Wednesday, July 27, 2016

Kadet and Koontz on an Objective Ethical Framework for MNC Tax Planning

Jeffery M Kadet and David L Koontz have recently posted a two-part article entitled "Profit-Shifting Structures: Making Ethical Judgments Objectively," of interest and available on SSRN: parts one and two. From the abstract:
MNCs and their advisors have seemingly taken ethics out of the mix when considering the profit-shifting tax structures they have so prolifically and enthusiastically implemented over the past several decades. ... Given the strong motivation to implement such structures, a counterweight is needed to balance the unfettered acceptance and adoption of profit-shifting strategies based solely on the mere possibility that they might pass technical tax scrutiny by the government. Greater thought needs to be given to whether these plans are consistent with and serve the long term objectives of the MNC and its many global stakeholders. Stating this proposition more directly, it is time to ask if all of these stakeholders would accept the efficacy of these structures if they were made fully aware of and understood the technical basis, the strained interpretations, the hidden arrangements, the meaningless intercompany agreements, the inconsistent positions, and the lack of change in the business model for the schemes proposed or already implemented.
This article presents an objective ethical benchmark to test the acceptability of certain profit shifting structures. ... In brief, this ethical benchmark requires an examination of the factual situation for each of an MNC’s low or zero taxed foreign group members regarding three factors, which are: 
(a) identification and location of critical value-drivers,(b) location of actual control and decision-making of the foreign group member’s business and operations, and(c) the existence or lack thereof of capable offshore management personnel and a CEO located at an office of the foreign group member ... who has the background and expertise to manage, and does in fact manage, the entity’s business. 
Through this examination, it should be possible to determine whether a foreign group member is recording income that is economically earned through business decisions and activities conducted in the jurisdiction in which it claims to be doing business. ... This benchmark should be used by MNCs with the active participation of board and management members. An MNC could also use this approach to proactively respond to critics or to demonstrate its tax bona-fides. 
The article contributes to an ongoing discourse about how states can tax multinationals effectively, and how tax planning decisions should be assessed, in a world of global capital mobility and flexible commercial structures.

Tuesday, July 26, 2016

Cabezas on Institutional Legitimacy in the State Aid Cases

A few weeks ago via twitter I shouted out two of my students who won this year's Tax Analysts Student Writing Competition, in the international category. One of those two papers is now available on the Tax Analysts website (normally gated, but this is free to view): Private Meetings and Institutional Legitimacy: Apple and the EU. Here is the brief abstract:
Montano Cabezas examines the private meeting between Apple Inc. CEO Tim Cook and European Commissioner for Competition Margrethe Vestager regarding the ongoing state aid investigation against Ireland.
The article reviews the Apple state aid case and the Competition Commission's review process, and analyzes Cook's attempts to intervene, asking "What is the harm that could be avoided by eliminating ex parte communications between interested parties and the commission in state aid investigations?" The article concludes as follows:
Following the LuxLeaks and Panama Papers scandals, there is a general popular belief that collusion exists between government bodies and wealthy taxpayers -- whether individuals or MNEs -- and that any form of offshore planning is therefore indicative of cheating and abuse. Viewed in that context, an off-the-record meeting between the head of an international investigative body and the leader of one of the world's most powerful corporations seems severely misguided. 
The commission is a sophisticated actor and should know better. It seems clear that a private meeting between Cook and Vestager would damage the public perception of the commission's legitimacy and impair the commission's political capacity to operate. Apple had a right to make written submissions to the commission, and the commission had a corresponding right to ask Apple directly for further information about its relationship and dealings with Ireland. By taking a shortcut around those formal procedures, Vestager weakened the institutions responsible for the administration of justice.
A timely article, as meetings between the Commissioner and various US stakeholders, including the U.S. Treasury, have continued. The Commission's decision is expected this fall.


Analysis of Canada's Tax Gap Pre-Study

Further to my last post on the newly released Tax Gap study by the Canada Revenue Agency, the following comes from guest blogger Iain Campbell (ARC, UK):

I hope this comment is not too long but I’ve been following Tax Gap discussions for so long that it’s hard to pass by the chance to comment!

Background
This is an interesting development. Writing from the UK I’m not in regular contact with developments in Canadian tax administration. But I do recall there has been some entertainment over the Tax Gap, with the Parliamentary Budget Officer asking for the CRA to do some work on it - and being rebuffed.

