Author: International Tax Advisor
Key Concepts of Senate Finance Chairman Hatch’s Proposal Re: “Non-Resident U.S. Citizens”
The complete report can be located at the Senate Finance Committee website at Comprehensive Tax Reform for 2015 and Beyond – Senate Republican Staff –
The crucial policy considerations are set out in the report. The key paragraph of the report is reproduced here:
The principle idea is to impose U.S. income taxation on U.S. sources only for U.S. citizens residing overseas. The report leaves many unanswered questions. One of those questions is how to integrate the “expatriation tax rules” into such a concept? There is one sentence addressing this point, which contemplates the “mark to market exit tax” will continue as part of the law, if such a proposal were to become law.
The report does not discuss how the U.S. transfer tax system (U.S. estate, gift and generation skipping transfer taxes) might be reformed. Current law, imposes worldwide U.S. estate, gift and generation skipping transfer taxes on the worldwide assets of a U.S. citizen.
Time will tell if such a proposal gets any political traction in Congress or at the White House.
Will Congress and the President Finally Act in 2015 to Repeal or Modify U.S. Citizenship Based Taxation?
U.S. citizenship based taxation has been the law since its origins from the U.S. civil war. See, The U.S. Civil War is the Origin of U.S. Citizenship Based Taxation on Worldwide Income for Persons Living Outside the U.S. ***Does it still make sense?
Throughout most of the last 100+/- years, there has never bee
n a repeal of U.S. citizenship based taxation. Indeed, it is difficult to locate any legislative proposals from years past (if there were any) that proposed such a modification.
However, it is worth noting the following string of events over the last 18 months, which may indicate U.S. citizenship based tax reform could be possible:
- For the first time, both political parties and the President have identified issues with the current U.S. citizenship based taxation rules which they have proposed to modify;
- Second, there have been a number of serious proposals to modify and repeal U.S. citizenship based taxation. See, the American Citizens Abroad proposal (ACA proposal). See, “Tax Simplification: The Need for Consistent Tax Treatment of All Individuals (Citizens, Lawful Permanent Residents and Non-Citizens Regardless of Immigration Status) Residing Overseas, Including the Repeal of U.S. Citizenship Based Taxation,” by Patrick W. Martin and Professor Reuven Avi-Yonah, among several others;
- Third, a little over a year ago, the Senate Finance Committee, which was then controlled by Democrats identified U.S. citizenship based taxation as an international competitiveness issue. See, Senate Finance Report on International Competitiveness Identifies Possible “Expatriation” Reforms for U.S. Citizens Residing Overseas. Will U.S. citizens who live outside the U.S. find any relief soon?
- Fourth, in December of 2014, the the Senate Finance Committee Republican Staff issued a detailed report dedicating substantial discussion and analysis to “Non-Resident U.S. Citizens”. See pages 282 and 283 of the Comprehensive Tax Reform for 2015 and Beyond – Senate Republican Staff
- Fifth, the President in his Green Book proposal in February 2015, addressed (although in only the most narrow of circumstances), the need for reform of U.S. citizenship based taxation. See, The Proposal by the President to Exempt Certain U.S. Citizens from Worldwide Taxation: – Very Small, Select Group
This is the first time in my career, where both political parties and the President are at least talking about the possibility of tax reform in this area.
There is one key piece of the legislative puzzle missing from the above picture. The House has not weighed in on a proposal to modify substantially or repeal U.S. citizenship based taxation. See, former House Ways and Means Committee Chair Camp’s proposal to modify substantially international tax policy and rules (Making America A More Attractive Place To Hire and Invest: International Tax Reform). These House proposals do not include U.S. citizenship based taxation reform. In addition, I am not aware of any Democrats in the House who are pushing such a reform.
Even if there is approval in both the Senate and with the President (as there has been in other major legislative reform proposal, such as immigration), it is entirely possible the House will block any such U.S. citizenship based tax reform.
What Collection Efforts (if any) will the IRS Undertake to Collect U.S. Income Taxes from the Gain from the Sale of the London Mayor’s House?
What Collection Efforts will the IRS Undertake to Collect U.S. Income Taxes from the Gain from the Sale of the London Mayor’s House?
U.S. citizens and lawful permanent residents (LPRs) residing overseas must always consider what collection efforts the U.S. government might undertake for taxes owing.
