Man is an animal suspended in webs of significance that he himself has spun...

Friday, September 19, 2014

FATCA Now the Law of the Land in France

For those of you who missed the FATCA debate yesterday in the French parliament, here are the essential links:

The video of the discussion (go to the box on the right side of the screen and scroll down and click on ACCORD FRANCE-ÉTATS-UNIS D’AMÉRIQUE RESPECT OBLIGATIONS FISCALES (LOI FATCA)
The transcription of the debate

I watched it this morning and here are few of my thoughts.

First of all, I was impressed by the high caliber of the discussion. All the individuals who spoke did so clearly and thoughfully.  I heartily wish American politicans could do half as well.

Framing:  I was very interested in seeing how the pro-FATCA camp framed their arguments and addressed certain reservations already put forward in previous debates.

The larger context, of course, is the Good Fight against tax evasion and fraud.  Even Pierre Lellouche (UMP) who spoke against the law admitted:
L’objectif affiché se passe bien sûr de toute discussion. Il s’agit d’œuvrer pour la transparence fiscale et de mettre fin, grâce à la coopération des États et à la transmission automatique des informations, à la fraude fiscale massive que connaît le monde : environ 6 000 milliards de dollars qui échappent à toute imposition.
De ce point de vue, personne ne peut être contre. Comme disent les Américains, personne ne peut être contre la tarte aux pommes et la patrie, apple pie and motherhood ; tout le monde est pour ! (Sourires.) À mort la transparence !
(The objective obviously needs no discussion. It is about fiscal transparency and the end, thanks to cooperation among states and the automatic transmission of information, to widespread tax evasion in the world:  6 000 billions of dollars that escape taxes.
From this point of view, no one could be against it.  As the Americans say, no one can be against apple pie and country, apple pie and motherhood;  Everyone is for! (Smiles).  Death to Transparency!
)
Is FATCA THE Solution to Tax Evasion?  Not one speaker thought that FATCA was perfect, they simply differed as to how bad it was and whether or not these problems were deal-breakers.

Expressions of discontent peppered the debate: "extraterritorial", "unilateral"  and the rather grim indictment, "Americans have a tendency to privilege their interests over international law."  If a better, more multilateral proposition had been on the table, then that would have been preferable.  But it's not a perfect world, said its proponents, and it's better than nothing.  If nothing else it has had the salutory effect of moving other information-sharing initiatives forward (OECD, for example) which means that FATCA is just a step on the way to a true and legitimate worldwide standard.

Reciprocity is a Problem:  I was pleasantly surprised that they were aware of just how fragile the US commitment to reciprocity really is.  US law does not at the moment permit the US government to provide the same level of information to France, but the FATCA proponents did not mention ALL of the potential legal and political problems with FATCA on the US side. Mme Odile Saugues:  
Tout d’abord, il existe une incertitude sur le principe de réciprocité, et notamment sur le solde des comptes et la valeur des actifs. Les États-Unis se sont formellement engagés à transmettre ces informations dès que leur droit interne le leur permettra – ce qui n’est pas le cas à ce jour. Les élus républicains du Congrès – Rand Paul, sénateur du Kentucky, et Bill Posey, représentant de l’État de Floride – bloquent actuellement la transmission de ces données dans le cadre du dispositif... Cette situation risque de durer jusqu’aux élections de mi-mandat aux États-Unis, qui auront lieu le 4 novembre prochain.
(First of all there is uncertainty about the principle of reciprocity and especially about account balances and stock values. The US has formally committed to sending this information as soon as their internal laws allow it. Republican lawmakers in Congress - Rand Paul, Senator from Kentucky, and Bill Posey, representative from the state of Florida - are blocking the transmission of this information in the context of this law... This situation may continue until the mid-term elections which will take place on November 4.)
Interesting. To my knowledge there is no projet de loi on the American side, just a brief paragraph hidden in the Obama budget bill. Furthermore, there are court cases launched (or about to be launched) in the US and Canada which are a real risk to FATCA. The American lawsuit, in particular, should have been mentioned since it calls into question, among other things, the legality of those inter-governmental agreements on the American side - those IGAs that the French government says they were in part responsible for forcing on the US along with other European countries like Germany.  

I would also say that even if the Democrats were to win and take control of the US Congress, Americans banks and financial institutions are important campaign donors to both parties and they will surely have something to say about reciprocity on the US side.

