend

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  13. IRS Introduces Tool for Checking FATCA Foreign Bank Registration

    Take a look at some of the first names of compliant little FFIs - this is getting weirder and stranger by the day.

    http://www.accountingtoday.com/news/irs_watch/irs-introduces-tool-for-checking-fatca-foreign-bank-registration-70861-1.html#read

    http://apps.irs.gov/app/fatcaFfiList/flu.jsf

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  14. "This is a blog about federal tax crimes as they are"..... yes absolutely correct but since you present many blog posts about other topics with biased opinions,comments from either you or the author of some article etc. you should not be surprised - actually you really are begging for it - that you attract a lot of fierce and strong criticism. Practice what you preach and stick to tax crimes and tax cases/procedure but not saying one thing and doing another..... do not understimate our determination.



    ... and lastly please let history decide what is a pipe dream and what is not !!!

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  15. "I am confused. Once the banks are FATCA qualified, what is the marginal cost of servicing U.S. customers."

    Couple of things here:

    1. Of course a business should consider only the potential costs and profits when deciding between different courses of action. However, some FFIs seem to have a purely emotional reaction to FATCA: they don't want to become entangled with a complicated new reporting regime imposed by the US, and they think that avoiding US customers accomplishes that goal. So, to some FFIs, it doesn't matter what the marginal cost of servicing US customers is because that marginal cost isn't part of their decision matrix--they just want to pretend FATCA doesn't exist.

    2. For other FFIs, the marginal cost of servicing US customers is $0 because they impose FATCA compliance fees directly on each US customer (and some on each non-US customer as well). It will be interesting to see where the market shakes out here, but imposing a direct fee at account opening is a fairly prevalent activity and definitely better for all concerned than the head-in-the-sand approach taken by some FFIs.

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  16. It’s in the IRS’s favor to make it seem like a huge number of banks are in the program. Maybe the number is a lot smaller because people registered the kitchen sink.....lol.

    The list of UK “banks” includes:
    - 17th Earl of Pembroke W/T -Lady Pembroke
    - D M Williams deceased Will Trust
    - J M Marvin deceased Will Trust
    - Triangle Regional Aircraft Leasing Limit
    - Branch
    - Enotria Wine Group Limited
    - HSBC Vehicle Finance -UK- Limited
    - HSBC Workplace Retirements Services Fund
    - Newton Global Higher Income Fund
    - Marks and Spencer Financial Services plc
    - John Lewis Financial Services Limited
    So, that’s three trusts from deceased individuals, an aircraft leasing company, an unidentifiable entry (there are many of these), a wine distributor, a vehicle finance company, a workplace pension scheme,an investment fund (there tons of these), and subsidiaries of two of the UK’s leading retailers (M&S offers savings accounts, John Lewis apparently doesn’t so it’s probably credit card finance/securitisation).
    All from the first few pages of United Kingdom “banks”.

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  17. Thanks, Stewart.

    Your response -- a very good one -- reminded me of an anecdotal experience from law school. One of my fellow students -- a Princeton economic honors grad -- in contracts class was always offering to recite and almost invariably, on any contracts law point, he could work in the concept of the marginal efficiency of capital. I think most students understood the economics concept of the marginal efficiency of capital (I do link to Wikipedia below, but then when I attended law school in the old days, we did not have Wikipedia).

    At any rate, from a business perspective, the question in FATCA compliance and in servicing the banking / financial needs of U.S. citizens, the economic question is whether I (the FFI servicer) can make more money by incurring the costs and risks of servicing than by not incurring those costs and risks of servicing.

    It is that inquiry that tells me that there will be a critical mass of FFIs that will become FATCA compliant and that they will drill down and service the needs of the ordinary U.S. ex pat. Of course, to the extent that there are marginal costs of servicing the needs of U.S. ex pats, they will pass them through (with some overhead or profit), but if there is money to be made they will make the money rather than pass it up.

    That is, those FFIs that are profit rather than ideology driven will incur the costs to make the money. Those FFIs that just want to mope around complaining wherever they can about how they and their buddy FFIs have been mistreated may pass up profits. But those moping FFIs are living in the past. The FFIs that are looking to the future will incur the costs and make the money.

    Thank God for the free enterprise system.

    And as you know, there will be shakeout in the market. And, to be redundant, the ones who will find a way to service profitable business will prevail and those who let their prejudices and ideologies inhibit them will suffer.

    But the question here is not about the survival of the fittest among the FFIs. It is about trying to alleviate the short-term inconveniencies to U.S. citizens. Eventually, the market will solve the problem. But, what to do in the short term. I don't have a magic bullet on that, but I do feel that just complaining about FATCA is not a solution to the problem.