In fact, the CRA has not been keen on preparing a Tax Gap analysis. In 2002 it reported that attempting to estimate overall levels of reporting non-compliance such as the ‘tax gap’ or the total amount of smuggling activity was fraught with difficulty. (CRCA Performance report for the period ending 31 March 2002.) Ten years later the CRA were still not convinced. At the start of 2013 they told the PBO:

The CRA later pointed out “the significant debate about the precision, accuracy and utility of any methodology to calculate the tax gap”. It drew attention to critical comments from the UK Treasury Select Committee, as well as the fact of 52 tax administrations surveyed by the IRS, 33 did not produce one, and the high costs of doing so. (CRA, PBO Information Request IR0102: tax gap estimates, letter 20 March 2013,] and PBO Information Request IR0102: tax gap estimates, letter 1 August 2013.) In 2014 the PBO even threatened to take legal action in order to compel production.
But in the recent election there was a promise to undertake such a study, ending this long standing reluctance to follow the example of other countries, including the USA and UK.  And following the Panama Papers the Revenue Minister said in January a tax gap study would be done. The new Canadian study comprises a 31pp paper on a conceptual study of the Canadian tax gap and an 11pp study on the Canadian GST/HST, which gives a gap of 5.5% in 2000 and 6.5% in 2014. (It explicitly references the decision announced by the Minister of National on 11 April.)

Basis of study – what’s in and what’s out
The conceptual study does, to an outsider, seem to spend a lot of time in not saying a great deal. It seems to add qualification to qualification, caveat after caveat, so that at times I wondered if the CRA really wanted to publish anything at all. Gus O’Donnell is the UK civil servant who wrote the Report that led to the UK Customs and Excise combining with the Inland Revenue to form HM Revenue and Customs. In that Report he surely got it down to a few words: “Making estimates of the tax gap is methodologically and empirically difficult, although easier for indirect taxes where tax can typically be related to consumption. Direct tax gaps are particularly difficult to estimate because the aggregate figures for income, for example, are built on tax data.”

The CRA's conceptual study refers a lot to the HMRC papers and policies on calculating the Tax Gap. But in some of the key areas it dances around what might be difficult decisions e.g., whether to report the gross tax gap, or, as in the UK, the gap after action to tackle non-compliance.

Avoidance
More controversially, the UK includes tax avoidance.  This is a good illustration of its overall approach.


On the other hand, academics and members of the accountancy profession have argued the opposite, that any estimate should not include avoidance as referenced by the “spirit of the law”. For example, during a Treasury Select Committee Hearing on The Administration and Effectiveness of HMRC, Judith Freedman (Professor of Tax Law, Oxford University) commented “I really take issue with the spirit of the law part, because either you have law or you don’t have law and the law has to state what it is.”

The Canadian paper discusses this option and concludes “the appropriate treatment of tax avoidance is less clear”. It seems Canada has decided to not include avoidance in its definition: “In general the CRA’s approach to the tax gap encompasses non-compliance related to non-filing, non-registration (in the case of GST/HST), errors, under-payment, non-payment, and unlawful tax evasion” (p29).  There seems to be no explicit position on avoidance but, although I doubt it will happen, “under-payment” is potentially broad enough to include under-payment via avoidance.

Other “Gaps”
Another area the study did not address is what the IMF and EU call the “tax policy gap”. I agree with this decision (which mirrors the UK). The IMF would widen the definition and use of the Tax Gap approach. It suggests including the effects of policy choices that lead to reduced revenues. In a study on the UK Tax Gap it refers to the impact of compliance issues on revenue as “the compliance gap” and the revenue loss attributable to provisions in tax laws that allow an exemption, a special credit, a preferential rate of tax, or a deferral of tax liability, as the “policy gap” (para 68).  As part of this they recommend tax avoidance schemes deemed legal through litigation should be considered part of the policy gap, not the compliance gap, and this distinction should be made clear.

A similar point was made by an EU report on VAT. They suggested that a possible link between the policy and the compliance gaps, since using the reliefs and allowances intended by policy could make compliance more difficult. “Reducing the policy gap may often be the simplest and most effective way to reduce the compliance gap. “ (p21)

In my view these kinds of proposals are likely to be very complex, perhaps contentious, and hard to administer. It seems a sensible decision to not refer to them or suggest their inclusion.

