Both….
Lynne Swanson does it again. Another fine piece. This time at the U.K Tax News with a global audience.
She frames the story by asking the key question, “What If Other Countries Adopted American Citizenship and Tax Laws?
It is actually a frightening idea, however in this world of copy-cat taxation policies with OECD’s GATCA arising out of the U.S. unilateral global imposition of FATCA, and the U.K ‘Sons of FATCA‘, it is question that needs more attention. And, she got it!
As I understand it, the article was also published as a letter to the editor in Tax News International (subscription only), the most widely read tax publication anywhere, with the largest audience of compliance experts including Treasury and the IRS.
The questions she asks, is also a question posed by the late Andy Sundberg who penned a piece on January 6th that did NOT get as wide distribution as Lynne’s article did. It paints the picture of a dystopian nightmare for a person laboring under the demands from multiple countries all claiming their citizenship taxation rights. It was posted in February of 2012, the early days of IBS existence. What is the Systemic Risk of Citizenship taxation to the World’s Economy?
Later that year, there was Arrow’s excellent article written in June of 2012. The accidental Kenyan: What would happen if the African nation copied U.S. tax policy? by Don Whiteley. He focused on the impacts on Obama, and it got good play in Vancouver and Canada.
And now Blaze has completed the trilogy for even a wider audience, and answers the key “What if” in a manner that anyone should be able to understand, unless, apparently, you are a U.S. Congressman.
With this piece you are now armed with 3 good articles to send to family and friends that “Don’t get it!”
@Dash, You seem to be misinformed about the tax system. Nonresident foreigners do pay US income tax on US income, so under RBT, nonresident citizens would pay it too. The definition of the source of income for salaries is the actual location where the person works. So in your examples of the business visitor or the former resident who maintains a US business, they would still pay US income tax on their income that is related to the US, such as salaries while working in the US or dividends from a US company. Even foreign artists who perform in the US for a day have to pay US income tax on their earnings from the show.
Tax treaties may override these provisions, but remember that these treaties are reciprocal. Without a treaty, a resident of country A visits country B on business or receives a dividend from a company in B, pays income tax to country B, and pays little or no tax to country A due to the foreign tax credit. Similarly for a resident of B in A. With a treaty, the resident of country A does not pay tax to country B, but pays the full tax to country A. Similarly for the resident of B. So as long as the total income of each other’s residents in the country is more or less the same (which is a reasonable assumption), each country will not gain or lose any significant tax revenue due to the treaty. It’s like they are exchanging taxpayers, just for simplification. Countries are not dumb, and they do this voluntarily after analyzing the consequences.
You are also misinformed about the rights of citizenship. Foreigners cannot be physically present in the US indefinitely, and cannot be employed in the US without a work visa or green card, but there is no restriction regarding investment or business transactions. Traveling is also not a problem, as it’s relatively easy for a business person to obtain a US visitor visa (and citizens of most developed countries don’t even need one). There is no such thing as “full privileges to do business in the USA as a citizen”. I repeat: US citizenship does not “enable” anyone to do business in the US. And as explained above, US income of nonresident foreigners is indeed taxed by the US, and if they are in fact present in the US for too long (at least 4-6 months per year), they become fully taxed as residents, including on worldwide income, FATCA, FBAR, the whole shebang.
In sum, your proposal to tax nonresident citizens differently depending on their economic circumstances is RBT. That’s exactly what the US does for foreigners already, and we are simply asking the US to apply the same system for citizens. Again, there is no financial advantage of US citizenship. It’s perhaps this myth that has maintained CBT for so long.
If you don’t believe me, read this, from the US government itself:
“Breaking into the U.S. market can be a rewarding venture for many foreign businesses. Because U.S. citizenship and residency are not required, foreign nationals are able to start or expand on U.S. soil without experiencing much more red-tape than an American-born business owner would.”
http://www.sba.gov/community/blogs/community-blogs/business-law-advisor/starting-business-us-foreign-national
Thank you Shadow Raider for the clear explanation that’s so far escaped me. My husband and I have also searched in our minds how retaining US citizenship can somehow benefit us financially and have found none. We would actually have too much to lose by residing in the US as far as healthcare coverage and Canada’s departure tax goes. The only advantage I can think of for many is that a US passport allows you unfettered access to the US – but really for all intents and purposes a visa would do the same.
