In 2007, PWC finished construction of an uber-modern building in the most expensive city in the world, in the most expensive location in the city, creating an obvious need for a continuous revenue stream. On Sept 2, 2008, J. Richard Dick Harvey joined IRS from PWC Price Waterhouse Cooper . In April 2013, Norway became the sixth country to sign an Intergovernmental Agreement (IGA) on FATCA with USA.
PWC committed to be the first building to be built in the “Barcode Concept” in Björvika district in Central Oslo. There are fewer locations which could be better than this: a few meters from the ultra-modern Oslo opera house. At the edge of the train tracks–spitting distance from the train platforms. The high speed train to the airport is on one of the nearest platforms, uniquely situated at ground level within meters of the PWC door. Nearly all local buses stop at the front door of the train station. The regional buses (connecting throughout Norway, Sweden, and Denmark) are in the next building. Within a kilometer are the docks for the ferries traveling overnight to Denmark and Germany. Oslo’s main tax office is directly opposite on the other side of the tracks. The government buildings are within 800 meters, caddy corner across the train station. For pictures, see these:
http://www.skyscrapercity.com/showthread.php?t=623044 (construction pics of the next buildings built)
http://osu.no/eng/operakvarteret/operakvarteret/ (the area, including a capucino-ish discussion of thus area (the opera block) in Norwegian)
http://www.worldbuildingsdirectory.com/project.cfm?id=594 architectural background
Being accountants, let’s assume that PWC has made the calculation of the amount of revenue needed to be produced per square foot (meter). Besides the considerations of location costs described above, consider that the design is “airy”, meaning that there is square footage where debitable hours cannot sit. Many Norwegian modern companies have a gym in the basement or ground floor. Next, the employees would be newly hired to fill the building. They require training in US accounting methods. The workweek is 37.5 hrs. It is atypical for a Norwegian employee to work overtime, if he did, overtime rules are the norm. All young Norwegians would be calculated.to have 13-14 months of parental leave per couple per child.
European and Norwegian businesses are not known to take risks. Most projects must be sold prior to investments. “Back-to-back is the corpo jingo, meaning that a paying customer must be found first, prior to investing.
This building needs a consistent, high-yield revenue source.
Building finished 2007. Dick leaves PWC for IRS 2008. Dick begets FATCA 2010. Dick begins as a key negotiator for IGAs shortly after.
Where should Dick focus his efforts? On strategic countries where “tax cheats” might hang out. Or in strategic low-tax countries where he might flush out some US-person revenue sources.
And the sixth country that Dick’s dicks find is Norway? Whereas US capital gains & dividends & interest rates are 15%, Norway’s rates are 30%. All banks in Norway require persons to have Norwegian government registration numbers, either as a full time resident or part time resident. You can’t even order internet without a Norwegian identification number. A US homelander, hiding money, would he be looking for a place where he would get a government id number?
What is Norway’s interest? Reciprocity? Indeed, Norway is incredibly hungry for its citizens’ money out in the world, knowing that it has 49% top marginal tax rate, most Norwegians are looking for someplace else. Dick offers them the standard reciprocity bs, “promising equivalent levels of reciprocity” whilst demanding Norway to do this or to do that by which date. Norway ought to be smart enough to have known this was bs.
However, Norway has a strong and intrusive media regarding taxation. Taxpayer’s net assets and income had been available in the gossip newspapers up til 2010, and is still available on any neighbors if requested. Anders Breivik’s mother was reported to have had a US bank account (“offshore”).. If Norway could get some tidbits which could make the Norwegian govt look good in the media, what a great deal it could be! It may be only a couple million dollars versus its bank’s FATCA compliance costs in the billions, but there is incredible political strength in supporting media coverage.
So what does Dick give to Norway? A sensational set of “John Doe” summons of US banks, looking for the names of Norwegians using US credit cards in Norway to have summed a few million. So Dick’s tenders arrange for this DOJ summons. Likely they found some lutefisk importer in Minnesota, and some Norwegian-American Jew leftover from WWII flight selling Norwegian salmon to various US bagel & lox cafe’s. It’s at most a couple million dollars, but such a police action by USA in the interest of finding Norwegian tax cheats–what great stories could be made in the Norwegian media!!
Overall, its a win-win situation for 95% of the participants. USA gets no real legitimate tax revenue, but: Norway gets great media coverage of US summons raids looking for Norwegian tax cheats. Norwegian banks are already the strongest in the world, it won’t hurt the super majors like Nordea & Handelsbanken to dish out $100 million each in compliance costs. Besides, they can just pass it on to their customers. And Dick gets what Dick is after: guaranteed hundreds of millions of compliance invoices to Norwegian banks. The perfect method for funding a new office building with newly hired debiteers.
Well, maybe 5% might be a bunch of US person schmucks, who have committed the USA major crime of not having filled in a form they knew nothing about. But, who cares? They are so far away they hardly vote anyways–and if they do its just washed out amongst the 50 states and overcome by the Homelanders.
So, there you have it! A brand new building! A new brain leader for the IRS! And a guaranteed revenue stream to pay off the building in the most expensive location in the most expensive city in the world!
So, in the interest of finding dirty people in a place where none would ever logically be found, a minority of innocent people are trampled.
So, how about you, seen any new PWC construction in your town near the turn of the decade? Any of Dick’s Hangouts in your town?
You and I know where the dirty people really are located.
And you and I know what’s necessary after performing a dirty deed: A thorough Dick washing.
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