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Joseph Zernik, PhD PO Box 31440, Jerusalem 91313, Israel; josephzernik@humanrightsalertngo.org ;

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13-01-06 FATCA - United States Foreign Account Tax Compliance Act (2011) - Israel and other nations' responses - compilation of media reports
Bank of Israel's Stanley Fischer is unparalleled in his unconditional submission to the United States FACTA. Review of Israeli media reports indicates that under his tenure, Bank of Israel was determined, even prior to the final enactment of FATCA, that the matter was "not under its purview", and that Bank of Israel refused to issue Banking Regulations of the State of Israel in this matter, even after being pressed to do so by Israeli banks. Petition, previously filed with the Israeli High Court of Justice claimed that Fischer exchanged his loyalty to the State of Israel and its law with loyalty to another nation and its law, and/or loyalty to financial institutions and their interests. Eventually, the territory of "FACTA-compliance" is likely to coincide with the territory of the financial crisis, through corruption of banking regulation of other nations, under United States coercion. # 1 2 3 4 5 6 7 8 9 10 11 12 Record 1 13-01-06 Foreign Account Tax Compliance Act - Wikipedia 10-03-09 Ahren R., Israeli banks urge America clients to close Israeli accounts _ Haaretz 11-12-16 IRS Exempts Many Expats From FATCA - Forbes _ parts 1, 2 12-03-29 Leumi orders American clients_Haaretz 12-04-10 Bank of Israel wants to negotiate tax deal_Haaretz 12-04-12 Israel considering FATCA deal_International Advisor 12-04-12 Israel may seek special treatment on FATCA_StepJournal 12-04-27 IRS ramps up audits of taxpayers in Israel_Haaretz 12-08-10 Government tackling new US tax rules_Haaretz 12-11-28 China central bank slams US tax dodging law_ Reuters 12-12-12 Israel seeks tax pact with US on FATCA Globes 13-01-05 FATCA _ Scoop.it Page #

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LINKS:
[1] 13-01-04 FATCA-related Consumer Complaint No 2 against Bank HaPoalim, BM, and its Chief Internal Auditor Jacob Orbach, filed with Bank of Israel-Banking Regulation http://www.scribd.com/doc/118926904/ [2] 12-08-25 Dr Zernik's complaint, filed with Israeli banking regulation against Bank HaPoalim - for attempting to extort compliance with US IRS regulations in Jerusalem http://es.scribd.com/doc/103922991/ [3] 13-01-03 Letter to Stanley Fischer, Bank of Israel Governor RE- request for immediate production of records re FATCA-related complaint against Bank HaPoalim, BM http://www.scribd.com/doc/118792468/ [4] 12-10-23 PRESS RELEASE Petition alleges Bank of Israel Fischer patronizes criminality at Bank HaPoalim, BM http://www.scribd.com/doc/110868267/

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Foreign Account Tax Compliance Act

Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act (FATCA), Subtitle A of Title V of the Hiring Incentives to Restore Employment Act (HIRE), enacts Chapter 4 of, and makes other modifications to, the Internal Revenue Code in the United States. FATCA has three main parts: 1. It requires foreign banks to find any American account holders and disclose their balances, receipts, and withdrawals to the US Internal Revenue Service (IRS), or be subject to a 30% withholding tax on income from US financial assets held by the banks.[1][2] 2. Owners of these foreign-held assets must report them on a new Form 8938 along with US tax returns if they are worth more than US$50,000; a higher reporting threshold applies to overseas residents.[3] Account holders would be subject to a 40% penalty on understatements of income in an undisclosed foreign financial asset.[1] 3. It closes a tax loophole that investors had used to avoid paying any taxes on dividends by converting them into dividend equivalents.[4] The reporting requirements are in addition to reporting of foreign financial assets to the US Treasury Department,[5] particularly the "Report of Foreign Bank and Financial Accounts" (FBAR) for foreign financial accounts exceeding US$10,000 required under Bank Secrecy Act regulations issued by the Financial Crimes Enforcement Network (FinCEN).[6]