As one speaker put it about those IGAs and American promises: "Cette rédaction alambiquée est, pour qui connaît les institutions américaines, une vaste plaisanterie, qui rappelle le vieux proverbe selon lequel, en politique, les promesses n’engagent que ceux qui les écoutent."  (This convoluted text is, for those who know American institutions, a joke, reminiscent of the old adage in politics, promises only bind those who listen to them.)  Well said.

Impact of FATCA on French Citizens and Residents: Frédéric Lefebvre was the only speaker who addressed the impact of this law on French citizens. He spoke very eloquently in defense of the French abroad, the "Accidental Americans" in France and the 100,000 US citizens who are legal residents of the French Republic. (The full text of his speech is here.) No one will weep for the tax evaders caught in the net, he said, but:  "Il faut cependant prendre garde, je le dis avec gravité, aux effets pervers du dispositif tel qu’il nous est proposé." (You must be careful, and I say this to you with utmost seriousness, of the perverse effects of this law that you are proposing." )

Frédéric Lefebvre's motion to delay the implementation (and the vote) until these matters can be studied further was voted down and the law implementing FATCA in France was approved.

Thursday, September 18, 2014

John Oliver on Scottish Independence

For those of you who are following this story, this John Oliver piece is well worth watching.



FATCA Debate in the French Parliament

Got an email yesterday from a Flophouse reader pointing out that the UMP Quebec 2014 twitter feed recently tweeted two Flophouse posts.  That was unexpected but pleasantly so.  Thank you to whoever manages that feed and I hope that those who follow it will be inspired to action.  As of this morning there are 29 comments about the US renunciation fee raise on the regulation.gov website and it would be good to have many more.  Please be aware that you can leave a comment anonymously.  That's right, you do not have to give them your name or contact information.

As I was reading the feed I noticed a note from Frédéric Lefebvre, the Député des Français d’Amérique du Nord.  If you are a French abroad in North America, he is your representive in the French national parliament.  He has been an excellent advocate for his constituents who are, alas, part of the collateral damage brought about by FATCA.  In June he met with two dual (French/US) citizens to talk directly with them about how this American legislation impacts them in France.

He says that there will be a parliamentary debate TODAY (September 18, 2014 and it's number 4 on the morning agenda) concerning the legislation that is needed to implement FATCA in France.

For those who are interested (and you are many) here is the projet de loi for FATCA that was introduced in July by Laurent Fabius and passed by the French Senate (via an "accelerated procedure").

And here is a report about the FATCA legislation prepared by Ms. Estelle  GRELIER for the Assembly which was presented and discussed by the Commission des affaires étrangères on September 10.

Hopefully the debate will be recorded and if so I will post it here on the Flophouse.

Update:  You can watch the debate en direct this morning here.

Wednesday, September 17, 2014

Tribes and Truth

This delightful Ted video was posted by Andrew over at Multicultural Meanderings.  Hans Rosling is back with his son Ola to explain How Not to Be Ignorant of the World.  A few heuristics for rethinking what we think we know of the world.  To Andrew's short summary of Ola Rosling's points I would add one that I call (for want of a better term) Tribes Never Tell the Truth.

We are social creatures and every human group (family, tribe, clan, class, country, nation, state) we belong to has a story about itself and about the people and places beyond its boundaries and borders. Arjun Appadurai put it quite well when he pointed out that "No modern nation, however benign its political system and however eloquent its public voices may be about the virtues of tolerance, multiculturalism, and inclusion, is free of the idea that its national sovereignty is built on some sort of ethnic genius."

 These stories contain facts mixed with myths to form powerful narratives and we cannot help but evaluate the input we get from the world against the storyline of whatever group we identify with. Even the most indepdendent of thinkers can find himself struggling mightily to incorporate information that challenges what he thinks he already knows about the world.   Those who are quick to recognize this about religion or nationalism should acknowledge that there are quasi-religious narratives lurking under the surface of their "rationality".  As Mircea Eliade said:
"Mythical behaviour can be recognized in the obsession with 'success' that is so characteristic of modern society and that expresses an obscure wish to transcend the limits of the human condition;  in the exodus to Suburbia, in which we can detect the nostalgia for 'primordial perfection';  in the paraphenalia and emotional intensity that characterize what has been called 'the cult of the sacred automobile.'"
These stories are another impediment to seeing the world clearly because challenging them (and finding them wanting) gets us kicked out of a club we desperately wish to belong to.  Most groups (even ones comprised of "free thinkers") do not tolerate even small deviations from the common story.  Is it not true that perceived apostates are treated even more harshly then those who are clearly in the camp of the enemy?  Every group has its own Inquisition, ready to ferret out those who "belong without believing."

