Overseas Concerns about Senate Bill S.510

I am a United States citizen living outside of the United States, one of 9 million. While I agree that in principle efforts must be made to ensure that the wealthiest residents of the United States pay their fair share of taxes, I am concerned about a number of aspects of Senator Warren’s proposed S.510 “Ultra-Millionaire Tax Act”--not because I am wealthy, but precisely because I am not. There are aspects of the bill that remain extremely ambiguous in terms of how they will be implemented and how they will impact working and middle class Americans like myself, often treated as collateral damage in efforts to tax the rich. My concerns, in order of those that will most harm ordinary Americans first are: The bill expands information reporting, but it is unclear whether this will only apply to people with substantial wealth nearing the $50 million threshold for taxation, or whether this will apply to all Americans. In the case of non-residents, this will likely require additional expensive paperwork at tax season in which even non-wilful errors are treated with statutory maximum $10,000 penalties. This will become a compliance tax on the middle class like FBAR & FATCA 8938 reporting has. Similar to information reporting concerns, two anti-abuse provisions seem to be poorly targeted and will substantially harm non-resident citizens. First among them is the Sec 3b directive to enhance enforcement under FATCA--given that the Treasury has reported poor quality of data received, and given the history of the Treasury only ever applying the maximum $10,000 penalty for innocent errors, we have zero reason to think that this will only target the wealthy. Similarly, the mysterious Sec 3a directive for the treasury to prevent sheltering of assets in foreign corporations poses a risk to small business owners that have already been hit hard by GILTI & the transition tax. The tax code & Treasury make no distinction between a multinational like Amazon and a Kebab shop owned by a non-resident citizen when it comes to CFC rules. The valuation methodology to be used is similarly undefined--will a more punitive or more cumbersome valuation apply to even modest assets owned by an American that lives outside of the US? Further objectionable aspects of the bill include its applicability to nonresident, noncitizen spouses married to US Persons (a truly questionable principle), its applicability to illiquid foreign retirement accounts, and an egregious 40% additional tax on individuals who have been forced to renounce US citizenship either to maintain their place of residence or because staying compliant while living abroad has become impossible. The concept of the bill is interesting, but this is fundamentally flawed legislation that defers an excessive amount of lawmaking to the Treasury, either because the expected rules will be too objectionable for Congress to vote in favor of, or because no one has given it thought. Please do not support this bill.