I have posed the question regarding the London Mayor, Boris Johnson, since it raises a number of unique issues. First, under the law, the IRS should administer Title 26 the same for high profile, political, non-political, educated and uneducated individuals. In practice, the judgment of a particular Revenue Agent (and his or her manager) often weighs into how a case is pursued; or not pursued.
The fact that Boris Johnson is a public individual, does impose certain limitations on the ability to investigate his particular case. That is largely because of Department of Justice policy. As explained in the last post, only the Tax Division of the Department of Justice can authorize warrants of public officials, which presumably would extend to London Mayor Boris Johnson. See, 6-4.130, Search Warrants.
Previous posts have explained some of the basic legal tools at the disposal of the IRS and the Department of Justice, Tax Division. See an earlier post, U.S. Enforcement/Collection of Taxes Overseas against USCs and LPRs – Legal Limitations and the following excerpt:
1. INFORMATION – The collection of asset and financial information under FATCA has a very “long arm” around the world. Indeed, the image of the Uncle Sam octopus published in the June 28, 2014 article in the The Economist entitled Taxing America’s diaspora: FATCA’s flaws captures well the idea of the reach of FATCA.
2. INFORMATION VS COLLECTION – However, enforcing tax assessments and penalties and collecting against assets located outside the U.S. is a very different legal question, without such a “long arm”; simply because the reach and jurisdiction of U.S. law is necessarily limited and regularly in conflict with local laws of different countries.
To say it another way, Uncle Sam can indeed enforce the collection of financial and asset information under FATCA, due to the economic costs and ramifications to financial institutions and their investors if they did not comply with the automatic information exchange. However, Uncle Same cannot simply enforce the collection of U.S. taxes and penalties through the worldwide financial institutional network, the same way it can in the U.S.
The U.S. has broad lien, levy and seizure powers under U.S. tax law. The IRS can simply seize assets from U.S. bank accounts without going to a judge or court for final (or jeopardy) tax assessments provided they comply with various provisions of the law. This is not a typical concept in the law for other creditors (other than the IRS) who must generally first take steps through the courts to get some type of judicial action (e.g., a court order) before simply seizing and taking assets from an individual.
The IRS’s broad lien and levy powers against assets, however, has significant limitations overseas. See the 1998 Treasury Report – Sometimes Old is as Good as New – 1998 Treasury Department Report on Citizens and LPRs, I hav
e worked with IRS Revenue Officers who specialize in international collection matters who argue and assert they can merely exercise this lien and levy power overseas against foreign financial institutions. However, this is where the power of the IRS comes to a screeching halt (or at least a major slowdown); when the collection of overseas assets is at stake.
The IRS is not without remedies to collect foreign assets, but it is not a simple process; if it can be done at all in any particular circumstance.
Finally, it is worth noting that a powerful tool at the disposal of the IRS (working in conjunction with the Department of Homeland Security) is the TECs database, which tracks the movement of individuals, specifically including U.S. citizens, who are necessarily U.S. taxpayers. See a prior related post: “Neither Confirm nor Deny the Existence of the TECs data”: IRS Using the TECs Database to Track Taxpayers Movements –
Time will tell, how this tool is used in practice against U.S. citizens residing overseas; particularly those with accounts in various banks that have been the highlight of U.S. international tax evasion investigations, such as UBS, Credit Suisse and HSBC (see, The Guardian, US government faces pressure after biggest leak in banking history).
WSJ (18 Feb. 2015): London Mayor Boris Johnson to Renounce U.S. Citizenship After Tussle With Uncle Sam
Ironically, the outspoken London Mayor has decided to renounce his U.S. citizenship, according to an article published by the Wall Street Journal.
See, WSJ: (18 Feb. 2015) – London Mayor Boris Johnson to Renounce U.S. Citizenship After Tussle With Uncle Sam
This article reported that his U.S. tax bill was at issue – :
In case you missed it: London Mayor Boris Johnson has said he will renounce his U.S. citizenship following a high-decibel tax squabble with his country of birth. At issue: a tax bill U.S. tax authorities claimed he owed on some London property. The mayor will (of course) keep his citizenship in the U.K. as his political ambitions continue to play out.
