US tax lawyer, blogger and #FATCA researcher inducted into “Hall Of Fame”

So much publicity! So little relevance!

The New York primary was this week. Both Donald Trump and Hilary Clinton extended their leads and moved one step closer to their respective party’s nominations. (Mrs. Clinton with the approval of the Democratic Party and Mr. Trump with the disapproval of the Republican Party.) Interestingly both Mr. Trump and Mrs. Clinton have higher disapproval ratings than approval ratings. Yet each of them appears likely to represent their respective parties in the upcoming Presidential election. One of them will win the election (this is not the same as having been elected). Will the eventual winner make a positive difference in the life of any individual? Doubtful. Watching the political process contributes to a sense of negativity about human nature.

But, wait! The World Is Full Of Good People!

Starting at the age of 7 or 8, I participated in four seasons of organized sports. To be truly effective, organized sports are highly dependent on adult volunteers. I well remember a guy named “Bob D.” Although I thought of him as old, he was probably somewhere between the age of 20 and 25. Anyway, “Bob D” was helping with baseball. “Bob D.” was helping with basketball. “Bob D.” was helping with football. “Bob D.” was always volunteering his time and coaching.  I have a memory of my father noticing “Bob D.” and commenting “There are a lot of good people in this world”. So true.  I don’t believe that “Bob D.” received a lot of recognition or a lot of gratitude. Yet year after year, season after season, week after week, day after day. “Bob D.” showed up. He clearly made a positive difference in the lives of others.

The Unsung Heroes of Life

You will find people like “Bob D.” in every facet of life. They do things for people, just because they want to. They contribute to their communities, just because they want to.  They provide mentorship for people, just because they want to. They put their kids through university because they want to. They are the true “Unsung Heroes of Life”. I once thought of writing a little book about these “Unsung Heroes of Life”.

Although, I can’t do a book. I can offer this “Bedtime Story” …

A “Bed Time” Story …

Instructions to readers (who are likely examples of “Unsung Heroes of Life”):

Please read as a “Good Night” story to an angry person in your life or to an “American abroad” trying to cope with FATCA, FBAR and CBT.

Once upon a time in a “far off land”…

Once upon a time there was a lawyer who lived in  the Middle East. She was a well known lawyer (major blog), with a particular expertise in a topic of relevance, to the only peoples of the world, subjected to a specific type of obligation, based on “place of birth”. The “obligation” is  “Taxation-based citizenship”. You guessed it. She was a U.S. tax lawyer.

But, before jumping to any conclusions (I hate lawyers just as much as the next person), understand that this tax lawyer, was much more than a normal U.S. tax lawyer. Although, she understood what forms to complete, she knew what the forms meant. Although she gave FBAR advice, she also understood how unjust FBAR was. Although she understood how FATCA worked, she knew how unfair FATCA was  to Americans abroad. Although she understood the dangers of non-U.S. tax compliance for Americans abroad, she understood the dangers and difficulties of  U.S. tax compliance for Americans abroad. In short, she truly understood the evil and immorality of “taxation-based citizenship” AKA “place of birth taxation”.

She was Detective Sherlock by day …

By day, she used her research skills to uncover the solutions and to help solve the “Puzzles and Problems” of Taxation-based Citizenship”. She used her “detective skills” to uncover the secrets of the Internal Revenue Code and FBAR. She understood trusts, the U.S. hatred of “all things foreign” and “foreign trusts”. She was highly respected and known as the “Sherlock” of U.S. tax lawyers. If a solution could be found, she was sure to find it.

She was Detective Sherlock by night …

By night she played a different role.  She continued to wear her “Sherlock Hat”. She used her detective skills to solve the most difficult problems in peoples lives. By, night she helped people of all races, creeds, religions and nationalities. Whether subject to “Taxation-based Citizenship” (U.S. citizens) or NOT subject to “Taxation-based Citizenship” (normal people), she helped solve their problems. She believed that all people, regardless of their place birth, should have the rights of equal protection with respect to access to Detective Sherlock. She believed that no person should be denied access to Detective Sherlock except by “due process” of law.

A real and documented story of the life and times of Detective Sherlock …

New York City – April 15 , 2016 – A most serious problem unfolds!

A young boy’s small dog had been lost in the far off land of America. The dog was eventually found,  running loose WITHOUT his IRS TIN (“Tax Identification Number”) micro chip. The dog was off the IRS radar. From the perspective of the U.S. government, the dog (assuming a “U.S. place of birth”) was nothing more than a wealthy tax cheat (probably had not filed his FBARs).

