Men are not prisoners of fate, but only prisoners of their mind – RIP @Marciovp – @ADCSovereignty

This is a post that I began to write on August 20, 2015. The post was in response to the death of Dr. Marcio Pinheiro.  Trish Moon wrote a tribute to Dr. Pinheiro at the Isaacbrocksociety. I urge you to read both the post and the comments to that post.

Dr. Pinheiro was a “naturalized U.S. citizen” who was living in Brazil. There is NO DOUBT that the attack on Americans abroad, which was orchestrated and prosecuted by the Obama administration, made the last years of his life a “living hell”. Marcio Pinheiro was a victim of Obama administration policies that began in 2009. These policies  shaped the finals years of Marcio’s life. For those who are NOT aware of the origins of the fear and anger experienced by Americans abroad, I invite you to read: “Never Forget What Happened in 2011” and the comments (also by Trish Moon).

I am motivated to finish this “dormant” post, by Trish Moon’s superb “It’s NOT the Taxes, it’s the Effect on Real Lives, Stupid” post which she published on December 31, 2015. That post is destined to be become a “classic”. The main purpose of the post is captured in the language:

By governments not addressing what the tax laws actually meanin the life experience of those affected (including their immediate “alien” families) they are disabling a whole class of citizens from participation in the normal opportunities available to other citizens, based upon nothing less than a U.S. claim of ownership; due in most cases merely for having been born there.

This is what we have somehow failed to communicate clearly enough. Perhaps it will take a couple of more years before the damage begins to be more obvious.

The story of Dr. Pinheiro is NOT a story of taxes. It’s the story of the extra-terroritorial application of U.S. law. It’s the story of how the provisions of those extra-territorial laws destroy the lives of those who reside outside the U.S. and are deemed by the U.S. to be “U.S. Persons” (primarily based on place of birth).  It is also a story of the role that the media, the tax compliance community, and now other governments (via FATCA IGAs) play  in the enforcement of U.S. law on the  residents and citizens of other nations. Remember that Dr. Pinheiro was a citizen of Brazil living in Brazil. Remember also that the vast majority of people affected by FATCA and the application of U.S. tax laws in Canada, are Canadian citizens living in Canada.

There is no evidence that Dr. Pinheiro owed the U.S. Government any taxes. The evidence is that his concern was his  failure to file the FBAR (“Foreign Bank Account Report”). He was required to file the FBAR to disclose to the U.S. Government the bank accounts that he used to manage his life in Brazil. The belief prior to 2015 was that: the failure to file the FBAR could have subjected him to penalties that would exceed 300% of the value of the bank account. (The IRS has only recently clarified its position on this.) Think of it: a man’s life destroyed because of fear of penalties for having not disclosed his local bank accounts to the U.S. Government (when nobody even knew of the patently absurd requirement to do so). Are Homelanders required to disclose their local bank accounts to the U.S. Government? (Those who are “Looking for Mr. FBAR should read here and here.)

Remember this. Dr. Pinheiro lived in a state of terror NOT because he didn’t want to comply with U.S. laws. He lived in a state of terror because he did want to comply with U.S. laws. Hmmm….

That’s worth repeating. This time I think I will bold it:

Remember this. Dr. Pinheiro lived in a state of terror NOT because he didn’t want to comply with U.S. laws. He lived in a state of terror because he did want to comply with U.S. laws. Hmmm….

Now continuing where I left off in August of 2015.




I have been deeply affected by the death of Dr. Marcio Pinheiro. I had followed (since as early as 2011) his comments on various blogs. An interesting partial biography of Marcio is here. In July of 2013, I was privileged to have had a lengthy conversation with him. The extent to which he was tormented by the world of CBT and FBAR was evident. He was a clear victim of the “system” of which Congress, the administration, the IRS, the media and the tax professionals all play a role. He clearly had received poor professional advice. That said, there is no way that he (like millions of Americans abroad) could have known that he had received poor advice. The result was that, at a bare minimum, the “system” destroyed the remaining years of his life. Those who are “callous” and who don’t understand the context might claim that Marcio’s wounds were “self inflicted”. This was precisely the position taken by President Obama’s lawyers in defending the Bopp Lawsuit. Perhaps his wounds were “self inflicted”? But, to be clear, his “self inflicted” wounds were the clear result of having desperately wanted to be in compliance with the laws, which created  the “system”, which destroyed his life. My experience with Dr. Pinheiro may be summarized as:


I once had the privilege of a telephone conversation with Dr. Pinheiro. He was a good man. He was a decent man. He was a family man. He was a man who “tried to do the right thing”. He was a man who believed in compliance with the law. He tried hard to comply with U.S. laws. He was a proud American citizen. He was a loyal Democrat. He supported President Obama. He believed that the FBAR Fundraiser was an unintended consequence of U.S. tax policies. He believed that President Obama and the Democrat Party would see the errors of their ways and correct the situation. He was wrong. For all of the preceding reasons, the last few years of his life were a “living hell”.