A previous post in November 2014 discussed a news report of the London Mayor and his U.S. citizenship and hence U.S. tax residency status. See, According to news press, London Mayor, dual citizen, refuses to pay United States income taxes
Surely, he will be careful and thoughtful about the steps he is taking as part of his U.S. citizenship renunciation. His reported response to the news reporter last year could prove risky under U.S. law, to the extent he intentionally refuses to file U.S. income tax returns and pay taxes. The following line of questions and answers could be quite damning for him:
Presenter Susan Page then pressed him whether he would pay the bill, to which he said: “I think it’s outrageous.
“Well, I’m – no is the answer. Why should I? I haven’t lived in the United States for, you know, well, since I was five years old.
“I could but I pay – I pay the lion’s share of my tax, I pay my taxes to the full in the United Kingdom where I live and work.”
Here, the London Mayor has indicated he is not filing tax returns, yet knows he has a legal duty to file them and pay a tax owing under U.S. law. He goes further to say “I could . . . pay . . .” While rarely used standing alone by prosecutors (without other criminal claims brought), it is a crime that carries up to a 12 month prison sentence, to not file a U.S. return, supply information or pay tax; see, IRC § 7203. The relevant language of the statute is as follows:
Any person required under this title to pay any estimated tax or tax, or required by this title or by regulations made under authority thereof to make a return, keep any records, or supply any information, who willfully fails to pay such estimated tax or tax, make such return, keep such records, or supply such information, at the time or times required by law or regulations, shall, in addition to other penalties provided by law, be guilty of a misdemeanor and, upon conviction thereof, shall be fined not more than $25,000 ($100,000 in the case of a corporation), or imprisoned not more than 1 year, or both, together with the costs of prosecution.
Here, the government has yet another stick it can pull from its bag of sticks to be used against current and former U.S. citizens residing outside the U.S. It is of course, very common, that individuals who have spent most of their lives outside the U.S. have not filed any U.S. tax returns nor paid any U.S. income taxes. At what point, might these individuals have U.S. civil tax liability and what facts are necessary to give rise to criminal tax liability?
The vast majority of U.S. citizens residing overseas owe little to no U.S. income taxes because (i) modest income amounts and the impact of the “foreign earned income exclusion” or (ii) they reside in a country with higher taxes and tax rates than the U.S. because of the “foreign tax credit”. See, USCs and LPRs Living Outside the U.S. – Key Tax and BSA Forms
A couple observations about London Mayor Boris Johnson. First, he would be well advised not to make public statements about filing [or not] U.S. tax returns or paying [or not] U.S. taxes. Second, he will want to carefully consider completing and filing accurate U.S. tax returns as part of his formal renunciation process; particularly for the year in which he sold his London home tax free under UK laws. Third, he will want to understand carefully, the details of what is and should be filed on IRS Form 8854, after he has visited the U.S. embassy and files his Form DS-4080, Oath of Renunciation of the Nationality of the United States.
Finally, the case could present a unique international political and public relations nightmare for the U.S. Department of Justice, if they decided to bring any sort of criminal tax charges against the London Mayor. It would seem highly unlikely in my opinion.
The government has a strict requirement that prohibits a United States Attorney (e.g., the high profile Preet Bharara, U.S. Attorney for the Southern District of N.Y. Attorney ) from unilaterally bringing tax charges against individuals. See, 6-4.200, Tax Division Jurisdiction and Procedures, which provides in relevant part:
“. . . The Assistant Attorney General, Tax Division . . . must approve any and all criminal charges that a United States Attorney intends to bring against a defendant in connection with conduct arising under the internal revenue laws, regardless of which criminal statute(s) the United States Attorney proposes to use in charging the defendant. See 28 C.F.R. § 0.70.
Also, only the Tax Division can authorize warrants of public officials, which presumably would extend to London Mayor Boris Johnson. See, See, 6-4.130, Search Warrants.
On a related post, see, How many former U.S. citizens and long-term lawful permanent residents have filed (or will file) IRS Form 8854? and Revisiting the consequences of becoming a “covered expatriate” for failing to comply with Section 877(a)(2)(C).
U.S. Tax and Expatriation Tax Laws – They Are What They Are . . .
The point of this post is a fairly simple one. The law is complex, it has evolved significantly over the years and continues to evolve; if for no other reason how the IRS enforces it. Some people might not like the law.