    Finally, this is not just U.S. ex pat issue. It is an issue that other country ex pats will face as their countries join the initiative and regime created by FATCA. But, if FATCA is successful, many of these inconveniencies will have been worked out for those other countries and their ex pats and it will be smoother for the other country ex pats who will benefit by all of the interim inconveniencies suffered by U.S. expats.


    So, my comment to those U.S. ex pats feeling the pain right now, you are bearing part of the cost of building the future. That's not great consolation in the pain of the immediate, but at some point maybe there will be an ability to take a longer view.

    Jack Townsend

    PS on the marginal efficiency of capital, see

    http://en.wikipedia.org/wiki/Marginal_efficiency_of_capital

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  18. Quote, "someone with liquid assets of $1M and upwards will probably NOT be able to find banking services".

    I added the NOT to your quote, as it is generally an incorrect statement. I offered to deposit more than $1M and was refused by all banks except for one. The one bank referred me to their sister bank (same corporate shell - different region). The sister bank would only open the account with $1M (no problem), would only open it on my second passport (non US - no problem), and the money could not be transferred (OR SOURCED) from the USA (a huge problem). My funds are in the USA, I have tax returns to document my earnings since 2000, and I can't move the money outside the country.

    So, I hold a second passport, I am considered HNW, and I work in the finance industry for a major international player (no retail banking). The institution I work for ended up relenting and pays my wages outside the country as even they finally realized I could not get a bank account within the country without a CLN. As stated in one of my earlier posts, my contract specifically stated that my monthly wages would only be paid into a bank account in COUNTRY X... They ended up modifying this as I couldn't get a bank account. The bank account I was able to get in Country Y is wages only. If I transfer more than wages, they will close the account.

    This may all seen too far fetched to believe to those who are not experiencing it. Some items to note: Why would I bother writing lies on this blog? Why do I (and other expats who have experienced the same thing) never refer to the banks by name (or the countries) where they were able to get bank accounts? Bank accounts are so hard to get at this point that people do not even want to reveal the country nor the name of the bank for fear their accounts will be closed down.

    For me, it had gotten to such an extreme that I went to the embassy of my second passport and inquired about having my place of birth removed. I explained everything that was happening and that my rights were being violated because of my place of birth and my other citizenship (US)... Needless to say, they can't remove place of birth.

    Each day I understand the reasoning of those that have renounced more and more. When I finally do renounce the reason for renouncing on the CLN will be: I NEED A LOCAL BANK ACCOUNT. Even after the renunciation, I will have to produce a CLN for the rest of my life because of my place of birth! The situation is beyond stupid.

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  19. ....."this is not the forum to be effective in promoting solutions to any systemic issues that may exist"...... like I wrote before if you do not like people entering a discussion with you about your "pipe dreams" stop blogging about it and stick to tax crimes, tax cases and procedure otherwise face the music !

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  20. The situation is beyond stupid ..... I second that !

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  21. I don't mind facing the music.


    I would like to think that the readers of this blog are efficient agents. If they want to use this forum to make their points, I will continue to approve their comments. I am just saying that I doubt that ranting about OVDP and its side effects will be productive on this blog. There are better fora to bring legitimate complaints about OVDP and its side effects.


    But,if you feel it is worth your time to bring those complaints to this blog, then have at it. I have to say that I am all for fixing problems in FATCA. I just say that I do not have the feeling that this blog is the forum to do that.


    The only thing that does concern me is that, if there are too many "echo chamber" comments of sound and fury and signifying nothing to the target audience of this blog (students and practitioners), then I am concerned that the comments will simply not be read but by those readers wanting their own biases confirmed. And that will mean that nothing is accomplished by the comments.


    Even worse, readers when they stop reading the comments will miss the good comments that could have been meaningful to them. If that occurs -- and on anecdotal feedback, I believe it has already occurred in some instances -- then everyone is worse off by have poorly targeted comments.


    Jack Townsend

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  22. Thank you for allowing me to vent and I do appreciate your blog and insights. I have said my piece, there is no further use in beating this dead horse.

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  23. I think you of all people can be accused of "echo chamber" comments when it comes to swiss banks and swiss secrecy laws which btw. you still have not understood to this day....etc. Again the problem with you is that YOU are sitting in a glasshouse and throwing stones is not smart. A blog entry like :

    Banks -- Many Banks -- Are Becoming FATCA Compliant; Good News for U.S. Ex Pats.... has so many missleading and even factual incorrect nuances, I can understand that you are no expert on these matters but then I would urge you to stick to what you know best ! You cannot have it both ways.... making biased comments,statements yourself but refering to anecdotal evidence on the other side and than conveniently mentioning anecdotal feedback about "poorly targeted comments" to downgrade their quality.
    If I remember correctly you lost your last poll that was targeted in this direction with a 120 to 20 margin !! I think we all can live with this minority anecdotal feedback your are claiming exist and focus on the other 85%.

