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https://www.taxconnections.com/taxblog/us-tax-laws-pushing-americans-to-expatriate-ovdi-arbitrary-and-capricious-an-interview-with-bill-yates-former-attorney-office-of-associate-chief-counsel-international/
US Tax Laws Pushing Americans to Expatriate; OVDI “Arbitrary and Capricious” – An Interview With Bill Yates - Former Attorney, Office of Associate Chief Counsel (International), IRS