So I would add this heuristic to the list - one that was beautifully expressed by the late Christopher Hitchens -  "How do I know that I know this, except that I've always been taught this and never heard anything else? How sure am I of my own views? Don't take refuge in the false security of consensus, and the feeling that whatever you think you're bound to be OK, because you're in the safely moral majority."

Tuesday, September 16, 2014

FATCA/CBT: Acting In Your Own Defense

I put a dollar in a change machine. Nothing changed.

George Carlin

Maybe it's my hippy childhood but I'm a great believer in acting directly in one's own defense.  Delegating upward to organizations is fine unless it means total abdication and sitting on one's shaking hands hoping that someone who is not you will save the day. 

Two opportunities for direct action dropped into my hands yesterday.  Just like that.  Here they are. 

1. Let the US Gov know what you think about the renunciation fee raise:  Do we not all agree that this is horse manure?  422%?  You have got to be kidding me. That's outrageous. Are Americans abroad captive citizens who have to be actively discouraged from turning in their US passports?  And who is going to have trouble paying the 2,350 USD fee?  Well, it sure as hell isn't the 1% (or the 10% for that matter).  

The fee raise is already in effect but the US government will take comments until October 21.  You have three ways to submit yours :

Leave a note here;  
Send them an email: fees@state.gov with the RIN (1400-AD47) in the subject line of the message; 
Send them snail mail: U.S. Department of State, Office of the Comptroller, Bureau of Consular Affairs (CA/C), SA-17 8th Floor, Washington, DC 20522-1707

2.  Send them some FATCA facts and hit them hard:  Democrats Abroad just released the results of a survey they conducted on the impact of FATCA on Americans abroad.  Three documents that you can find here:

FATCA: Affecting Everyday Americans Every Day

Send them to whom?  To everyone you can think of.  A few ideas:  elected lawmakers back in the US, local lawmakers in our host countries, journalists, bloggers, hometown newspapers.  Hell, take your email contact list and send it to your friends and family.  This is a serious bit of research (Dr. Amanda Klekowski von Koppenfels of the Brussels School of International Studies was part of the task force that gathered the data) and it's one of the best responses I've seen so far to the folks in Washington (not to mention the American homeland public) who think that the FATCA collateral damage is just a few rich tax evaders in disguise telling stories and this will all go away by itself if they just ignore the "myths" long enough.

There you have it.  Two things you (and I) can do today.  

And to be crystal clear, I will be doing it for me. Because I don't know how any of this will shake out but I feel better doing something in my own defense   It's not quite anarchist calisthenics, but it is a small step away from behaving like a subservient second-class citizen.

Monday, September 15, 2014

Flophouse American Diaspora Reading List

“Sometimes we feel we straddle two cultures; at other times, that we fall between two stools.”

Salman Rushdie, Imaginary Homelands: Essays and Criticism 1981-1991

Time for an update of the Flophouse American Diaspora Reading List - the best books and articles I've read recently about American people and communities abroad.  New books are in green.  As always, please feel free to add to the list.  

This list has three sections:

I.  Upcoming titles - Books that have not been published yet but that I plan on reading.
II.  General books/articles - the larger view.  Some talk about specific issues (like citizenship), others are studies, portraits or serious research about Americans abroad.  
III. Expat autobiographies:  Accounts of Americans in different countries.  These are not books that tell a potential American migrant how to live in Mexico, however.   These are personal accounts that talk about what happens to American identity when it gets transplanted somewhere else for a year or two or for a lifetime.  

Upcoming Titles:

The Citizenship of Americans Living Abroad: Democracy and Those Who Leave by Katya C. Long.  Expected publication date is December 1, 2014

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General books:

The Other Americans in Paris: Businessmen, Countesses, Wayward Youth, 1880-1941 (2014) by Nancy L. Green. I was really looking forward to this one and it did not disappoint (gave it four stars on Goodreads).  The American community/colony in Paris has always been far more diverse than one might think:  businessmen (and women), lawyers, doctors, dentists as well as students and artists and writers. Green does an excellent job of broadening our perspective about this community which has existed since before the American Revolution.  I highly recommend this book and all of Nancy Green's work.