I believe that Dash could really benefit from learning how US citizens with unfettered access to the US actually benefits the US, and how those benefits would could be expanded under RBT, instead of a situation where USP’s are punished for living outside of US borders.
@dash, is it the perception of having more options than a resident US person what’s bothering you? Should US citizens be punished for the advantages given to us by the country where we reside outside the US be viewed as receiving unfair advantages over a resident American? Are you just jealous?
@Shadow Raider
“There is no such thing as “full privileges to do business in the USA as a citizen”. I repeat: US citizenship does not “enable” anyone to do business in the US.”
With all due respect, this simply isn’t true. Yes, anyone can incorporate a business in the US, but that doesn’t mean they can freely enter the US to work for that business. Typically a foreigner would enter the US as a B-1 business visitor. There are clear legal limitations to what a B-1 business visitor can do. Canadian businesspeople–who aren’t duals–get turned away at the border every day when they can’t convince the CBP that what they are doing falls within the limitations of the law. That creates a business risk that puts non-citizens at a business disadvantage–even if they personally have never been refused entry.
The US also has strict export control laws, such that transferring intellectual property from a US company to a non-citizen often has restrictions–even if that non-citizen happens to be the CEO of the company.
Moreover, I’m not just talking about the formal rules here. A US citizen who grew up in the country or lived many years in the US often has a strong network in the US that puts them at a business advantage that an occasional visitor wouldn’t have.
And just to reiterate what I’ve said before–we are considering here the question of whether there should be CBT, but without FBAR/FATCA. It is agreed (at least by myself) that FBAR/FATCA puts US expats at a disadvantage that clearly outweighs any advantages I might be enumerating.
Now I do think a strong case can be made that someone who never travels to the US on business shouldn’t face CBT. But someone who visits the US on business as a citizen–even if those trips are brief and wouldn’t trigger taxation if they were merely a Canadian tourist–I think their citizenship should be a significant factor in their tax status.
@bubblebustin
“is it the perception of having more options than a resident US person what’s bothering you? Should US citizens be punished for the advantages given to us by the country where we reside outside the US be viewed as receiving unfair advantages over a resident American? Are you just jealous?”
No. I’m not posing the question of whether you have an UNFAIR advantage. I’m posing the question of whether you have an advantage, period. You may have earned that advantage fairly and squarely–but you still have an advantage.
Tax is not a punishment. The fact that I’m proposing to tax someone doesn’t mean that I’m somehow proposing to punish them for something they’ve allegedly done wrong. We don’t just tax criminals on ill gotten gains–it is in the nature of our tax system (in all countries with an income tax) that money earned perfectly honestly is still subject to taxation. Maybe you have a fundamental problem with the concept of taxing income–there are tax resisters who do have such concerns–but that question is beyond the scope of the discussion I’m willing to have on here.
If your US citizenship is helping you to earn money, I see no problem with the US taxing it. Doesn’t mean that that income is illegal or unethical in any way. Just means it should be taxed like any other honest income would be taxed. If your US citizenship is NOT help you to earn money, then you have a very strong case for saying the US shouldn’t be taxing your or burdening you with filing requirements etc.
@ShadowRaider
@Dash
Interesting points made by both of you.
@ShadowRaider says:
“Again, there is no financial advantage of US citizenship” – based on the ability of non-citizens to carry on business in the U.S.
@Dash says:
“Yes, anyone can incorporate a business in the US, but that doesn’t mean they can freely enter the US to work for that business.”
So, we appear to be back to the point that the Primary/ONLY real advantage of U.S. citizenship is the right of entry to the U.S. I would grant that this is an advantage. The question is whether it is worth the huge cost.
Here is a thought to add to Shadow Raider’s point. He says that there is no “financial advantage of U.S. citizenship”. But, there can be huge financial disadvantages to U.S. citizenship in carrying on a business in the U.S.