As those who have read and followed Tax-Expatriation.com know; it is not a place to seek legal advice. It provides lots of information – a comprehensive source of information. See, limitations. It also does not attempt to contemplate every scenario when a particular point is made; e.g., as the IRS modifies how they interpret rules or how they enforce them.
For instance, for a fairly comprehensive article about how the law works, see Accidental Americans” – Rush to Renounce U.S. Citizenship to Avoid the Ugly U.S. Tax Web” International Tax Journal,CCH Wolters Kluwer, Nov./Dec. 2012, Vol. 38 Issue 6. The net worth threshold (US$2M) and income tax thresholds (US$124,000, indexed for inflation) are spelled out in that article. It does not have the indexed inflation amounts. See, The “Average Annual Net Income Tax” Amounts for “Covered Expatriate Status” – Increases to US$160,000 for the Year 2015
Every individual who renounces their U.S. citizenship is taking, in what is my view, a very important decision. Many individuals do not like U.S. tax laws; nor the expatriation tax laws. Many individuals around the world do not like their home country tax laws; nor other laws.
This blog is not intended to be a policy blog debating whether the U.S. tax laws are good laws or bad laws. It’s designed to provide information about the law and important developments and relevant information.
Finally, the “blogosphere” is full of people who attempt to write about the law as if they understand it; particularly the complexity of Title 26, the regulations and a host of case law that spans almost 100 years. These opinions are a dime a dozen. Many get it terribly wrong – particularly in this politically charged topic – and will make statements and provide information that sounds attractive to the uninformed. The following is the type of decision that is made every day.
Path 1: If someone tells USC, Mr. X (or if he reads) the following, he might find it quite attractive: “You will have no U.S. tax liabilities if you simply do “steps Y and Z.” Plus, the U.S. federal government will never know and/or they will never be able to collect the taxes from you anyhow. Simple. Would you rather pay $0 or a bunch of money to the U.S. federal government?”
Path 2: On the other hand, if a qualified legal adviser accurately advises USC, Mr. X of the following, he may not find the answer so attractive: “Sorry, given your factual circumstances, you will have US$ 100,00X of immediate income tax liabilities if you simply do steps “Y and Z.” Plus, by doing so, if you ever bequeath or gift your U.S. citizen children, they will have to pay 40% (under current law) of the value of such inheritance or gift in U.S. taxes. This latter tax obligation will not be your obligation, but rather your U.S. citizen children.”
Not surprisingly, Mr. X may well want to take Path 1, because it is the answer he prefers. If Mr. X does steps “Y and Z”, he will now live with the U.S. legal consequences. He well might not like those legal consequences and think they are unfair, unjust or borderline immoral for any government to impose, but that is how laws often work.
U.S. Tax and Expatriation Tax Laws – They Are What They Are . . .
The President’s Proposal is NOT the Same as Current Law – Section 877A(g)(1)(B)
Some individuals are mistaken that the Obama proposal to exempt certain U.S. citizens from taxation (including the “mark to market” exit tax), is the same as the exception in IRC Section 877A(g)(1)(B).
It’s not. They are not the same, although they have some similar requirements (e.g., 5 years of certification of U.S. tax law compliance under penalty of perjury).
For a brief discussion on the President’s proposal, see –The Proposal by the President to Exempt Certain U.S. Citizens from Worldwide Taxation: – Very Small, Select Group
The Proposal by the President to Exempt Certain U.S. Citizens from Worldwide Taxation: – Very Small, Select Group
A prior post explained the green book proposal published earlier in February: Obama Budget Proposal to “Provide Relief for Accidental Americans”? Will the Proposal to Modify the Expatriation Rules Become Law?
The unique consequence of such a proposal, would be to eliminate U.S. citizenship based taxation for
a very small, select group of U.S. citizens. See, Co-author. “Tax Simplification: The Need for Consistent Tax Treatment of All Individuals (Citizens, Lawful Permanent Residents and Non-Citizens Regardless of Immigration Status) Residing Overseas, Including the Repeal of U.S. Citizenship Based Taxation,” by Patrick W. Martin and Professor Reuven Avi-Yonah, September 2013.