Civic Myths: A Law-And-Literature Approach to Citizenship (2007) by Brook Thomas.  There is citizenship as the law of the land which defines who is legally "in" (or "out") but there is also the social context around it which influences how we feel about that citizenship.  Thomas shows how the "good citizen" or the "immigrant citizen" were portrayed in popular American literature.  The most interesting for me was his discussion about the very famous essay The Man Without a Country which may still be influencing how Americans feel about expatriation (renouncing or losing US citizenship).

Citizenship Without Consent: Illegal Aliens in the American Polity (1985) by Peter H. Schuck and Rogers Smith.  My review is here.  This is a book that argues against the rather broad application of US jus soli citizenship laws.  I think it reads very differently for an American living outside the US who is aware that these laws have created something that is being referred to now as an "Accidental American." (Many thanks to Allison Christians for loaning the book to me so I could read it. I promise to bring it back next time I am in Montreal.)

What Soldiers Do: Sex and the American GI in World War II France (2013) by Mary Louise Roberts.  I'm ambivalent about this one.  It's so well-researched and has so much information in it that I was in awe as I was reading it.  However, I'm not so sure about the conclusions she drew from that research.  I think I need to read it again before I can give it a fair review.   If you have read it, let me know in the comments section what you thought. 

Migrants or Expatriates?  Americans in Europe by Amanda Klekowski von Koppenfels. This one came in 2014 and is THE book to read right now if you are interested in knowing something concrete about just who those absent Americans (7 million or so of them) are:  socioeconomic status, political affiliations, host country, integration, identity and so much more.  Short Flophouse review here and an interview she gave about the book here.  

The Citizenship Revolution: Politics and the Creation of the American Union, 1774-1804 by Douglas Bradburn.  This came out in 2009 and it examines the development of US citizenship in the post-Revolutionary War period.  Fighting over citizenship in this newly independent state was influenced by what was going on in Europe (the French Revolution), the arrival of yet more immigrants and the naturalization question, and expatriation (how to give up US citizenship).  For the last look no further then the fascinating case of one Gideon Henfield, an American who, when accused of privateering, invoked his "right to expatriate" and informed the court that he was no longer an American, but a Frenchman.  He was acquitted in 1793 and allowed to leave and go about his business. 

Beyond Citizenship: American Identity After Globalization by Peter Spiro (2008).  This one is already on the Flophouse Diaspora and International Migration Reading List but it definitely should go here as well.  What has happened, in his view, to US citizenship in a globalized world?  I am planning on re-reading it with my American abroad eye taking into account what has happened in the world to US citizenship since 2010.

Expatriation, Expatriates, and Expats: The American Transformation of a Concept by Nancy L. Green.  This article (available on-line) was published in 2009 in the The American Historical Review. Great essay about American expatriation in the legal and cultural senses.  How did the right to expatriate (the right to leave) go from a mechanism for "nation-building" to one of excluding Americans from the nation?

Americans Abroad: A Comparative Study of Emigrants from the United States by A. Dashefsky et al.
Published in 1992 this is a study of Americans migrants in Australia and Israel (Canada is briefly mentioned as well).  It asks provocative questions about motives for leaving, adaptation in these countries, and why the migrants stayed, returned to the US, or decided to move on to a third country.  In the final chapter are some interesting conclusions and proposals for policies around this emigration one of which is: "Deter efforts to force migrants to change citizenship or otherwise make a permanent, formal commitment to one society or another."

Published in 2007, a very interesting book that re-examines the "American Dream" in the light of American emigration.  Talks about Americans in Canada, Israel, Australia and New Zealand.  It's one of the few I've found that includes African-American emigration and women migrants.  Some good statistics (or at least estimates) at the end of the book.

The Unknown Ambassadors: A Saga of Citizenship by Phyllis Michaux.
Published in 1996, this is the story of how Americans abroad organized around issues of particular importance to Americans living outside the US:  citizenship for the children of Americans who were born abroad, voting rights, and many other issues like Medicare from the 1970's to the 1990's.  This is the diaspora going to the homeland government for recognition as a distinct group with particular interests.  It's a battle that is still ongoing but this book is important because it's the only one I know of that gives the the history and the context behind today's efforts.