Controversy
FATCA has raised fears of imposition of capital controls and assertions that capital flight is underway as a result.[7][8][9] There have also been privacy concerns, in particular for those with dual citizenship.[10] Many have also expressed doubts as to the implementability of this legislation.[11] As a result of FATCA, European banks such as Deutsche Bank, Commerzbank, HSBC, ING Group and Credit Suisse have been closing brokerage accounts for all US customers since early 2011, citing "onerous" US regulations, which FATCA will make more complex when it goes into effect in 2013.[12][13] However, in late 2011 the IRS stated that FATCA would be made simpler for many expatriates.[14] American Citizens Abroad (ACA), a Geneva-based organization representing the interests of six million Americans residing outside the U.S., has launched a campaign to repeal FATCA.[15] The ACA claims that "FATCA legislation is predicated on the faulty assumption that foreigners throughout the world with no predisposition to favor the U.S. will react positively to its attempts to convert them into unpaid IRS agents."[16] The Association of Certified Financial Crime Specialists (ACFCS) claims FATCA is expected to raise revenues of approximately US$800 million per year for the US Treasury; however, the costs of implementation are more difficult to estimate, and estimates between hundreds of millions and over US$10 billion have been published.[17] ACFCS also claims it is extremely likely that the cost of implementing FATCA (which will be borne by the foreign financial institutions) will far outweigh the revenues raised by the US Treasury, even excluding the additional costs to the US Internal Revenue Service for the staffing and resources needed to process the data produced.[17] Rep. Carolyn Maloney, D-N.Y., has introduced a bill aimed to protect American ex-pats who have no representation in this matter, since they cannot participate in congressional or state elections. [18] Canada's Finance Minister Jim Flaherty has raised an issue with this "far reaching and extraterritorial implications" which would require Canadian banks to become extensions of the IRS and would jeopardize Canadians privacy rights. A petition against Governor of the Bank of Israel, Stanley Fischer, filed in October 2012 with the High Court of Justice, alleged that Fischer's failure to stop Israeli banks from acting on FATCA against Israeli customers, amounted to "replacement of his loyalty to the State of Israel and its laws, with loyalty to another nation and its laws

Foreign Account Tax Compliance Act and/or financial institutions and their interests."[19]

Implementation
FATCA added Internal Revenue Code 6038D (26 U.S.C.6038D [20]) which requires reporting any interest in assets over $50,000 after 18 March 2010, and 1298(f) (26 U.S.C.1298(f) [21]), requiring shareholders of a passive foreign investment company (PFIC) to report certain information. The IRS issued temporary regulations (TD 9567) on 14 December 2011 requiring the filing of Form 8938 with individual income tax returns,[22] and proposed regulations (REG-130302-10) for domestic entities.[23] Treasury and the IRS issued proposed regulations (REG-121647-10) regarding information reporting by foreign financial institutions on 8 February 2012,[24][25] and issued final regulations and guidance (TD 9584) on reporting interest paid to nonresident aliens on 17 April 2012.[26] The Form 8938 filing requirement is in addition to Form TD-F 90-22.1 "Report of Foreign Bank and Financial Accounts" (FBAR).[5][27] France, Germany, Italy, Spain, and the United Kingdom have consented to cooperate with the U.S. on FATCA implementation,[28][29] as have Switzerland and Japan.[30] The deputy director general of legal affairs of the People's Bank of China, the central bank of the People's Republic of China, Liu Xiangmin said "China's banking and tax laws and regulations do not allow Chinese financial institutions to comply with FATCA directly."[31]