He was one of millions of people whose life was severely damaged by U.S. “Extra-territorial” taxation, FBAR and FATCA.

Then and now …

Context is everything. The “FATCA Round Up” is beginning to identify those who the U.S. defines to be it’s property people. More and more people will have their “OMG Moments“. They are having their “OMG Moments” in 2015 (or later). In 2016, it is possible to get competent legal advice. In 2016, “support groups” and “online meeting places” exist for “Grief and the UnSuspecting US Person“.  In 2016 there are online meeting places that openly discuss the injustices of the U.S. extraterritorial laws”. (Many of these “extra-territorial laws are described as tax laws. The truth is that many of those laws are NOT about tax but are about reporting.) None of these “support and educational groups” existed in 2009 – the year that the Obama Administration launched the “FBAR Fundraiser”. I mention this because, those who are currently learning about the danger of being a “U.S. person living outside the United States”, cannot understand the terror, loneliness and desperation of those who experienced their OMG moments in 2009 – 2012. They can’t understand the terror that the U.S. Government inflicted on U.S. persons abroad. They will never understand the sheer viciousness and vindictiveness of the Obama administration. They will never understand what it meant to live through the summer of 2011. In 2011 IRS Commissioner Shulman threatened American’s abroad with the language of  “This is”:

The Last Best Chance To Disclose Foreign Financial Accounts and Assets

As Trish Moon recently explained, on Jack Townsend’s blog, the summer of 2011 was an absolutely terrifying time to be an American abroad Canadian citizen with a U.S. birthplace. All components of the “system” worked together to make the lives of Americans abroad a living hell. The IRS “dusted off” laws that had never been enforced (example FBAR), sent out bulletins to the Media, which published articles describing people as tax cheats and instilling fear, which sent people to the nearest tax professional, who entered their victims into the “Offshore Voluntary Disclosure Programs”, where they offered to pay the IRS penalties (sometimes without regard to whether they were even still U.S. citizens.) It was  simply incredible. This was a time that predated things like “Streamlined Compliance” and “penalty free” ways to come into U.S. tax compliance. But, before explaining what happened in the period beginning with 2009, we need to understand some background. We need to understand some definitions.

We need to understand the definitions of:

  1. Who is a “U.S. person”; and
  2. What is an “offshore account”.

The definition of “U.S. person” includes:

  • a U.S. citizen regardless of where he may live in the world (understand that this includes U.S. citizens living outside the United States. Understand also that, under U.S. law, there is a presumption that anybody born in the United States is a U.S. citizen). There is no presumption that somebody born outside the United States is a U.S. citizen.
  • a Green Card Holder regardless of where he may live in the world (understand that this includes Green Card who no longer live in the United States but have not officially terminated their Green Card status).

The definition of “offshore account” includes:

  • and bank or brokerage account (“financial account”) that is outside the United States.

2009 – The Launch of the “FBAR Fundraiser” – AKA The “Voluntary” Disclosure Programs – “OVDP” and “OVDI”