"Gilded Prostitution": Status, Money, And Transatlantic Marriages, 1870-1914 by Maureen E. Montgomery.   The title is a bit off-putting but if you are an American woman married to a foreign national this is a good one.  The marriages examined here are between elites (U.S. and U.K.) over a century ago and yet some of the negative (and positive) attitudes about women who marry foreigners and leave America are all too familiar.  Under it all, of course, were questions of citizenship (should women lose their citizenship because they marry "out") and taxation where money followed these women abroad.

Americans Abroad, How Can We Count Them? This book which came out in 2010  is the transcript of a hearing held in 2001 by the U.S. Congress House of Representatives Committee on Government Reform, Sub-committee on the Census,  on the feasibility of including Americans civilians abroad in the census.  This is the diaspora meeting the homeland government directly and the interplay between homeland interests and the interests of Americans abroad is fascinating.  In particular the testimony of the representative from the U.S. State Department shines a light on the relationship between the US Embassies/Consulates and the American communities in the host countries.  

Diaspora Politics: At Home Abroad by Gabriel Sheffer
This is a general book about diaspora politics but I include it here for two reasons: 1.  It will put the efforts for recognition in the three previous books on this list in a much larger context.  There are patterns, general strategies that all diasporas use or try to use as they attempt to manage the relationship with the homeland over different issues and 2.  He examines the question of whether or not the American communities abroad (some of which have a history that goes back to the American Revolution in the 18th century) constitute a true diaspora. 

"The inclusion of those overseas Americans in this category raises some interesting theoretical questions:  Can the Americans, who themselves are of diverse ethnic origins and are citizens of a civic state rather than an ethnic state, be regarded as belonging in the category of ethno-national diasporas, or do they constitute yet another borderline case?"

A Gathering of Fugitives:  American Political Expatriates in Mexico 1948-1965 (2002) by Diana Anhalt. a fascinating portrait of American political expatriates, a "small group of controversial Americans who found refuge in Mexico during the late 40's and throughout the '50's..." Flophouse review here.

This book focuses on one of the largest and most visible group of Americans who live and work abroad: teachers. Zimmerman talks about the distinct differences between those who went abroad in the first half of the 20th century and those who left in the latter half. Though the social, historical and political frameworks changed over time, he notes that there has always been a diversity of opinion and a debate about just what these Americans were doing (or supposed to be doing) abroad. There are things in here that will make Americans wince - not just how some Americans viewed the countries where they worked (especially those that were a part of the American empire like Puerto Rico or the Philippines) in the first part of the 20th century, but also how this continued with a different twist in the second half of the century.

A beautiful book about American women abroad - the photography is stunning.  These are ordinary women who have done (and are still doing) extraordinary things outside the US: Jean Darling (Ireland), Yuzana Khin (Thailand), Gillian McGuire (Italy), Kim Powell, (France), Lucy Laederich (France), Marcia Brittain (Uruguay), and Jane Cabanyes (Spain) to name just a few. The book came out of a FAWCO (Federation of American Women's Clubs Overseas) project and is the work of two members: My-Linh Kunst (photography) and Charlotte Fox Zabusky.  A longer Flophouse review of the book can be found here.

The Transplanted Woman by Gabrielle Varro
Gabrielle Varro is a CNRS researcher in anthropology and sociology who has studied bi-lingualism, immigration and the sociology of mixed-marriages. This book came out of a study that she conducted with AAWE of French-American marriages and families over generations.  Some of it is about the dynamics of cross-cultural marriages but it also looks at American identity as it is transmitted through the American wives of French men.  A Flophouse discussion of Varro's work can be found here.

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Autobiographies:

Foreigner in My Own Backyard (2014) by Travis Casey.  I found this when when I was looking for a copy of Bill Bryson's book.  The author is an American who has been living in the UK for 20 years (he's a dual US/UK citizen) and who has had to come back to the US for a short time to care for family.   These are his first impressions of life back in the homeland.  It's funny (and sad sometimes).  Some of his stories show just how ambivalent Americans in the US are about Americans who leave.  If you are an American abroad and have ever toyed with the idea of going "home" for an extended visit, I think you will enjoy this one.