References
[1] Bell, Kay (23 March 2010). "Jobs bill includes tax changes" (http:/ / money. msn. com/ tax-tips/ post. aspx?post=00000065-0000-0000-a34f-1a0000000000& _blg=18). MSNBC. . [2] Smith, Lisa. "FATCA Foreign Account Tax Compliance Act" (http:/ / www. iexpats. com/ fatca/ ). iExpats.com. . Retrieved 13 September 2012. [3] Internal Revenue Service (25 January 2012). "Do I need to file Form 8938, 'Statement of Specified Foreign Financial Assets'?" (http:/ / www. irs. gov/ businesses/ corporations/ article/ 0,,id=251217,00. html). . [4] Morgenson, Gretchen (26 March 2010). "Death of a Loophole, and Swiss Banks Will Mourn" (http:/ / www. nytimes. com/ 2010/ 03/ 28/ business/ 28gret. html). The New York Times. . [5] Jolly, David; Knowlton, Brian (26 December 2011). "Law to Find Tax Evaders Denounced" (http:/ / www. nytimes. com/ 2011/ 12/ 27/ business/ law-to-find-tax-evaders-denounced. html). The New York Times. . [6] 31 C.F.R. 1010 (http:/ / www. law. cornell. edu/ cfr/ text/ 31/ 1010) (76 F.R. 10234 (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ getpage. cgi?dbname=2011_register& position=all& page=10234) of 24 February 2011). [7] Rahn, Richard W. (7 November 2011). "Joining the chorus for tax cooperation" (http:/ / www. washingtontimes. com/ news/ 2011/ nov/ 7/ joining-the-chorus-for-tax-cooperation/ ). The Washington Times. . [8] Dunn, Peter W. (28 November 2011). "FATCA: A Ticking Time Bomb for the Economy" (http:/ / www. americanthinker. com/ 2011/ 11/ fatca_a_ticking_time_bomb_for_the_economy. html). American Thinker. . [9] "Scratched by the FATCA" (http:/ / www. economist. com/ node/ 21540270). The Economist. 26 November 2011. . Retrieved 2012-07-16. "Another approach would involve some global funds avoiding American assets entirely. That can hardly be what Congress had in mind." [10] "Canadian Finance Minister Flaherty criticizes U.S. crackdown on tax evasion" (http:/ / www. cbc. ca/ news/ canada/ new-brunswick/ story/ 2011/ 09/ 20/ nb-flaherty-tax-evasion-law-1002. html). CBC News. 20 September 2011. . [11] "American tax law: Scratched by the FATCA: Congress creates a bureaucratic nightmare for fund managers" (http:/ / www. economist. com/ node/ 21540270). The Economist. 26 November 2011. . [12] "European Banks Stop Serving American Customers" (http:/ / www. spiegel. de/ international/ business/ 0,1518,803742,00. html). Der Spiegel. 14 December 2011. . [13] "German banks abandon US customers" (http:/ / www. thelocal. de/ money/ 20111215-39519. html). The Local. 15 December 2011. . [14] Wood, Robert W. (16 December 2012). "IRS Exempts Many Expats From FATCA" (http:/ / www. forbes. com/ sites/ robertwood/ 2011/ 12/ 16/ irs-exempts-many-expats-from-facta/ ). Forbes. . Retrieved 13 September 2012. [15] Bugnion, Jackie (4 October 2011). "Why FATCA is bad for the United States and should be repealed. Speech presented at the International Withholding Tax Summit 2011, London" (http:/ / www. aca. ch/ fatcabad. pdf). American Citizens Abroad. . [16] "Why FATCA is Bad for America and Why it Should be Repealed Now!" (http:/ / www. aca. ch/ joomla/ index. php?option=com_content& task=view& id=457& Itemid=95#sdendnote6anc). American Citizens Abroad. 2011-12-20. . [17] "FATCA may identify tax cheats, but its dragnet for financial criminals may produce an even bigger yield" (http:/ / acfcs. org/ fatca-may-identify-tax-cheats-but-its-dragnet-for-financial-criminals-may-produce-an-even-bigger-yield/ ). Association of Certified Financial Crime Specialists. . Retrieved 2012-05-011.

