tag:blogger.com,1999:blog-1519969502186924526.post7341820261942077926..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Swiss Banks Under Criminal Investigation Brace for Costs after Credit Suisse Plea (6/2/14)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger40125tag:blogger.com,1999:blog-1519969502186924526.post-48924439218909438082014-06-06T05:17:41.492-05:002014-06-06T05:17:41.492-05:00As you may be aware, they have subsidiaries outsid...As you may be aware, they have subsidiaries outside of Russia, which <br />will most likely not allow USPs to open accounts as well. For instance <br />in Germany (www.vtb-direktbank.de), they ask, among other things. the <br />following questions on the account opening form:<br /><br />- Place of birth<br /><br />- Country of birth<br /><br />- Nationality<br /><br />- Second nationality (!!!)GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-22098982197650280632014-06-06T05:07:46.317-05:002014-06-06T05:07:46.317-05:00Consequences for the big bully US : Foreign banks ...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.<br />http://www.swissinfo.ch/eng/business/Foreign_banks_fall_out_of_love_with_US.html?cid=38714508GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-79516954870119917212014-06-05T17:12:56.758-05:002014-06-05T17:12:56.758-05:00The words of politicians are useless. It's th...The words of politicians are useless. It's the actions which talk.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-1387314587711148322014-06-05T14:05:08.493-05:002014-06-05T14:05:08.493-05:00The full title of the article is:
VTB to Stop S...The full title of the article is: <br /><br />VTB to Stop Services for U.S. Taxpayers in Russia on Risks<br /><br /><br /><br />Let us not confuse that title: IN RUSSIA<br /><br /><br />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.<br /><br /><br />Someone should e-mail the author of the article and let them this is not a unique thing... it is worldwide. <br /><br /><br /><br />P.S. Thanks for posting these.John Auditnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-50373038771443972932014-06-05T12:37:27.106-05:002014-06-05T12:37:27.106-05:00“…..Russia’s number two lender, state-controlled V...“…..Russia’s number two lender, state-controlled VTB Group (VTBR.RS), said Thursday <br />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.……”<br /><br />http://www.nasdaq.com/article/russia-vtb-to-phase-out-us-customers-20140605-00681GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-37103127293144693602014-06-05T09:13:15.781-05:002014-06-05T09:13:15.781-05:00Obama’s recent speech in Poland:
... “bigger natio...Obama’s recent speech in Poland:<br />... “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 <br />can never legitimize the theft of a neighbor’s land.”.....<br />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.GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-55426261564625488612014-06-04T23:58:34.768-05:002014-06-04T23:58:34.768-05:00The reason why America is a diaspora back-stabbing...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.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-1737058778507643102014-06-04T19:51:57.259-05:002014-06-04T19:51:57.259-05:00Here is a link to the entire list of 77,000 so cal...Here is a link to the entire list of 77,000 so called "Banks'<br /><br />https://www.abolishfatca.com/IRS_FFI_List.pdf<br /><br /><br /><br />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.<br /><br /><br />Patric Temple-West is one of the worst with such headline characterizations.Just_Me_Alsonoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-35259531466254344502014-06-04T13:33:13.789-05:002014-06-04T13:33:13.789-05:00lol....sorry but after 3 years with the guy I am n...lol....sorry but after 3 years with the guy I am not surprised at all anymore !!!!GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-24336761991111915842014-06-04T11:44:19.252-05:002014-06-04T11:44:19.252-05:00testimony given to the Canada House of Commons com...testimony given to the Canada House of Commons committeeGlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-73830980354978305812014-06-04T11:04:35.652-05:002014-06-04T11:04:35.652-05:00Jack,
FFIs are terrified of the US finding even o...Jack,<br /><br />FFIs are terrified of the US finding even one undeclared account even they're on the list of "compliant" FFIs.<br />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.<br />They want to become "compliant" to avoid witholding, while limiting the risk while not accepting US customers.<br />The US policy of unreasonable fines is what is making US customers toxic.Anonnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-92207530844631124022014-06-04T10:58:17.946-05:002014-06-04T10:58:17.946-05:00So tell me, is a Swedish candy company or a termin...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.<br /><br /><br />I hate these simplistic headlines designed to deceive the drive by reader. <br /><br /><br />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.<br /><br /><br />FATCA is a surveillance dragnet without "probably cause" or "due process" and I am surprised Jack, that would NOT be concerned about this.Just_Me_Alsonoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-78272593529976614702014-06-03T14:56:08.571-05:002014-06-03T14:56:08.571-05:00FATCA is a US federal tax crime, since it violates...FATCA is a US federal tax crime, since it violates US law prohibiting discrimination.