The American (2007) by Franz-Olivier Giesbert.  A rather dark book but with a unique perspective.  The author is an Accidental American in France who wrote about his relationship with his American father.  Flophouse review here.

Second Skin (2012) by Diana Anhalt.  Some stunning poetry from the author of A Gathering of Fugitives. She writes about her host country (Mexico), languages (English/Spanish) and much more.  One of my favorite lines from her work:

"Today I speak Spanish to survive,
but I write in English for its punch,
for the way it slices through excess, draws blood,
attracts sharks. (They know this voice and come to me.)"
All about the trauma of losing identity and forming a new one in a new language and country.  Very honest account of how she felt during the process.  A longer Flophouse review of the book is here.

The musings of a "redneck socialist" which are mostly about homeland politics but there are some excellent essays in this book about his time in Belize. His political views are pretty clear:  "Capitalism is dead," he said, "but we still dance with the corpse." Really engaging writer and his expat perspective is one you don't come across everyday.  Just have a look at his bio.  

Tales of Mogadiscio by Iris Kapil
This is a series of essays written by an American woman in a cross-cultural marriage (her husband is Indian and they got married in the 1950's).  She was a serial expat but this book is about the two years the family spent "on the economy" in the capital city of Somalia in the 1960's.  Beautiful descriptions of what that city was like before the country descended into chaos and became the epitome of a "failed state."  Kapil has a fine blog called Iris sans frontières.

Saturday, September 13, 2014

What if?

I'm almost finished with a really good book by Alan Weisman called The World Without Us.  It's a thought experiment:  What if humans vanished tomorrow?  What would happen and would might the world look like in 10, 100, 1000 or 10,000 years?

I can't vouch for the science but it does support a suspicion I've had since I was a kid growing up in the Pacific Northwest of the US:  the human race's grip on this planet is a lot more tenuous than we think.  I was raised in the western half of Washington state which is temperate rain forest and I did a lot of hiking in my youth.  Here's a video that will give you a good idea of what that looks like:



In order for anything human-made to last,  it has to be maintained with great effort.  In a few short years, that old field or house or road starts to deteriorate.  I saw this with a plot of land that my family owned back in the 1970's - we cleared an area and just a few years later had to get out the chainsaw to clear it again.  This is not an argument for humans doing whatever they want;  it's simply a recognition that there are forces that will take back what we make, much faster than we might imagine.

As I was reading the book and thinking about that, it occured to me that I had an even more recent example of this.  I spent part of my summer in Brittany, France where my mother-in-law owns an old fisherman's house.  I've been going to the same area for over 20 years now and what I see every time I visit is less and less land under cultivation (fewer farmers).  Some of the land was sold and there are new houses (or people trying to save old ones) but a lot of it has simply been abandoned.  In some places the only way you know that there was a farm and fields is because you'll see a little part of what was a stone wall peeking out from under the moss, ferns and trees.  Then you look closer and see that on the other side, there is forest but it's not that old (less than 100 years).  From field to forest (albeit a kind of scruffy forest with a lot of brush and shrubbery in addition to the trees) in one lifetime.  Even the stone walls, which in some places come up to my shoulder are being covered with vegetation and I've seen trees growing in these walls around those old fields, slowly tearing them down.

During dinner one evening this year we looked out the window and saw a chevreuil (European deer).  In 30 years my mother-in-law said that she had never seen one before that day.  Here's what they look like:



I really recommend the Weisman book and I'll leave you today with some pictures I took during our month in Brittany. Have a great weekend, everyone.

Old stone house which is occupied - in the foreground is the old stone wall


Four à pain (oven for baking bread).  It's not that old (probably 19th century).
The owners of this property are keeping the brush away from it but look at the roof.

Typical dirt road in the area.   You can still see the outline of the stone walls on one side.
Brush and trees growing on both sides which get hacked back to keep the road clear. If you
go off the road, wear high boots - there are snakes.

And finally, one of my favorite local spots and an example of two very old things that that have lasted up to the present day:  La chapelle Saint-Philibert in Trégunc.  It was built in the 16th century and is beautifully maintained.  The chapel however, was built next to a fountain which is ancient.  When I went one year on their annual pardon, I was told that it was definitely around in Roman times (pre-Christian era) and may date to earlier than that.