The group affected would indeed be very small. Most importantly, the requirements that would limit the number of eligible persons to a very small class of individuals are the following:
- [those who] have never held a U.S. passport or . . . held a U.S. passport for the sole purpose of departing from the United States in compliance with 22 CFR §53.1,
- [those who] relinquish . . . his or her U.S. citizenship within two years after the later of January 1, 2016, or the date on which the individual learns that he or she is a U.S. citizen.
The immigration law regulations 22 CFR § 53.1 require that a U.S. citizen have a U.S. passport to enter or depart the United States. The relevant part of the regulations is § 53.1(a) which provides as follows:
Passport requirement; definitions.
Assuming an individual was aware of such regulatory rule, they could not qualify for this proposed exception, if they ever lived in the U.S. since becoming 18 1/2 years old. This means that only those individuals with U.S. passports who (i) obtained a U.S. passport as a child (presumably through their parents) while (ii) living in the U.S. and (iii) did so in order to comply with this regulation 22 CFR § 53.1 would be eligible. Since the regulations were just passed in 2006, anyone who obtained a U.S. passport, for instance in 2002 (even if they never lived in the U.S.) would presumably be disqualified from this tax treatment.
Also, if they did not get a passport when they were in the U.S., leaving the country after the 2006 passport regulations were adopted, would have been a violation of the law.
Bottom line, it seems nearly impossible that anyone who ever had a U.S. passport would ever qualify for this exception.
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Part II: U.S. Department of State Communications to USCs overseas Regarding Tax Obligations with IRS
A recent post discussed a rather surprising development of how the – U.S. Department of State, Starts Communicating with U.S. Citizens Overseas Regarding Tax Obligations with the IRS
There are several observations to be made about this approach.
First, some USCs living overseas will find this a welcome development, as it provides a method of 
basic education of how U.S. tax laws work. The newer U.S. passports do have an obscure reference to U.S. tax obligations of USCs. In the past, there was generally no communications from the U.S. Department of State to USCs, including newly naturalized U.S. citizens about their U.S. tax obligations.
Second, there is much helpful information provided in the U.S. Department of State’s explanation. The key tax forms that are most relevant for USCs and LPRs residing overseas are explained in the government e-mail. See, USCs and LPRs Living Outside the U.S. – Key Tax and BSA Forms
All of the following forms are identified by the U.S. Department of State:
- Substantive Income Tax Forms (Affecting Tax Liability)
- Foreign Earned Income Exclusion – IRS Form 2555
- Foreign Tax Credits – IRS Form 1116
- Information Tax Forms (Not Affecting Tax Liability, but with Substantial Penalties for Failure to File)
- IRS Form 8938 Statement of Specified Foreign Financial Assets
- Foreign Bank Account Reports (“FBAR”) – FinCEN Form 114, Report of Foreign Bank and Financial Accounts through the BSA E-Filing System website.
These are the most relevant forms for the majority of USCs and LPRs; although there are numerous other forms and calculations that may be required depending upon the particular circumstances, income, assets, employment, etc. for each individual
The third observation, relates to how employees of the U.S. Department of State will use this information and communicate with USCs? Will they begin asking (even if infrequently) whether a U.S. citizen overseas is in compliance with their U.S. federal tax requirements? What are the consequences to the U.S. citizen if they state yes, no or refuse to answer? What can happen to an individual if they provide a false statement to a federal employee or file a false document? See What could be the focal point of IRS Criminal Investigations of Former U.S. Citizens and Lawful Permanent Residents?
The fourth and last observation, is whether the IRS will begin providing USC taxpayer information on a regular basis to the U.S. Department of State? The law provides limitations upon how the IRS can disclose and provide taxpayer information. See, 26 U.S. Code § 6103 – Confidentiality and disclosure of returns and return information
However, there are significant exceptions in the law, that do allow disclosure of taxpayer financial and taxpayer information to other agencies (particularly “Intelligence Agencies,” which presumably includes the U.S. Department of State). See, for instance, IRC Section 6103(i)(7). The statutory requirements of 6103(i)(7) are not particularly rigid.
Obama Budget Proposal to “Provide Relief for Accidental Americans”? Will the Proposal to Modify the Expatriation Rules Become Law?
[See follow-on post: The Proposal by the President to Exempt Certain U.S. Citizens from Worldwide Taxation: – Very Small, Select Group– published 18 Feb. 2015]
Every year, the President of the United States, releases his proposed budget. The budget is prepared by his team of advisers at the Treasury Department and is known as the “green book“.