In 2009, the Obama administration launched an attack on all “U.S. persons” with “financial accounts” outside the United States. To be clear, the objects of this attack included those who were citizens and residents of other nations. The object of this attack included those who did not even know they were U.S. citizens (the IRS offered those who did not know they were U.S. citizens the option of paying a penalty of 5% of their net worth as a penalty for not filing U.S. taxes). The attack may have been motivated (at least INTIALLY) by an attempt to punish homeland Americans who were using “offshore accounts” to evade U.S. taxes. (Incidentally, the United States is the number one tax haven in the world for those who are NOT Americans and wish to hide money from their own governments. But, no matter …) Forget the idiotic sound bites about “tax evasion”. The principal effect of the “FBAR Fundraiser” was on U.S. citizens living outside the United States (with bank accounts in their country of residence) and on Green Card Holders inside the United States (who still had bank accounts in their country of origin). The idea was that U.S. citizens and Green Card Holders who had not disclosed those bank accounts should pay a penalty to the IRS. The penalty was a significant percentage (mostly 20 – 25%) of the highest balance in those accounts. The purpose of the programs (in very general terms) was to “allow” people with “unpaid U.S. tax” associated with undeclared “offshore accounts” to pay a penalty to the IRS in exchange for non-prosecution. In the vast majority of cases, people simply did NOT know about the requirement to disclose these “offshore”  (from the perspective of the US) accounts but local  (from the perspective of Americans abroad) accounts, to the U.S. Government. These arrangements were called the “Offshore Voluntary Disclosure Programs” (OVDP, OVDI). For, the record I do NOT believe that the IRS had Americans abroad in mind, when they initially created the “Offshore Voluntary Disclosure Programs”. That said, I do believe that the IRS was willing to accept money from any source that would pay it money. But, the IRS was not the main culprit. After all, the IRS did not decide who entered the the “Offshore Voluntary Disclosure Programs”. Completely innocent Americans abroad (and some who were not even U.S. citizens) were lured into the “Offshore Voluntary Disclosure Programs” by tax “professionals”. History will record that far more damage was done by those tax professionals – the lawyers and accountants – than was done by the IRS! We will call this initiative by the U.S. Government, which was executed by the “Tax Professionals”: “The FBAR Fundraiser”. That said, in fairness to the “Tax Professionals” NOWHERE on the IRS website was there an indication that the “Offshore Voluntary Disclosure Programs” were NOT appropriate for average Americans abroad who were paying taxes in their country of residence.

(Note that the IRS “Compliance Options” have evolved over time. In general, (IMHO) the IRS has acknowledged that the “Voluntary” Disclosure programs from 2009, 2011, and 2012 were NOT appropriate for Americans abroad. The first version of “Streamlined Compliance” took effect in the fall of 2012 and the current version took effect in 2014. At the present time, it appears that most non-compliant Americans abroad can become U.S. tax compliant on a “penalty free” basis. An excellent summary of the evolution of the “Disclosure Programs” and options for “non-compliant Americans abroad is here – pay attention to the comments. That said, I continue to maintain that the bigger problem for Americans abroad is to actually live as a U.S. tax compliant American abroad.)

Dr. Pinheiro’s problems began during the “The 2009 FBAR Fundraiser”

It was in 2010, that Dr. Pinheiro, a U.S. citizen residing in Brazil, learned of his obligation to file the FBAR “Foreign Bank Account Report”. Note that Dr. Pinheiro had been filing U.S. tax returns while living in Brazil. He described his discovery of Mr. FBAR as follows:

In 2010 I was visiting with my daughters and son in LA when I decided looking an a CPA Organization that catered to Americans Living Abroad. That was the first time I learned about FBARs. I also learned that I was already an outlaw because I should have sent them yearly since 2003. The first lawyer I contacted asked me for $15,000.00 up front to defend me from my crime and also told me that I would have to pay 50,000.00 to the IRS. I became more panicky. The CPA I was dealing with told me that I did not have to do this and that all I need to do was to send the FBARs for the previous six years explaining why I did not send them before, She could not tell me if they would accept this or not.

That started my ordeal. Since 2010 up to now my life because a nightmare. Now I not only had to file the US IRS Return every year but also had to send the FBARs, Since being in Brazil and not having US CPAs here I tried to do it on my own. And this took a lot of time and worry. I became a problem for my family because the time I spent trying to do the right thing. I had conflicting advises on what to do, or course always taking in consideration the draconian penalties they would hit me with for not done it before. If you look at the screen of my computer you will see that amount of e-mails I sent to US CPAs and Tax Lawyers. There are many pages with the e-mails coming and going.

Why did Dr. Pinheiro not know about the FBAR?

The answer is simple. Nobody knew about the FBAR. This did NOT stop the IRS from threatening draconian penalties for failure to file this form (which nobody knew about). The United States may be a tyranny. But, the IRS (at least in the summer of 2011 was a “terrorony”. This blog post by Phil Hodgen illustrates some of the context.