Then there are the base erosion issues where tax is avoided through the use of legal structures that make use of mismatches between domestic and international tax, e.g. permanent establishments. The Canadian study nods in the direction of BEPS and then passes by.

What’s the point of working out a Tax Gap?
But putting aside these sorts of issues, or whether “top-down” targeting is better than “bottom-up”, does the size of the hidden or “informal” economy predict the level of GST/VAT underpayment (or is it the other way around?), perhaps the  big $64K question is whether any of this means anything. If there is no clear agreement on the numbers, how they are calculated and their reliability, then is there are any point in preparing them?

The very concept of the tax gap is not universally agreed to be a useful analytical or strategic lever. Apart from the earlier Canadian reluctance, the Australians were slow to go down this road. UK Parliamentarians have been less than keen. In 2012 the Treasury Select Committee said they thought it was essentially a waste of time and resources. Worse, they feared it would misdirect HMRC away from ensuring every taxpayer paid the right amount of tax. Such fears have not died. The current TSC is examining UK corporation tax. Their early work involved scoping the problem and they heard some evidence on the tax gap. Andrew Tyrie (the Chair) seemed less than enthused at the very concept.

I think it has merits. But it ought not to be elevated to some shibboleth. It is one high-level measure of how successfully legislation is being applied, use of resources, etc.  The UK Government’s official position is that that “thinking about the tax gap forces the department to focus attention on the need to understand how non-compliance occurs and how the causes can be addressed—whether through tailored assistance, simpler legislation, redesigned processes or targeted interventions. Measuring the tax gap helps us to understand whether increasing returns from compliance activity reflect improved effectiveness or merely a decrease in voluntary compliance.”

The Canadian paper says broadly the same things (pp22-24). It talks of providing insight into the overall health of the tax system, of understanding the composition and scale of non-compliance, but warns of their limitations.

If that is how it used then I think it is a useful aid to policy making and how robust is the assurance being provided by the tax administration.


Tuesday, July 5, 2016

Canada "Tax Gap" Study Released

The Government of Canada has released its first study of the "tax gap," which the Government defines as "the difference between the tax that would be paid if all obligations were fully met in all instances, and the tax actually paid and collected." The Canada Revenue Agency (CRA) has not completed a study of the income tax, but has released this paper on the concept and methodology. It has presented a report for GST/HST (Canada's VAT), estimating the tax gap to average about 5.6% per year over the period 2000-2014. For 2014, this produced an estimated tax gap of about $4.9 billion:



This study has been undertaken after many calls from academics and nongovernment organizations, including Canadians for Tax Fairness, which according to the CRA will be involved in consultations regarding the ongoing study. Canadians for Tax Fairness estimate that Canada loses $7.8 billion in income tax revenues to "tax haven" use, a number they constructed using Statistics Canada's foreign direct investment data.

The Government acknowledges that there is no reliable method for measuring the tax gap, and that the exercise is one in speculation based on imperfect information:
There are a number of challenges facing tax administrations undertaking tax gap estimation. The key challenge is access to the comprehensive and good-quality data necessary to produce estimates. A significant proportion of the tax gap involves unreported or under-reported income and assets and economic activity that are deliberately hidden from the government. As a result, many countries that publish tax gap estimates highlight their uncertainty.
Expect more to come from this exercise as the tax gap study is a key component of the Government's pledge to spend $444 million over five years "to enhance [CRA] efforts to crack down on tax evasion and combat tax avoidance."

Monday, June 27, 2016

Corporate Tax for the 21st Century

I'm in Oxford today for the Said Business School's annual summer conference, staying for the academic conference the remainder of the week. Here is today's program; see comments on twitter with #ct21

