"I believe they finally listened to me this time. They dropped the 5% to 1% rate, but it was the "as applied" in legal terms; the way it was written would mean that anyone who was not an American citizen or resident would be subject to the tax due to the language. They would look at that and say, "You are not an American, so therefore, "as applied," it would have applied to anyone, including pension funds, you name
it."