Foreign Account Tax Compliance Act

[18] Hinchberger, Bill (27 September 2012). "European banks shut Americans out over U.S. tax rules" (http:/ / www. usatoday. com/ money/ business/ story/ 2012/ 09/ 27/ european-banks-oust-americans/ 57849014/ 1). USA Today. . [19] "Joseph Zernik v Stanley Fischer (7650/12) Petition in the High Court of Justice of the State of Israel" (http:/ / www. scribd. com/ doc/ 110868553/ ). 23 October 2012. . [20] http:/ / www. law. cornell. edu/ uscode/ 26/ 6038D. html [21] http:/ / www. law. cornell. edu/ uscode/ 26/ 1298(f). html [22] 26 C.F.R. 1.6038D-1T (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ get-cfr. cgi?TYPE=TEXT& YEAR=current& TITLE=26& PART=1& SECTION=6038D-1T) through -8T excluding -5T (76 F.R. 78553 (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ getpage. cgi?dbname=2011_register& position=all& page=78553) of 19 December 2011) [23] 26 C.F.R. 1.6038D-5T (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ get-cfr. cgi?TYPE=TEXT& YEAR=current& TITLE=26& PART=1& SECTION=6038D-5T) (76 F.R. 78594 (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ getpage. cgi?dbname=2011_register& position=all& page=78594) of 19 December 2011) [24] Internal Revenue Service (8 February 2012). "Treasury, IRS Issue Proposed Regulations for FATCA Implementation" (http:/ / www. irs. gov/ newsroom/ article/ 0,,id=254068,00. html). . [25] 77 F.R. 9022 (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ getpage. cgi?dbname=2012_register& position=all& page=9022) of 15 February 2012 [26] 77 F.R. 23391 (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ getpage. cgi?dbname=2012_register& position=all& page=23391) of 19 April 2012 [27] 31 C.F.R. 1010.350 (http:/ / frwebgate. access. gpo. gov/ cgi-bin/ get-cfr. cgi?TYPE=TEXT& YEAR=current& TITLE=31& PART=1010& SECTION=350) [28] U.S. Treasury Department (8 February 2012). "JOINT STATEMENT FROM THE UNITED STATES, FRANCE, GERMANY, ITALY, SPAIN AND THE UNITED KINGDOM REGARDING AN INTERGOVERNMENTAL APPROACH TO IMPROVING INTERNATIONAL TAX COMPLIANCE AND IMPLEMENTING FATCA" (http:/ / www. treasury. gov/ press-center/ press-releases/ Documents/ 020712 Treasury IRS FATCA Joint Statement. pdf). . [29] Coder, Jeremiah (28 June 2012). "News Analysis: U.K. Hoping U.S. Will Make FATCA Easier to Swallow". Tax Notes Today. [30] Cohn, Michael (21 June 2012). "U.S. Strikes FATCA Deals with Switzerland and Japan" (http:/ / www. accountingtoday. com/ news/ fatca-switzerland-japan-treasury-63091-1. html). Accounting Today. . [31] Flaherty, Michael (28 November 2012). "China central bank official slams U.S. tax dodging law" (http:/ / www. reuters. com/ article/ 2012/ 11/ 28/ us-asia-regulation-china-idUSBRE8AR0N720121128). Hong Kong: Reuters. .

External links
FATCA Information (http://www.irs.gov/businesses/corporations/article/0,,id=236667,00.html) from the US Internal Revenue Service FSI Tax Posts (http://www.fsitaxposts.com/) U.S. Treasury FATCA Resource Center (http://www.treasury.gov/resource-center/tax-policy/treaties/Pages/ FATCA.aspx)

Article Sources and Contributors

Article Sources and Contributors

Foreign Account Tax Compliance Act Source: http://en.wikipedia.org/w/index.php?oldid=531223599 Contributors: Admconv, BullRangifer, Download, Geraldshields11, Handbling, InproperinLA, Int21h, Kaneandhicks, Kuru, Legis, Mauls, Mild Bill Hiccup, N2e, Ottawahitech, Pne, Quant18, Rjwilmsi, Seniorexpat, Tabletop, Vegaswikian, 12 anonymous edits

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Israeli banks urge America clients to close Israeli accounts