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  24. "Is a need for such services"? To pay US taxes, an expat needs to send money to the US. To send money, it needs to have a financial service, since an enveloped filled with cash stored under the pillow and addressed to the US Treasury will never reach its destination. So, "no need for such services" would mean the US would then not recognize the need to pay US taxes, given that it would not recognize the need for US expats to have access to financial services needed to make tax payments.

    In other words, of course there is "a need for such services" since the US lusts with greed for expat earnings and thus expats must have access to financial services so that the US can get a free ride from their labors.



    More Americans seriously need to chill with their greed and lust for expat earnings while focusing instead of preventing discrimination caused by faulty US policy.

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  25. The "right forum" is every forum, blog, web site, article, etc. Yet, no matter where expats express their views, stateside Americans refuse to listen since America doesn't give a damn about its people.

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  26. Sticking the head in the sand to ignore problems has become American culture.

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  27. If stateside Americans addressed these problems instead of ignoring them, then expats wouldn't have to continuously remind stateside Americans that they are still ignoring the problems.

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  28. FATCA is a US federal tax crime, since it violates US law prohibiting discrimination.

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  29. So tell me, is a Swedish candy company or a terminate inspection business a BANK? Yes, they have signed up on the latest list to be FATCA compliant.


    I hate these simplistic headlines designed to deceive the drive by reader.


    If you want to hide something EVIL, bury in something BORING that the average person will NOT understand or can be misled by the headline.


    FATCA is a surveillance dragnet without "probably cause" or "due process" and I am surprised Jack, that would NOT be concerned about this.

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  30. Jack,

    FFIs are terrified of the US finding even one undeclared account even they're on the list of "compliant" FFIs.
    They don't trust the US to be reasonable if a client lies to them, is not reported and somehow the US finds out about it. They've seen the fines other banks were fined.
    They want to become "compliant" to avoid witholding, while limiting the risk while not accepting US customers.
    The US policy of unreasonable fines is what is making US customers toxic.

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  31. testimony given to the Canada House of Commons committee

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  32. lol....sorry but after 3 years with the guy I am not surprised at all anymore !!!!

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  33. Here is a link to the entire list of 77,000 so called "Banks'

    https://www.abolishfatca.com/IRS_FFI_List.pdf



    Now, look yourself, and what our media tells us are "Banks" but are really something much more broadly defined then the simplistic reporting we have come used to seeing.


    Patric Temple-West is one of the worst with such headline characterizations.

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  34. The reason why America is a diaspora back-stabbing nation which justifies any crime which harms the innocent living abroad, is because over half of US congressmen are millionaires. Most US politicians are so damn rich that they lust for more money and thus neither care nor understand what it means to refinance a mortgage. They don't care about the poor. They only care about how they can grab more money from the unrepresented.

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  35. Obama’s recent speech in Poland:
    ... “bigger nations must not be allowed to bully the small, or impose their will at the barrel of a gun or with masked men taking over buildings. And the stroke of a pen
    can never legitimize the theft of a neighbor’s land.”.....
    That is a very synical statement and I would respond to that : bigger nations must not be allowed to bully the small, or impose their will by economic blackmail. And the stroke of a pen can never legitimize the theft of a neighbor’s wealth.

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  36. “…..Russia’s number two lender, state-controlled VTB Group (VTBR.RS), said Thursday
    that it will phase out business with U.S. taxpayers because of the requirement to report details of their accounts to the authorities in the U.S.……”

    http://www.nasdaq.com/article/russia-vtb-to-phase-out-us-customers-20140605-00681

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  37. The full title of the article is:

    VTB to Stop Services for U.S. Taxpayers in Russia on Risks



    Let us not confuse that title: IN RUSSIA


    So, this is not an issue of foreign banks cutting ties to US citizens with the USA. This is Russia cutting ties to US citizens living in Russia.


    Someone should e-mail the author of the article and let them this is not a unique thing... it is worldwide.



    P.S. Thanks for posting these.

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  38. The words of politicians are useless. It's the actions which talk.

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  39. Consequences for the big bully US : Foreign banks fall out of love with US...Fearful of an outright withdrawal, Connecticut has offered incentives to keep the banks in the state, betting that they will remain significant employers.But at the national level, the reverse is true: policy is being developed that will arguably make the US less attractive for overseas banks.
    http://www.swissinfo.ch/eng/business/Foreign_banks_fall_out_of_love_with_US.html?cid=38714508

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  40. As you may be aware, they have subsidiaries outside of Russia, which
    will most likely not allow USPs to open accounts as well. For instance
    in Germany (www.vtb-direktbank.de), they ask, among other things. the
    following questions on the account opening form:

    - Place of birth

    - Country of birth

    - Nationality

    - Second nationality (!!!)

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