A non-citizen can incorporate a business and carry on business in the U.S. (the right of entry is a separate issue). The link to:
http://www.sba.gov/community/blogs/community-blogs/business-law-advisor/starting-business-us-foreign-national
confirms that this non-citizen may have to file IRS Form 5472. But, other than that, the non-citizen can get his profits out of the United States.
Consider the case of a U.S. citizen abroad attempting to do exactly the same thing – that is incorporate a company to do business in the U.S. Assuming that the U.S. citizen abroad is running his business through a foreign corporation (which is quite likely) then that U.S. citizen abroad in addition to Form 5472 will also have to:
– File Form 5471 (a very expensive requirement); and
– quite possibly be subject to the SubPart F rules.
Therefore, I would argue that in many cases a non-citizen has an advantage over a U.S. citizen in carrying on business in the U.S.
In other words, U.S. citizenship may never be a financial advantage, but it often is an extreme financial disadvantage. This is absolutely sick. What kind of country punishes its own citizens and in so doing creates a competitive advantage for non- citizens.
See the following description of the problems of CBT from James Dale Davidson writing in “the Sovereign Individual”
http://isaacbrocksociety.ca/2013/08/07/the-irs-has-become-one-of-americas-leading-exports/
@USCitizenAbroad
A lot of the arguments that people seem to be making against CBT seem to me to be about things that are quite orthogonal to CBT.
Form 5471, for example, applies to ANYONE who has to file a US resident tax return. It isn’t somehow unique to CBT. A snowbird who owns shares in a Canadian corporation, for example, will have to file Form 5471. It isn’t limited to citizens.
@Dash, OK, I’ll concede a bit. I agree that US citizens can do certain things in the US that foreigners (without the proper visa) can’t, so US citizenship does make it easier to earn US income. But as I explained, the US taxes US income from everyone. And for salaries and business income, even the tax rates are exactly the same.
Let’s say an American and a Canadian, both residing in Canada, each has a Canadian business and earns income from it. Each one also decides to set up a business in the US. Let’s say they both earn the same income from the US business, and therefore pay the same amount of tax to the US on that income. The Canadian obviously does not pay US tax on his Canadian income, but according to your suggestion, the American should. Do you think this makes any sense?
Or let’s change the example a bit. As you suggested, the American has the “citizenship advantage” and is able to expand his US business more than the Canadian. Therefore, the American earns more US income than the Canadian, and accordingly pays more US tax too. Isn’t that enough? Should the American also be subject to US tax on his Canadian income? In other words, if the use of the “citizenship advantage” results in more US income, doesn’t that automatically results in more US tax too? Why should there be an additional tax due to the citizenship itself?
Remember, the question is not whether Americans abroad should pay tax to the US. It’s whether they should pay tax to the US on their foreign income. I agree that US citizenship helps earning US income, but I don’t see how it can have any advantage in earning foreign income.
@USCitizenAbroad, The text that you copied was written in 1996. The Philippines abolished CBT in 1997. The Eritrean diaspora tax is 2%.
GS_Garbo comments at http://www.ibtimes.com/americans-abroad-cant-bank-smoothly-fatca-tax-evasion-reform-comes-play-1517032 :
“FATCA is turning US persons into untouchables in the world business community since any
small- to medium-sized business anywhere in the world with a US person holding more than a 10% stake is automatically under the jurisdiction of the IRS. Inside the US, that is a given and hence not a factor, but
outside of the US, no one in their right mind would accept an American as a business partner knowing they will then be subject to mandatory IRS scrutiny. How long will it take the US Congress to figure this out (and I realize it is the fault of citizenship-based taxation but FATCA is bringing it all to a head)?”
@Dash, I think the US should post big signs at all the borders, and in the airports, “Warning, if you leave the United States, you will be taxed during your time away for the mere privilege of returning.” Is that stupid or what? What you are suggesting, and it is actually quite appropriate, is that the prisoners in the United States are given leave from the prison, provided that they pay annual tribute for the right of return.
The right of return, however, is a fundamental right, and it is a violation of a fundamental right to cause someone to pay for it. Do you make people pay $5 at the elections booth?