09:00-09:30
09:30-11:30
The need for reform, and current policy proposals
Michael Devereux, Oxford University Centre for Business Taxation
Welcome and introduction
Chair: John Vella, Oxford University Centre for Business Taxation
Michael Graetz, Columbia University and Yale University
The need for reform
Michael Devereux, Oxford University Centre for Business Taxation
Principles for reform
Wolfgang Schön, Max Planck Institute for Tax Law and Public Finance, Munich
Reforms on the current political agenda
Reuven Avi-Yonah, University of Michigan
Valeska Gronert, European Commission
Discussion
11:30-12:00Coffee
12:00-13:30
Residual Profit Allocation Proposal
Chair: Wolfgang Schön, Max Planck Institute for Tax Law and Public Finance, Munich
Paul Oosterhuis, Skadden Arps LLP
Michael Keen, International Monetary Fund
Jennifer Blouin, Wharton Business School, University of Pennsylvania
Steve Edge, Slaughter and May
Discussion
13:30-14:30Lunch
14:30-15:45
Destination Based Cash Flow Tax Proposal, and developing countries
Chair: Judith Freedman, University of Oxford
Michael Devereux, Oxford University Centre for Business Taxation
Rachel Griffith, Institute for Fiscal Studies and University of Manchester
Malcolm Gammie QC, One Essex Court
Discussion
15:45-16:15Coffee
16:15-17:30
Panel Discussion
Chair: Michael Devereux, Oxford University Centre for Business Taxation (Chair)
Ian Brimicombe, AstraZeneca Plc
Alex Cobham, Tax Justice Network
Michael Graetz, Columbia University and Yale University
Rt Hon Dame Margaret Hodge MBE MP, House of Commons
Vanessa Houlder, Financial Times
John Kay, Financial Times

Sunday, June 26, 2016

Tax Avoidance in a World of Aggressive Tax States

I finally got around to posting the presentation I made last month at the Journal of Tax Administration Conference on "The Changing Shape of Tax Avoidance." The paper upon which this presentation is based is still in progress, I'll post a draft soon. I would be very happy to have comments on the ideas I am developing in this project.

Wednesday, June 8, 2016

OECD seeking "technical" input from the public on "multilateral instrument" to modify tax treaties

The OECD recently released what it calls a "public discussion draft" in connection with its work on the multilateral instrument (MLI), and seeks public input until June 30. As I explained in a post a  few months ago, the MLI is be used to 'modify' all existing tax treaties in force among signatory countries to conform to BEPS standards and recommendations. However, the released document is not actually a discussion draft of the MLI--there are no terms to be reviewed. The drafting committee, which currently includes 96 members (OECD members and "BEPS Associates"), only met for the first time two weeks ago so this is decidedly not a draft of substantive provisions to be debated in the public discourse. No, that would be chaos and contrary to the plan:
"the draft text of the multilateral instrument is the subject of intergovernmental discussions in a confidential setting."
Instead it is in effect a crowdsourced, and very carefully framed, issue-spotting exercise. The document consists of three pages: page one is the BEPS narrative (why the OECD undertook this project and what has happened so far). Page two describes what BEPS changes will be covered in the MLI once drafted. Page three lays out three "technical issues" the OECD faces in drafting the MLI, and finally gives the call for input. The discussion is very brief and in OECD-passive-speak so it's almost comical to summarize but here are the three issues, as I understand them:
  1. the MLI must be able to modify existing treaties, and this will be done with "compatibility clauses."
  2. the MLI will be broadly worded so will require commentary and maybe explanatory notes for consistent interpretation
  3. the MLI will be in French and English but will interpret thousands of treaties written in different languages.
These are all very interesting international law issues and not technical tax law issues at all. They are also clear expressions of intent to cement the OECD's role as the principal curator of international tax norms. This is especially clear in respect of point 2, because consistent interpretation means that the OECD commentary and "guidance" must harden ("ossify") into more persuasive and ultimately binding legal authority. For a discussion of what that implies for the rule of law, see this old thing I wrote a long time ago.

Point 1 raises the issue that seems to me most difficult in terms of the transition to complete OECD domination of global tax policy: I am still not sure how the MLI is supposed to work on top of a network of individualized and distinct bilateral agreements among sovereign nations. The OECD says "If undertaken on a treaty-by-treaty basis, the sheer number of treaties in effect would make such a process very lengthy." Indeed it would but as a matter of law in many countries, revising an existing international agreement requires another international agreement that is ratified in the same manner as the original, which appears to require the signatories to come to a meeting of the minds as to the terms that govern their unique relationship. The OECD says that distinguished experts have carefully considered the public international law questions at hand. But I haven't seen any study and I don't quite understand how you get a coherent international tax law regime in anything like a "quick" process. The OECD's implied answer in point 1 only raises another question for me: what is a compatibility clause? Is this a well-understood mechanism in play in other areas of international law? Can I get a precedent somewhere to anticipate where we are going with this?