Dr. Marcio Pinheiro’s life can be understood only in that context. He was isolated in Brazil without competent legal advice, with nobody to talk with, already in the U.S. tax system (meaning he had nowhere to hide) with the knowledge that he had not been filing his FBARs. He was scared out of his mind. He was scared because he wanted to be in compliance with U.S. laws! Again, he was scared because he wanted to be in compliance! That’s the context.

The U.S. Tax “System” (not considering the content of the laws) – Greater than the sum of the parts – Consisting of four branches

Branch 1:  Congress – responsible for making the laws. The Internal Revenue Code is an Act of Congress. In most cases individual Congressmen neither read nor understand what they sign. Very few Congressmen even know what “citizenship taxation”, FBAR and FATCA are. Furthermore, U.S. tax laws rarely (if ever) consider the effects of the laws on Americans abroad. (Note that almost ALL tax laws affecting Americans abroad – including FATCA – are “Revenue Offset” provisions.)

Branch 2: Treasury/IRS – the branch of the U.S. Government that is responsible for implementing the laws enacted by Congress. Treasury/IRS is part of the executive branch of the U.S. Government. To put it simply: Treasury/IRS is responsible for the collection of revenue according to the Internal Revenue Code. That does NOT mean that IRS must understand every provision of the Internal Revenue Code. My guess (and this is speculation) is that few people in the IRS understand the vast regulatory regime that applies to Americans abroad. Note also that Americans abroad cannot talk directly to the IRS. They are forced to interact with the IRS through the “Tax Professionals”.

In addition, Treasury (meaning the Obama administration) through it’s power to make regulations has the ability to “fix” most of the damage inflicted on Americans abroad. A reading of the relevant statutes makes it clear that by regulation Treasury could:

– completely exempt Americans abroad from the FBAR rules
– effectively exempt Americans abroad from the FATCA Form 8938 requirements
– raise the reporting threshold for PFICs to level that would effectively exempt most Americans abroad
– confirm that many non-U.S. retirement programs (including the Australian Superannuation) are to be treated as “Social Security” (and therefore tax exempt under the U.S. Australia tax treaty)
– and much more

The Obama administration has been unwilling to acknowledge the “fiscal prison” that U.S. citizenship taxation has become and by a “stroke of the pen” elminate these problems

Branch 3: The Tax Professionals – These include lawyers, CPAs, Enrolled Agents, and tax preparers. The latter two are specifically licensed by the IRS.

 What needs to be understood is that:

  1. U.S. tax laws are NOT enforced by the IRS as much as they are enforced by the “Tax Professionals”.
  2. The “Tax Professionals” “create” the interpretation of various laws by how they respond to them. (There is a reason that nobody knew about PFICs prior to 2009.) Is a TFSA really a “foreign trust”? Are the S. 877A Exit Tax rules retroactive?
  3. Tax Professionals are NOT independent of the IRS and depend on the IRS for their livelihoods.
  4.   Tax Professionals are also subject to Circular 230 which is the “Rules of Practice” before the Internal Revenue Service.

Understand that very very few “tax professionals” inside the United States know anything about U.S. taxation of its citizens abroad. This is a complex area that is highly specialized.

This is why your choice of tax professional matters very much! Tax Professionals  are NOT all the same. The fact that they are a licensed EA, CPA or lawyer is completely irrelevant. Some of them understand this stuff and some don’t. When it comes to “International Tax”, there is an exceptionally long learning curve. Regardless of their intention, tax professionals have, through their possible ignorance, possible incompetence and almost certain desire to “get along with the IRS”, the potential to completely destroy you!

Branch 4: The Media – Literally every aspect of U.S. life is regulated by the Internal Revenue Code. In fact, Americans are the most regulated people on the planet. The media outlets play a major role in disseminating information about taxation. (See this December 30, 2015 article which appeared in the Toronto Globe and Mail.) The media was almost completely responsible for advertising the IRS “Voluntary Disclosure” programs. Note that the Media knew nothing about what it was advertising. The media has never understood that U.S. “tax laws”, as applied to Americans abroad, are NOT about taxation. These laws are about “life control”. These laws are about imposing “investment and retirement planning restrictions” on Americans abroad. These laws are about requiring the disclosure of information under the threats of draconian penalties. These laws affect all aspects of the lives of “Americans abroad”. For the most part, the media has been complicit in painting those “Born In The USA” as “tax cheats” (without regard to whether they are citizens and residents of the country where they reside).