Israel banks aiming to avoid conflict with Washington in wake of new U.S. banking regulations.
By Raphael Ahren | Mar.09, 2010 | 2:29 AM
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Obedient to intensifying U.S. government pressure to crack down on offshore tax evaders, in January Israeli banks began ordering clients they identify as "Americans" or "U.S. tax residents" to close investment accounts they hold in Israel. It is apparently an anticipatory measure, ahead of changes in U.S. law. Local banks are apparently responding to changes in American regulations as their legal counsels interpret them. The Bank of Israel hasn't handed down instructions to the banks on the matter, which doesn't fall under its purview. In February, for instance, Bank Mizrahi-Tefahot informed clients that as a "result of current U.S. regulations" it can no longer provide "securities services to U.S. persons," and explained the termination procedure. "You are receiving this letter because you are identified in our records as a customer who may be a U.S. person, within the meaning of the applicable regulations," Mizrahi wrote. The letter said that clients who fall into this category have until April 7 to tell the bank how to dispose of their holdings, adding that the bank will continue to provide "banking and non-securities services, including deposit accounts and CDs as well as foreign currency, checking and credit card services". "If we do not receive your instructions by March 16, 2010, we may liquidate the securities in your account," Mizrahi warned. Local finance professionals agree that the situation is likely will evolve as the Americans develop and implement new banking guidelines, but differ in their assessment of the possible consequences for U.S. citizens living in Israel. "Theoretically, any American who has an account here could be affected by the changes," Aaron Katsman, a Jerusalem-based financial consultant who specializes in English-speaking clients, said. "They won't be able to hold stocks. They could have deposits here, but that's about it." Americans in Israel are left with "with very few options," added Philip Braude, CEO of Beit Shemesh-based financial planning company Anglo Capital Limited. His suggestion: "Take the money back to America. If you're an American you should be investing in America." He agrees that the current situation is murky, with Israeli banks aiming to avoid conflict with U.S. authorities. "The bank aims to comply with legal and regulatory requirements and constantly reviews the services offered to its clients to adapt them to the changing regulatory environment," Bank Hapoalim spokeswoman Ofra Preuss told TheMarker. She declined to elaborate. Bank Leumi spokesman Aviram Cohen said that while he could not discuss the bank's customer relations policies, its business decisions are "based on legal standards." What is not under contention is that American citizens must file annual tax returns with the Internal Revenue Service even if they live abroad, hold dual or multiple citizenships and pay taxes to another country. While the U.S. has not instructed Israeli banks to close accounts held by American nationals, the IRS is widely expected to ask foreign banks to disclose information about U.S. account holders at some point. The IRS "does not comment on pending legislation," agency spokesman Bruce Friedland told TheMarker. He said that U.S. citizens may bank in Israel "so long as they appropriately report the existence of accounts, report the income from the accounts and pay the tax on the income generated from the accounts." Braude, of Anglo Capital Limited, points out that even if the bank is not specifically aware that a particular customer hold U.S. citizenship, that fact would not help them in a court of law. The bank could not argue that it did not know the client was American, he said: Israeli identity cards indicate place of birth, and banks obtain a copy of the document when opening an account. The problems Americans face in Israel are part of the fallout from a tax evasion scandal involving Switzerland's biggest bank, UBS. In 2008 the U.S. accused the Zurich-based bank of helping wealthy Americans to evade taxes. In response, UBS announced it would stop providing crossborder private banking services to American clients. Last month the Swiss bank UBS agreed to pay $780 million to avoid being prosecuted by the American authorities. It also disclosed the names of some account holders. It's perfectly legal for U.S. citizens to own stocks outside the U.S., Jerusalem wealth manager Katsman explained. However, he added, many people open accounts abroad for the express purpose of dodging tax payments. "Since the U.S. is desperate to get any kind of revenue possible, because things are tough there and they're running huge deficits, this is one of their ways: to make American citizens either pay huge fines or repatriate the money back to America." America has a weapon: It could withdraw the licenses of U.S. branches of foreign banks if it suspects collusion in tax evasion. "Israeli banks have branches in the U.S. and they know [the U.S.] would make it very hard for them to operate if they don't give them the same information that UBS gave them," Nir Amikam, head of research at Wareham Investment Bank, told TheMarker. "I don't know if it makes economic sense, I guess it depends on how much money [Americans have in Israeli banks]," he added. "The banks are probably thinking that it's not as much as they themselves are making by having branches in the U.S." Finance professionals estimate that U.S. residents hold several billion dollars in Israeli investment accounts. "The banks here in Israel, and all around the world, just took a business decision: They're not going to deal with Americans having stocks and bonds portfolios here because they don't want to take any risks," an investment advisor in one Israel's leading banks told TheMarker. However, she added, she believes that at present only U.S. residents are directly affected by the banks' decision. Americans living in Israel would not be asked to liquidate their stocks and bonds portfolios, in her opinion. "We definitely think that in the next two or three years, there's going to come a point when America will stop and declare: OK, we're happy now," said Dylan Shub, principal of Tel-Aviv-based Fortress Capital Management. At that point we'll be able to understand exactly what has to happen and what we need to do." Since the American authorities have not yet clarified what guidelines they might implement in the future, it is likely that Israeli banks will take further preemptive measures to avoid any conflicts with the U.S. authorities, several finance professionals agreed.

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IRS FATCA Guidance, Round 3 Oh Canada! Hating FBARs And FATCA Get Ready For More FBAR Rules IRS Relief To Canadian Dual Citizens Dual Citizen Tax Relief From IRS New FBAR Filing Deadline Approaching Please Sir, Can I Have Some More FATCA?
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No one likes FATCA, least of all U.S. persons living abroadsee Expats Call For FATCA Repealand financial institutions that will bear the brunt of the work tooling up to comply with this massive U.S. financial reporting law starting soon. FATCA Carries Fat Price Tag. However, the IRS has just announced it will make FATCA easier for many.