Middle East – April 16, 2016

Real Time: The Detective Sherlock files …

After spending a day of solving CFC and PFIC problems for a middle Eastern family subject to U.S. extra-territorial abuse (one of the children was accidentally born in the USA), Detective Sherlock prepared for a quiet evening. Suddenly her solitude and relaxing moment was interrupted by  an URGENT message and video from America!

The message was that a “stray dog” had been found. A video of the dog accompanied the message. It was clear that the dog had been separated from its owner. The dog was in distress. Without a TIN it was impossible to determine who the dog was. (Maybe the dog was even an illegal immigrant!) Without a TIN, the dog did not exist. The dog was under close watch and supervision in a “safe house” far away from the eyes of the U.S. Government!

Detective Sherlock’s mission, should she accept it, was to discover:

1.     Without a TIN number, who could the dog possibly be?

2.     Who was the owner?

3.     How to unite the dog with the owner?

Real Time: Detective Sherlock sprung into action …

She began sleuthing the internet using the term:

“Lost dog in Brooklyn possibly NOT tax compliant”

The results included a Facebook page devoted to identifying animals that had been running loose without their TIN number. Amazingly, a possibly “non-compliant  dog of interest” was located. The picture of this dog was a 98% match with the Dog in the video.

Real Time: New York City – April 17, 2016 …

The possible owner of the “non-compliant dog of interest” received a text message from Detective Sherlock in the Middle East.

The message said:

“Non-compliant dog” found – presently in “safe house” – away from IRS in Brooklyn. To confirm “match” please reply with dog’s name.

Real Time: Middle East – April 17, 2016

Detective Sherlock received the following reply text from the possible owner:

“Non compliant dog responds to name of Phoebe – please do NOT notify IRS – FBAR penalties feared!”

Detective Sherlock replied to the possible owner with the following text:

“Not to worry – your secret is protected by lawyer client privilege – will notify New York “Safe House” of name “Phoebe”.

Real Time: New York City April 17, 2016

“Safe House” in New York received message from Detective Sherlock saying “non-compliant dog” responds to name “Phoebe”.

“Safe House” people address mystery dog by name of Phoebe. Safe House representative calls out to Dog, addressing Dog by the name “Phoebe”. Dog responds positively with noticeable relaxation. Name of Phoebe positively associated with dog.

And then …

Representative of “safe house”, locates suspected owner and  returns Phoebe to that  owner. Owner noticeably relieved and and grateful.

Real Time: New York City April 18, 2016

Young boy gets Phoebe a TIN. Believes the TIN is the best protection a dog could have from every becoming permanently lost. Takes first step to bring Phoebe into U.S. tax compliance and files 6 years of back FBARS for Phoebe. Hires high priced New York City Criminal lawyer to write “reasonable cause” letter for Phoebe.

Real Time: Middle East April 18, 2016

After reuniting Phoebe with owner, Middle East Tax Lawyer, reviews “reasonable cause” letter for Phoebe written by NYC criminal lawyer. Approves “reasonable cause” letter with few changes. Notes Phoebe unaware that FBAR required, if aggregate of “offshore dog accounts” exceed $10,000. Notes also that Phobe was not owned by a lawyer and therefore Phoebe had no reason to know of FBAR law.

FBAR penalty NOT imposed. Phoebe receives “warning letter” from IRS.

The moral of the story? Happy endings?

The young boy gets his dog Phoebe back. Phoebe gets a TIN number. The IRS gets its FBARs. Middle East Tax lawyer receives “official recognition” for being a true “Unsung Hero of Life!”

Yes, it’s all true!

Congratulations to Detective (and U.S. tax lawyer) Virginia La Torre Jeker for her role in The Great Facebook Dog Recovery and on the occasion of her induction into the “Unsung Heroes of Life” Hall of Fame).  Whether interpreting the Internal Revenue Code or reuniting lost dogs with their owners, she is a true “Unsung Hero of Life!” The young boy (Phoebe’s owner) will NOT remember Donald Trump or Hilary Clinton. He will NEVER forget the efforts and kindness of Virginia La Torre Jeker!

Virginia Holmes

In conclusion …

If you would like to nominate somebody for induction into the “Unsung Heroes Of LIfe Hall of Fame“, please contact me.

John Richardson