Understanding the “system” – It’s more than the sum of the interaction of the “moving parts”

Congress creates a framework. The IRS administers the framework. The IRS sets the “tax professionals” loose on the public to collect what they can. When it comes to “Americans abroad”, the complexity and unfairness of the laws means that the “tax professionals” are the primary enforcers of U.S. tax law. In some cases, they are the equivalent of “bounty hunters” – transferring the wealth to the IRS. Like it or not, the “System” means that most “tax professionals” are working for the IRS and not for you! The media:

  1. Creates the awareness of the U.S. extra-territorial law;
  2. Describes the problem as a “tax problem” (when it is often a “citizenship” problem);
  3. Creates fear;
  4. Which sends people to the office of the “tax professionals”.

It’s frightening to be an “American abroad” Canadian citizen with a U.S. birthplace who is NOT in compliance with U.S. laws …

Dr. Pinheiro’s story is the story of someone who had filed U.S. tax returns and had not filed FBARs. It is an established fact that the anxiety and fear that he experienced severely diminished the quality of his life. It is possible that the fear and anxiety led to a premature death.

Why did his “non-FBAR compliance” have such a devastating effect on him? I asked him the question: Why did this experience affect him in the way that it did? What was the personality type of those who were most affected by the “Offshore Jihad“? I replied that he did not know. My personality theory is this:

The U.S. rules of “extra-territorial taxation” (which have more to do with information disclosure than taxation) cause severe psychological and emotional damage to those who try the hardest to comply with the law.

Yes, it’s frightening for Canadian citizens and residents with a U.S. birthplace, to live outside the U.S. and NOT be in compliance with U.S laws. Yet …

It’s frightening to be an “American abroad” Canadian citizen with a U.S. birthplace who IS in compliance with U.S. laws …

Trish Moon describes the “effect” of compliance with these U.S. laws on the lives of Canadian citizens with a U.S. birthplace. She writes:

By governments not addressing what the tax laws actually meanin the life experience of those affected (including their immediate “alien” families) they are disabling a whole class of citizens from participation in the normal opportunities available to other citizens, based upon nothing less than a U.S. claim of ownership; due in most cases merely for having been born there.

Well said. How true. I recently tried to explain to “Americans abroad”: How To Live Outside The United States In An FBAR And FATCA World .

Excerpts from the post include:

if a U.S. citizen lives outside the United States that he lives according to the principle that:

“When in Rome, live as a Homelander” does, when elsewhere, live as they live elsewhere.

Ten Commandments:

1. Thou shalt NOT have a bank or brokerage account outside the United States. If you do so, it must be reported to U.S. Financial Crimes on an annual basis. Failure to disclose is “Form Crime”. You may be fined an amount that is more than 300% of the value of the account.

2. Thou shalt NOT marry an “alien”. If you do so, you will have difficulty leaving your estate to him or her. Better to return to the Homeland to search for a suitable spouse.

3. Thou shalt ensure that your “alien” spouse agrees to be a U.S. taxpayer. Failure to do so, will result in your having the punitive filing status of “married filing separately”. This will guarantee greater exposure to the Alternative Minimum Tax, the new 3.8% Obamacare surtax, higher tax brackets and lower thresholds for reporting (including FATCA Form 8938) requirements.

4. Thou shalt NOT believe that the sale of your principal residence is a “tax free capital gain”. In fact, the sale of your principal residence will trigger a 23.8% capital gain which means that your house cannot be used as a retirement investment.

5. Thou shalt NOT buy non-U.S. mutual funds. If you do, you will have your gains confiscated in the form of an “Excess Distribution” Tax. Buy American. Buy U.S. mutual funds.

6. Thou shalt buy ONLY “term insurance”. Any other form of “insurance that has cash value” will be treated as a sacred instrument of tax evasion. Furthermore, if you purchase a “foreign insurance policy” thou shalt pay a special excise tax.

7. Thou shalt NOT buy or participate in an RESP, RDSP, employer pension plan, or any other kind of retirement planning vehicle which will be considered to be a TAXABLE “Foreign Trust” (with all the attendant penalty laden reporting requirements).

8. Thou shalt neither be self-employed NOR carry on business through a non-U.S. (AKA “Foreign”) corporation. If you do, punitive taxes, deemed income, and expensive reporting requirements will descend on you.