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In IR-2011-117, the IRS revealed it will shortly be releasing a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for 2011. Form 8938 (Statement of SpecifiedThe Economy Recom m ended How Hurricane Sandy Will Affect Foreign Financial Assets) will be filed by taxpayers with specific types and amounts of foreign financial assets or foreign accounts. The IRS stresses that you need to pay attention to these filing requirements. If you dont, the penalties are quite high. Individuals who may have to file Form 8938 are U.S. citizens and residents, nonresidents who elect to file a joint income tax return and certain nonresidents who live in a U.S. territory. We all knew that, but the thresholds were key. We thought the rule would be $50,000 plus, but for certain types of taxpayers only higher numbers will trigger these rules. Form 8938 is required when the total value of specified foreign assets exceeds certain thresholds. For example, a married couple living in the U.S. and filing a joint tax return would not file Form 8938 unless their total specified foreign assets exceed $100,000 on the last day of the tax year or more than $150,000 at any time during the tax year. Living Abroad? The thresholds for taxpayers who reside abroad are higher. A married couple residing abroad and filing a joint return do not need to file
www.forbes.com/sites/robertwood/2011/12/16/irs-exempts-many-expats-from-facta/

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Robert W. Wood
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Robert W. Wood is a prominent tax lawy er with a national practice. A partner with Wood LLP (www.WoodLLP.com), he is admitted to practice law in California, New Y ork, the District of Columbia, Tex as, Montana, Arizona, Washington and Wy oming. He is Certified as a Specialist in Tax ation and Qualified as a Solicitor in England. Named among the best tax lawy ers in America,

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IRS Exempts Many Expats From FATCA - Forbes

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Form 8938 unless the value of their specified foreign assets exceeds $400,000 on the last day of the tax year or exceeds $600,000 at any time during the year. Instructions for Form 8938 explain the thresholds for reporting, what constitutes a specified foreign financial asset, how to determine the total value of relevant assets, what assets are exempted, and what information must be provided. No tax return? No 8938. Form 8938 is not required of individuals who do not have an income tax return filing requirement. Dont Forget FBARs. The new Form 8938 filing requirement does not replace or affect a taxpayers obligation to file an FBAR (Report of Foreign Bank and Financial Accounts). See Got FBARs? But Which One? For more, see Primer For First Time FBAR Filers. Big Penalties! Failing to file a required Form 8938 carries a $10,000 penalty. Whats more, if the IRS notifies you and asks for one, you can get slapped with up to $50,000 for continued failure to file. A 40% penalty on any understatement of tax attributable to non-disclosed assets can also be imposed. Special statute of limitation rules apply to Form 8938, which are also explained in the instructions. Form 8938, the forms instructions, regulations implementing this new foreign asset reporting, and other information to help taxpayers determine if they are required to file Form 8938 can be found on the FATCA page of irs.gov. For more, see:

The author is a Forbes contributor. The opinions expres s ed are thos e of the w riter.

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---------------------------- Original Message ---------------------------Subject: FATCA and the Supreme Court of the State of Israel... From: josephzernik@humanrightsalertngo.org Date: Fri, November 2, 2012 3:45 am To: Raphael dot ahren at haaretz dot co dot il -------------------------------------------------------------------------Raphael Ahren Haaretz Dear Mr Ahren: In reference to your 2010 report "Israeli banks urge America clients to close Israeli accounts", I would be grateful if you could provide the source for you comment: "The Bank of Israel hasn't handed down instructions to the banks on the matter, which doesn't fall under its purview." Was it from a Bank of Israel official? If so, are you at liberty to disclose the source? Needless to say, I firmly believe that the statement is false. And if provided by a Bank of Israel official was also meant to mislead. You may also be interested in the following: 12-10-31 FATCA and the Supreme Court of the State of Israel... http://www.zimbio.com/Stanley+Fischer/articles/mWFHb4uwcL/12+10+31+FATCA+Supreme+Court+State+Israel I live in Jerusalem, and would be happy to provide additional information in case you are interested. Joseph Zernik, PhD Human Rights Alert (NGO)