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-78272518589832389582014-06-03T14:54:02.895-05:002014-06-03T14:54:02.895-05:00If stateside Americans addressed these problems in...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.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-90848935506284693632014-06-03T14:52:28.721-05:002014-06-03T14:52:28.721-05:00Sticking the head in the sand to ignore problems h...Sticking the head in the sand to ignore problems has become American culture.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-16921582075375618092014-06-03T14:51:03.233-05:002014-06-03T14:51:03.233-05:00The "right forum" is every forum, blog, ...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.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-22496627215925279632014-06-03T14:38:24.212-05:002014-06-03T14:38:24.212-05:00"Is a need for such services"? To pay U..."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.<br /><br />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.<br /><br /><br /><br />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.SwissTechienoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-67545303150734315882014-06-03T14:33:22.624-05:002014-06-03T14:33:22.624-05:00I think you of all people can be accused of "...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 : <br /><br />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.<br />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%.GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-17074169235821922322014-06-03T14:15:59.762-05:002014-06-03T14:15:59.762-05:00Thank you for allowing me to vent and I do appreci...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.John Auditnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-78748093528816807922014-06-03T14:14:33.616-05:002014-06-03T14:14:33.616-05:00I don't mind facing the music.
I would li...I don't mind facing the music. <br /><br /><br />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.<br /><br /><br />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.<br /><br /><br />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.<br /><br /><br />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.<br /><br /><br />Jack TownsendJack Townsendhttp://www.tjtaxlaw.com/noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-18266557786896240992014-06-03T14:02:30.393-05:002014-06-03T14:02:30.393-05:00The situation is beyond stupid ..... I second that...The situation is beyond stupid ..... I second that !GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-57990075831923860132014-06-03T14:01:12.229-05:002014-06-03T14:01:12.229-05:00....."this is not the forum to be effective i........"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 !GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-67476721418426927672014-06-03T13:39:35.992-05:002014-06-03T13:39:35.992-05:00Quote, "someone with liquid assets of $1M and...Quote, "someone with liquid assets of $1M and upwards will probably NOT be able to find banking services".<br /><br />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. <br /><br />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.<br /><br />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. <br /><br />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.<br /><br />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.John Auditnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-64402425910762339242014-06-03T13:12:41.129-05:002014-06-03T13:12:41.129-05:00Thanks, Stewart.
Your response -- a very good one...Thanks, Stewart.<br /><br />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). <br /><br />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.<br /><br />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.<br /><br />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.<br /><br />Thank God for the free enterprise system.<br /><br />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.<br /><br />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.<br /><br /><br />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.<br /><br /><br />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.<br /><br />Jack Townsend<br /><br />PS on the marginal efficiency of capital, see<br /><br />http://en.wikipedia.org/wiki/Marginal_efficiency_of_capitalJack Townsendhttp://www.tjtaxlaw.com/noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-59540324153808199672014-06-03T12:08:59.954-05:002014-06-03T12:08:59.954-05:00It’s in the IRS’s favor to make it seem like a hug...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.<br /><br />The list of UK “banks” includes:<br />- 17th Earl of Pembroke W/T -Lady Pembroke<br />- D M Williams deceased Will Trust<br />- J M Marvin deceased Will Trust<br />- Triangle Regional Aircraft Leasing Limit<br />- Branch<br />- Enotria Wine Group Limited<br />- HSBC Vehicle Finance -UK- Limited<br />- HSBC Workplace Retirements Services Fund<br />- Newton Global Higher Income Fund<br />- Marks and Spencer Financial Services plc<br />- John Lewis Financial Services Limited <br />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).<br /> All from the first few pages of United Kingdom “banks”.GlobalCapitalismnoreply@blogger.com