For a complete copy of the proposal, that was released on February 2, 2015, see, General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (Released February 2015)
Buried deep into the proposal of the US$3.99 trillion fiscal year 2016 expenditure plan, is a provision to “provide relief for certain accidental dual citizens.” See pages 282 and 283 of the proposal.
It appears someone is listening in the Administration at Treasury; at least a little bit? Will Congress similarly be interested in such proposals? See, Will Congress Intervene to make USC based Tax Laws More User Friendly to USCs and LPRs Residing Outside the U.S.?
The proposal would not adopt residency based taxation for all U.S. citizens, as exists in the rest of the world, but would exclude certain U.S. citizens from the “mark to market” tax on expatriation (i.e., the “exit tax”). See, “Tax Simplification: The Need for Consistent Tax Treatment of All Individuals (Citizens, Lawful Permanent Residents and Non-Citizens Regardless of Immigration Status) Residing Overseas, Including the Repeal of U.S. Citizenship Based Taxation,” by Patrick W. Martin and Professor Reuven Avi-Yonah, 2013.
Those excluded from the exit tax and the tax to their U.S. heirs or beneficiaries who receive gifts or inheritances (See, The “Hidden Tax” of Expatriation – Section 2801 and its “Forever Taint.”) are those individuals who:
- became at birth a citizen of the United States and a citizen of another country,
- at all times, up to and including the individual’s expatriation date, has been a citizen of a country other than the United States,
- has not been a resident of the United States (as defined in section 7701(b)) since attaining age 18½,
- has never held a U.S. passport or has held a U.S. passport for the sole purpose of departing from the United States in compliance with 22 CFR §53.1,
- relinquishes his or her U.S. citizenship within two years after the later of January 1, 2016, or the date on which the individual learns that he or she is a U.S. citizen, and
- certifies under penalty of perjury his or her compliance with all U.S. Federal tax obligations that would have applied during the five years preceding the year of expatriation if the individual had been a nonresident alien during that period.
This would be a significant change from current law. However, the no passport requirement will narrow significantly the number of individuals who may be eligible for this relief; if it becomes law?
Most interesting about the proposal, is that it seems to say these U.S. citizen individuals (who meet all 6 criteria) will not be subject to any U.S. tax as a U.S. citizen. In other words, it seems to say they will be taxed the same as a non-resident alien, which in effect is residency based income taxation for this narrow class of U.S. citizens. The word tax is used generically, to presumably also exclude them from U.S. estate, gift and generation skipping transfer taxes.
The proposal has a window of opportunity that starts to close with time and then shuts in January 1, 2018; i.e., the 2 year period after January 1, 2016. This will mean that those future “Accidental Dual Citizens/Americans” who later learn of their U.S. citizenship, will only have 2 years from the moment they became aware of their U.S. citizenship status. One thing is to know you are a U.S. citizen as you live wherever you may around the world; another is to know and understand the U.S. taxes that are imposed upon you on your worldwide assets.
Laura Saunders of the WSJ: “Record Number Gave Up U.S. Citizenship or Long-Term Residency in 2014”
Record Number Gave Up U.S. Citizenship or Long-Term Residency in 2014: WSJ: By, Laura Saunders (10 Feb. 2015)
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Her most recent article has a number of excellent observations, including the following regarding an academic study of those citizens living abroad:
According to a recent survey of 1,546 U.S. citizens and former citizens living abroad, 31% of participants have actively considered renouncing their U.S. citizenship and 3% are in the process of doing so. Many who were considering the move cited increasingly onerous and intrusive financial reporting requirements. The survey was conducted between Dec. 5 and Jan. 20 by Amanda Klekowski von Koppenfels, a researcher at the University of Kent in the U.K.
For other articles written by Ms. Laura Saunders, on this related subject, see the Media: News & Articles section –
Wall Street Journal: Expats Left Frustrated as Banks Cut Services Abroad Americans Overseas Struggle With Implications of Crackdown on Money Laundering and Tax Evasion, (The Wall Street Journal, 11 Sept 2014) By –Laura Saunders
IRS Eases Up on Accidental Tax Cheats: Agency Lowers Some Offshore-Account Penalties, Raises Others (The Wall Street Journal, June 18, 2014), By – Liam Pleven and Laura Saunders