Further, is the MLI going to be a matchmaking exercise in practice? If country A agrees to revisions 1 through 6 as to countries B and C, but only revision 5 as to country D, and country B agrees to revisions 1-3 for countries A and D but only 5 and 6 for C, and countries C and D agree in principle but never ratify anything, then what, exactly, are the agreements between and among these countries?

I am also not sure what the agreement matrix looks like when there are multiple standards for several of the BEPS items.  Notably the "prevent treaty shopping" minimum standard provides multiple choices for defending treaties against "abuse": a principal purpose test, a limitation on benefits provision, an anti-conduit provision, or some combination. May each of countries A, B, C, and D choose a different combination vis a vis each of the others? It is difficult to see convergence. At the panel I attended in Montreal a couple of weeks ago this was a topic of vigorous discussion. The more I think about this, the increasingly uncertain I become regarding how this is going to work out in practice.

Any thoughts on these observations are welcome as I develop my thinking on these issues. And if you are submitting comments, please note:
 Comments and input should be submitted by 30 June 2016 at the latest, and should be sent by email to multilateralinstrument@oecd.org in Word format (in order to facilitate their distribution to government officials). Please note that all comments received will be made publicly available. ... Persons and organisations who submit comments on this document are invited to indicate whether they wish to speak in support of their comments at a public consultation meeting that is scheduled to be held in Paris at the OECD Conference Centre on 7 July 2016 beginning at 10.00 am.






Call for expressions of interest: Moot court on international taxation of digital services

I will be presiding over a moot at the annual conference of the International Fiscal Association this fall in Madrid. The topic as described below is vague, but suffice to say that recent news stories are driving (ahem) the topic forward. The moot is now open to expressions of interest by prospective participants who meet the eligibility requirements described below. Here is the info:


Young IFA Network Moot Court – Madrid, September 28, 2016
Expressions of Interest due June 15, 2016

All members of the Young IFA Network are invited to submit an expression of interest as a moot court speaker at the YIN Moot Court during the 70th Congress of the International Fiscal Association in Madrid, Spain.

YIN at IFA
During recent Congresses in Amsterdam, Kyoto, Brussels, Vancouver, Rome, Paris, Boston, Copenhagen, Mumbai and Basel, the Young IFA Network (YIN) organised a Moot Court.

YIN Moot Court Format
The YIN Moot Court will be held at the Conference Venue on Wednesday, September 28, 2016 from 3:15 pm to 4:45 pm. An acting Tax Judge (Allison Christians, Canada) will preside over a hypothetical tax case relating to digital services to be argued by young tax academics or professionals, one side representing the Tax Authorities and the other side representing the Taxpayer. At the end of the arguments, the acting Tax Judge will render her judgment on the tax case. The fact pattern for the case, the legal issues involved, and a summary of the case will be made available to the delegates before the start of the Moot Court.

Expression of Interest for Speakers at the Moot Court
YIN members that are interested in being one of the speakers at the Moot Court are asked to express their interest to Sanjay Iyer (sanjay@iyerpractice.com) on or before June 15, 2016 along with a brief profile/CV that shall assist the Committee in the selection of the speaker.
Eligibility requirements:
1.     YIN Member of an IFA branch
2.     40 years of age or below
3.     Registered for the 2016 Congress in Madrid, Spain.         

Thursday, May 26, 2016

What does it mean to implement BEPS?

Today I took part in a panel discussing the topic of "Life After BEPS," at which I laid out the three categories of BEPS commitments in three slides. These categories are "minimum standards" (there are four), "recommendations" (there are several) and "best practices" (there are many). These are defined terms in BEPS world but it is already fascinating that there is some category blurring going on in the discourse surrounding implementation. I'm interested in that blurring because of course we are in the midst of a major cycle of law- and norm-making in international tax, and "what countries actually agreed upon" is really going to matter pretty soon, as the difference between convergence and divergence depends on a meeting of the minds at the level of rulemaking. This will play out through conflict and resolution at the domestic and international level in the form of both hard law (multilateral and bilateral agreements and domestic law changes) and soft law (OECD models, guidelines, and peer monitoring). In case they are of interest, I thought I would post my three slides here.