To get a sense of how I feel about this injustice: http://isaacbrocksociety.ca/2012/09/29/the-parable-of-the-prodigal-uncle/
@Shadow Raider
I’m talking more about employees who remain on the payroll of the company in their country of residence. Usually such people DON’T pay tax in the countries they travel to on business. For example, as a US citizen, and an employee (not shareholder) of my company, I’ve traveled on business to Singapore, Korea (South), and Canada. I haven’t paid any income tax to any of those countries. Did I make a mistake? Will Singapore, South Korea and/or Canada be coming after me for income tax one of these days?
Years ago, when I was solely a Canadian citizen/resident, I traveled on business to the US. Again–I didn’t pay US income tax (no CBT because of course then I wasn’t yet a green card holder or citizen).
So here’s the scenario I’m imagining: Canadian company has a Canadian citizen (not dual) employee. Canadian is sent to the US branch office for 90 days on a project. It is really borderline (pardon the pun) as to whether this work is really legal on a B-1 status. Canadian makes a quick trip home for Christmas and on her return to the US branch office, the CBP gets suspicious and refuses entry. As the job absolutely requires this extensive US travel, the Canadian is fired–but she has remained on a Canadian payroll the whole time (before being fired) and so pays no US income tax–and rightly so.
So next the Canadian company sends her replacement–a Canadian/US dual citizen–to the US branch office. The dual citizen is also there for 90 days, also makes a quick trip back to Canada, but has no trouble re-entering the US due to dual citizenship. Dual citizen successfully completes the project, returns to Canada to a hero’s welcome, a huge bonus, and a promotion.
But the dual citizen has also remained on a Canadian payroll the whole time and has paid no US income tax. I’m suggesting that is wrong and unfair because the dual citizen has been rewarded financially due to her US citizenship status.
On the fundamental right to return to one’s country, consider Article 13 of the United Nations Declaration of Human Rights:
http://www.un.org/en/documents/udhr/#atop
As a former citizen of the United States, in order to exercise my other freedoms, I had to give up my US citizenship. This is a violation of my right of return. I take great umbrage to this violation of my fundamental right to return.
@Dash, for every scenario you dream up that might result in some advantage for a Canadian-US dual as compared to ‘just’ a Canadian, I can think of 100 scenarios with definite disadvantages for the Canadian-US dual as compared to the Canadian. Give it up already.
@Petros
The UN article you quote refers to the right to return to your country–and notice that the wording is “country” in the singular not “countries” in the plural. The article, at least the way I’m reading it, does NOT envision the idea of someone claiming that right in two different countries at once–as you seem offended that the US and Canada won’t let you simultaneously do and also as the son wants to do in your “Parable of the Prodigal Uncle”.
@WhiteKat
Sorry but the scenario I’m describing is NOT that rare for dual citizens–and I think in your heart you know it. Even Petros’ “Parable of the Prodigal Uncle”–while Petros is railing against the injustice of it all–is another scenario of a benefit to dual citizenship. The son, in Petros’ tale, benefits HUGELY from his dual citizenship. The uncle is a bit of an a-hole based on how he reacts but the son benefits greatly from having the good fortune to be born into a family with excellent connections in both countries. I don’t think it is asking too much for the son in Petros’ tale to give something back to BOTH countries.
@Dash, I don’t think you understand what a fundamental right is. Here, we are not disputing whether one “owes” something to one country or to another. I owe something to the US but it is not taxes–and it should never be taxes as long as I live abroad, except on income gained within the borders of the US–but that of course will be zero, because I no longer invest in that country.
In my case, in particular, I didn’t claim Canadian citizenship until I realized that I needed in order to protect myself from the “a–hole” expectations of Uncle Sam, particularly in endangering the fortune of my Canadian-only wife. Thus, dual citizenship never applied to me.
