12 thoughts on “US Treasury Resonds to Representatives

  1. I think Treasury did quite a bit of cherry picking to find any positive comments. Some firms have been collecting FACTA comment letters and posting them on their websites. It difficult to find any thing other than criticism and complaints.
    If the IRS and Treasury are listening, they must have ear protectors on.

  2. @Hazy: Great minds think alike. Ever since I read the letter from Treasury, the lyrics from Everything Is Beautiful by Ray Stevens have been stuck in my brain:
    “There is none so blind than he who will not see.”
    I think those words may have origins in the Bible, but I don’t pretend to know where, so I will just use the Ray Stevens reference.
    Treasury certainly had different interpretations of submissions from governments and banks around the world than anyone else has had! Did we really expect anything else?

  3. “These intergovernmental approaches have been widely praised..”
    What are these people smoking? Reality check, guys.
    To take the positive comments seriously one would have to run them a cultural filter. In their defense perhaps the Treasury people simply don’t know that and are taking these comments at face value because they don’t know any better. Yet another reason why cross-cultural competency is absolutely essential in a globalized world and you have to know how to “decode” something even if it is written or said in your language.
    The people who wrote these letters may have meant to communicate something completely different. Hard to know but here’s an example of how a positive remark can be completely misconstrued.
    I worked for a French company and we travelled to the UK to persuade the subsidiary to use our IT standards. During the presentation the Brits smiled and nodded their heads and at the end they said, “How interesting. Excellent work. We’ll be in touch.” My French colleagues were thrilled and thought that the Brits were won over. I said, not so fast. I think that might have been code for: “you’re in our house so we have to be polite but we are not impressed and we won’t be calling you.” I was right and they never did call.

  4. Great point Victoria. They seem not to understand cultural differences. It is obvious that these praises were just a way to be polite and not tell them in the face that this is just bad legislation (and I am just polite here 🙂 ).
    I am surprised what you say about the brits. I have worked with Japanese people in my field, and I thought what you said applied to them to the letter. It was nearly impossible to get constructive feedback on some projects, maybe just because they were too polite to convey negatives.
    In some other cultures, like India, hierarchy also is very important, and we were having efficiency issues, because some work seems to get reviewed by only higher ranking people, when it could be done by lower ranking people. We had to promote people to make our group more efficient and remove this funnelling.
    This is why expats are so important. You just don’t learn these things and learn to work efficiently in a global economy if you don’t learn other cultures, which often means spending extended periods of time in another country.

  5. @Victoria, Christophe: You are giving US Treasury far too much credit if you think their “understanding” of submissions from around the world has anything to do with cultural differences.
    Perhaps you are being diplomatic too. Treasury took a few short sentences from a multitude of lengthy reports and skewed them to what they want. Treasury knows exactly what they did–just like the big bully on the playground will always turn things around to make himself look like the good guy.
    The US will always find, or at least seek, only what it wants. Remember Weapons of Mass Destruction in Iraq? Remember Colin Powell’s presentation at UN? Remember Hans Blix? Where were WMD? Oh, wait, there weren’t any.
    US was not kind to France when France refused to participate in Iraq. Please don’t feel a need to be kind to US now.
    Treasury knows and understands exactly what those submissions mean.

  6. Really, were these huge submissions completely read by US Treasury representatives or did they just get to the first paragraphs where they were thanked for allowing the opportunity to respond by most of the responses I read. “They love what we’re doing” was not the message I got from most of the painstakeingly prepared submissions.

  7. It’s a very revealing letter. It starts by referring to “concerns about potential burdens under FATCA on financial institutions and U.S. citizens residing abroad, ” then gives at least some lip service to (a), but never refers to (b) again.

  8. Well what did we expect Treasury to say? As long as FATCA is the law, they have to implement it somehow. Can you imagine the hue and cry from the “stay-at-homes” who want “other people” to pay more taxes if Treasury admitted that FATCA is bad?

  9. @Christophe, Oh I hear you about the Japanese. Yes, a very interesting work environment. I think what clued me into the Brits was a kind of BS meter that detected a certain sarcasm in their comments – something I wouldn’t have been able to do with the Japanese since I didn’t spend more than a couple of years in Japan.
    @blaze, Another story. Just for the hell of it. Corporate executive from the US and I are having an surreal conversation in a Parisian bar. We are having trouble with an employee at the Paris office and we need to ease him out. The American exec doesn’t understand why this is such a big deal and why we can’t just fire the guy. I explain over and over and over again that there are work laws in France that make this difficult (not impossible mind you) and that we are trying to do this without having to write a huge check. It was a “dialogue de sourds” (dialogue of the deaf). No matter how hard I tried I could not get him to understand that he was sitting in another country and could not just do what he would have done in the US. He was not a bad guy (one the contrary he was very personable), he was not unintelligent and he sure wasn’t evil. He just could not wrap his head around a world so different from his own. The conversation ended on a bad note: he suggested that we go ahead and fire the guy and then explain to the court that it was corporate policy (i.e. American) not to pay the guy off. I lost my temper and said, “Sure, let’s do that and I guarantee that the French judge will DOUBLE the fine after he laughs himself silly.” I was not his favorite person after that.
    All this to say that when I listen to some of the stuff coming from US lawmakers or government employees, it reminds me a lot of this guy. They just don’t know what they don’t know. And that’s sad. Where I get angry is when I see a combination of ignorance AND arrogance.

  10. @ Victoria
    Well said.
    One example of the problems with FATCA is the difficulties Credit Unions outside if US are having with FATCA. In a submission by the World Council of Credit Unions they tried to explain that Credit Union systems in many countries are organized differently from the US Credit Union system. It appears that those writing the regulations can’t seem to understand that other countries make different choices in the structures of their financial
    The same situation applies to tax favored plans. The US has 401(k), Roth IRA, and other such plans. The current draft of the regulations appear to imply that unless plans in other countries are just like the US plans, they don’t qualify for any exemptions.
    Yes, it is ignorance and arrogance ( although I rather say IMPERIALISM).

  11. @Victoria, Hazy: That’s exactly why I call USA United States of Arrogance. They seem to believe only their laws matter anywhere in the world and that they can reign supreme in all other countries–with no consideration even given to the constitutions, laws and values of other nations.

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