Tuesday, May 17, 2016

Kill Switches in the New US Model Tax Treaty

I posted previously on the new US Model, which was released in February of this year; I've now posted my article, co-written with McGill PhD student Alex Ezenagu, on the "kill switch" provisions in the new model. These provisions are found in the new articles and definitions involving special tax regimes and subsequent law changes, which would allow countries to switch on and off specified treaty benefits if their treaty partners get too aggressive in the ongoing race to the bottom on tax.

Here is the abstract:
The new US model income tax treaty contains an unusual addition: mechanisms for the parties to unilaterally override the negotiated treaty rates in specified circumstances. Previewed last year in proposed form—a first for Treasury—these new mechanisms work as kill-switches, partially terminating the treaty as to one or both treaty partners. The idea is to forestall a more problematic outcome, such as an enduring breach of one of the parties’ expectations, or the opposite, a complete termination of all the treaty terms in the face of such a breach. Yet embedding a kill-switch in a treaty creates distinct legal, procedural, and political pressures in the tax-treaty relationship that implicate treaty negotiation, ratification, interpretation, and dispute resolution. Kill-switches also communicate a defensive tenor in the tax treaty relationships among many countries. This Article analyzes the new kill-switch provisions and concludes that their introduction in the U.S. Model reflects the steady deterioration of tax treaties from essentially diplomatic documents premised on the good faith of the parties to detailed contracts drafted in anticipation of the opposite.
It has long been assumed that tax treaties are uncontroversially technical agreements that no one outside of tax circles cares about or pays attention to--including, it seems, all too many lawmakers tasked with adopting these agreements into law. But with the US Treasury and the EU competition commissioner trading barbs over the fence about what seems right or fair when it comes to global tax competition and coordination, this assumption might be changing. The consensus built up over decades by OECD nations is under stress as the pressure for coherence in the international tax realm increases. Treasury released these provisions in draft from last fall, expressly in order to influence the OECD's work on BEPS. Now that the provisions are in the model, it remains to be seen how they will play out as BEPS, currently at a mid-cycle of norm making, moves from the articulation of principles to the implementation phase. This article doesn't provide answers or predictions about the future but it examines one aspect of the ongoing contestation and tries to situate it in historical and contemporary terms.

Monday, May 16, 2016

Tax Coop 2016: "Winning the Tax Wars" May 23-24

Tax Coop and the World Bank are hosting a conference on tax competition and cooperation to be held in Washington DC on May 23-24. As last year, I've constructed the debate, which this year will be livestreamed on May 23 at 16:15 EST.  I'll post the link when I have that information. At last year's conference, Dan Mitchell (Cato) and Richard Murphy (TJN) put corporate taxation on trial, debating the continuing viability of this tax in the face of technological innovation and economic globalization. This year's debaters are Alison Holder of ActionAid and Veronique de Rugy of the Mercatus Center at George Mason University.

They will debate the following:


This question will be explored through a series of three resolutions, as follows:
  1. First, be it resolved that: tax competition harms developing countries by reducing their capability to raise fiscal revenue to finance physical and social infrastructure needed for economic growth and social inclusion.
  2. Second, be it resolved that: tax competition increases developing countries’ reliance on foreign aid, making them more vulnerable to aid volatility. 
  3. Third, be it resolved that: tax competition aggravates existing income disparities between developed and developing countries.
Arguing the “affirming side” of each resolution will be Alison Holder of ActionAid. Arguing the “opposing side” of each resolution will be Veronique de Rugy of the Mercatus Center at George Mason University. Evidence from all jurisdictions will be admissible. The emphasis will be on persuasive, clear, and logical argumentation. The debate will proceed in four rounds and will be moderated and judged by Louise Otis of McGill University and Jay Rosengard of Harvard University. Last year's debate was definitely a highlight of the conference and I look forward to hosting Ms. Holder and Ms. DeRugy for this year's event. 

The full conference program features a slate of distinguished speakers from around the world and across public, private, and academic sectors.  Registration is free; additional program and speaker information available here and you can follow @taxCoop on twitter for updates and links. 







Wednesday, May 11, 2016

Citizenship-based Taxation and FATCA

I am occasionally asked for a list of the things I've written or presented about FATCA and citizenship-based taxation, and decided I may as well post it here. I have a newer article on the adoption of the IGA in Canada, will post that soon and add to this list.

On the personal impact of CBT/FATCA:


Providing Legal Analysis of FATCA and the IGAs:
Videos and Podcasts: