I wanted to post that a fairly prominent US tax law professor and new blogger Allison Christians is becoming the H. Heward Stikeman Chair in Tax Law at McGill University. From reading her blog she appears to be moderately pro FATCA although perhaps not as strongly as some other US tax profs I have seen out there(She is more pro information sharing citing the current US Canada agreement as an example). She has three blog posts I suggest you might want comment on. I have put links below:
http://taxpol.blogspot.com/2012/03/countries-dont-help-each-other-to-tax.html
She discusses the current US Canada information sharing arrangement in the above post and discusses DATCA
http://taxpol.blogspot.com/2012/03/international-tax-gangsters.html
General post on offshore evasion
http://taxpol.blogspot.com/2012/03/netherlands-to-share-more-tax-info-with.html
Discussion on the Netherlands joining the FATCA five agreement
Prof. Christians is almost certainly a US Person. Hopefully she will be enjoying filling out all those FBAR forms upon her arrival in Canada. Note: lets not get too nasty. Who knows Prof. Christians might be a Canadian citizen in a few years time.
She will certainly gain excellent personal experience on what it is like to be a US citizen living and working in a foreign country, with all of the additional tax forms she has to complete and file with the IRS Unless she transfers her assets to Canada, which she won’t be likely to do immediately, she will not have a problem with FATCA and FBAR firms at first. She will have to deal with how the US – Canada tax treaty deals with Canadian deferred compensation plans, which may differ from the way such funds are treated in the US. It would be interesting to know, but we probably never will, whether she completes her own US tax filings or is she turns to a professional to do the job for her. She will not be able to claim her contributions to Canadian charities as deductible for US tax purposes.
@Tim: excellent links to Professor Christains writing. I highly recommend everyone who is actively engaged in reading, and commenting on the Isaac Brock Society web page, to read the first post about countries helping each other as opposed to working against each other in the area of taxation. Professor Christain’s blog on this topic stands in sharp contrast to the “man the barricades!” reaction to the notion of Canadian banks outing their depositors to the IRS.
30 Year IRS Vet
What she says is all very sensible, if you take it on it’s own. FATCA and FBAR et al would be perfectly fine, except that it applies to the US system of citizen based taxation.
That is ultimately the real problem. FATCA etc are efforts to enforce an immoral and harmful (to us) tax rule, that we feel powerless to change. While it was unenforced we just ignored it, some intentionally, some not. Now we fight against the enforcement, but what I, and I think most of us, really want is to get rid of the underlying problem.
“……Under FATCA and citizenship based taxation the U.S. is actually colonizing the world through its expats.”
Julian Hudson posted this reply to the first blog mentioned above. I recommend everybody to read it.
Looks like she also did a stint at the University of Ottawa law school:
http://www.commonlaw.uottawa.ca/en/allison-christians.html