9. Thou shalt NOT relinquish U.S. citizenship. In the event that you do, you may be subjected to an “Exit Tax” which applies to your “non-U.S.” pension, “non-U.S.” assets, and assets that accumulated after you ceased to live in the United States. In addition, there are certain “Form People” who claim that you may be banished from the Homeland forever.

10. Thou shalt file, every year, file the following forms with the IRS: 1040 and all required schedules, FBAR, FATCA, 8938, 8965, 3520, 3520A, 709 (up to a maximum of up to about 45 forms). Understand that this will cost you thousands of dollars.

And this ladies and gentlemen, is why your problem is NOT “coming into U.S. tax compliance”. Your problem is “living as a tax compliant U.S. citizen abroad”. It really can’t be done (if you want any kind of life).

So, you want to renounce U.S. citizenship and cease being a “U.S. citizen abroad” …

Leaving aside the $2350 USD fee, there are tax consequences to renouncing U.S. citizenship. These consequences are found in S. 877A of the Internal Revenue Code. At the risk of oversimplification, the costs associated with renouncing U.S. citizenship will include:

  1. The costs of a total of 6 years of U.S. tax compliance. These costs are composed of (1) professional fees and (2) back taxes and possible penalties;
  2. The possibility of paying an “Exit Tax” which is based on the value of your assets.

Conclusion …

If you are a Canada Canadian citizen and resident who is deemed by the United States to be a “U.S. person”:

  1. You will live with the anxiety and terror of NOT being U.S. tax compliant; or
  2. You will live with the anxiety and life restrictions of attempting to be U.S. tax compliant;or
  3. You will have to pay the costs of “buying your freedom” by renouncing your U.S. citizenship and possibly being subject to the U.S. Exit Tax Regime

Really, you can’t make this stuff up.

It’s NOT the Taxes, it’s the Effect on Real Lives, Stupid …

At the end of the day the vast majority of Canadians required to file U.S. taxes owe little or no taxes. (That said there are many who owe very significant amounts of U.S. taxes.) Yet, the problems remain. The amount of tax owed is rarely the issue. It’s the effect of U.S. laws that purport to be about taxation but are really about life control that are the problem.

As long as the U.S. Government, the Government of Canada, the courts, the lawyers, the IRS, the Tax Professionals and the Media are permitted to frame these issues as “tax issues” the problems will remain. The simple fact is that the U.S. Internal Revenue, is not, when applied to those who reside outside the United States, about taxation. It’s about “life control”. It simply cannot be permitted to continue. It makes it impossible for those who are deemed to be “U.S. Persons” (sounds like a claim of ownership) to survive outside the United States. The time has come for all stakeholders to look beyond what these laws say, look beyond what is required to comply with these laws, and look into exactly how these laws effect the citizens and residents of other nations. It’s definitely time. It is hoped that the ADCSovereignty lawsuit will provide such opportunity!

Back to the beginning: Men are not prisoners of fate, but only prisoners of their mind …

Dr. Marcio Pinheiro was a prisoner of a mindset that told him, that even though he was  a citizen and resident of Brazil, he was morally obligated to comply with U.S. laws. It was his desire to comply with the laws that at best destroyed the remaining years of his life and at worse …

There is something profoundly unjust about a system that makes compliance with the law so destructive to one’s health and well being.

But, Dr. Pinheiro was not the first and he will not be the last to suffer from a “system” where:

– you are in severe trouble if you don’t comply; and

– you are in worse trouble if you do comply!

Rest in Peace, Dr. Pinheiro. You were a good man. You represented the very best that America had to offer. I feel privileged to have met you!

You leave us to consider the issue of whether:

Americans abroad are really the prisoners of fate, or whether they are prisoners of their own minds!

John Richardson

P.S. What follows is a video of Charles Adams a member of the National Finance Committee For the Obama Campaign. This was days before the 2012 Presidential Election. You may find the video interesting for three reasons:

  1. It demonstrates that the Obama administration was very clear about the damage that FATCA was doing to Americans abroad
  2. It strongly suggests an attempt by the Democratic Party to mislead voters about the “intention of the Obama administration” to remedy the most damaging effects of FATCA on Americans abroad.
  3. Notice the comment from Dr. Pinheiro. The poor man believed in the Democratic Party until the end. What a betrayal! But, as the song says: Ain’t that America …


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