If something is a fundamental right, it is in principle a failure of a just government to tax that right. I think you must come up with a better justification citizenship-based taxation of non US residents than making them pay for right to pass in and out of the country doing business. Your claim fails in that you would be taxing a fundamental right. A fundamental right, like suffrage, may not be taxed, or it becomes a privilege not a right. The job of government is not to extend privileges to the People but to protect the rights of the People. You make citizenship into a privilege, but citizenship is a question of rights and responsibilities–not privileges that the government can tax. I maintain that it is no more right to force an US citizen abroad to renounce or relinquish US citizenship through draconian tax laws, than it is to tax African Americans when they come to vote at a polling station. Both actions are preventing a person from exercising a fundamental right. And this is exactly the purpose of US citizenship based taxation: to punish Americans who have left the country. It is an attempt to prevent citizens from exercising their fundamental right to leave the country, and this is why the US condemned Soviet bloc countries for their exit tax, claiming that their expatriating citizens must pay for their education that they received at the expense of the state.
If you want to know what’s in my heart, I have not been quiet: I greatly resent the United States for forcing me to relinquish my US citizenship, essentially the right to return to my country of birth, in order to protect my myself and my family. There you have it.
So if you like, lets discuss whether expatriation and repatriation is a fundamental right. If it is, it is wrong to tax it. If it is not, then the UN Declaration of Human Rights is mistaken.
@Petros
“I owe something to the US”
I’m curious…what DO you see yourself as owing the US?
It is clear that you don’t see yourself as owing any taxes.
It is clear that you don’t see yourself as having any responsibility to give anything back to the US by investing there.
It is clear that your wife’s needs greatly take precedence over the needs of your birth country.
I’m not saying there is anything wrong with these priorities. But I’m curious–what’s left? At what point DOES the US become a priority where you do have some responsibility–because you asserted that you do still have some.
So, Dash, I’m trying to think of what my advantage for having a US connection might be?
Can I go to the USA to live out my retirement years in a warm, sunny location? No, not without going through the whole process of getting another greencard. (That’s not going to happen — EVER!) My greencard expired many years ago for purposes of re-immigration but not for purposes of taxation it turns out. And yes I was a stupid ninny for not imagining the USA might have some kind of form to officially return an expired greencard. So I just tucked the damn thing away and didn’t find it until 2 years ago when I needed to provide proof of the date I had left Canada and the date I returned — for purposes of having my OAS payment reduced according to how many years I spent outside of Canada. My CPP was also reduced because obviously I didn’t contribute to the plan while living outside of Canada.
Can I put in a claim for SS payments? No, I already have an official US statement saying I get no SS. We were self-employed in the USA and we only paid me $399 per year because we needed at least that amount exempted from the 13% SS tax — every penny was needed for us to survive down there.
Can I travel freely to the USA? No, not really. I do not qualify for a US passport (never was a dual Canadian-US citizen) so I have to travel on a Canadian passport (don’t have one) and then be treated like a potential terrorist, as are all “foreigners” these days. (I don’t like the idea of being criminalized without just cause so I’m not going to visit the USA — EVER!)
You seem to think it is an advantage that I am liable for US tax filing for the rest of my life, even though I haven’t set foot in that country for nearly 20 years. We returned to Canada with only a couple of thousand dollars in a US savings (we worked hard but only earned enough to survive, not save) and full ownership of a made in the USA (by our own hands) home which we sold and dutifully reported its sale to the IRS (not enough gain to trigger any tax). I was never accorded any label by the USA other than “resident alien” which I believed, upon my permanent return to Canada, had changed to “non-resident alien” because I was not residing in the USA. Again, stupid ninny me for not being able to grasp the US concept that someone who is not residing in the USA is still a ” US resident for tax purposes”.
My now Canadian and soon to be non-American husband will eventually be free and clear of his US tax filing but I, a Canadian since birth, do not have a way to officially break my US connection. I tried to remedy my situation 2 years ago when I found out there is a form to return a greencard. I sent it to the address given to me by the US consulate but my form was ignored, lost (although I have proof it was received) or maybe shredded, for all I know. I don’t know what terms will be in a Canada-USA FATCA agreement so I will face the possibility of having my entire Canadian savings confiscated by the IRS. All of these savings were generated in Canada and completely taxed by Canada. My US non-filing penalties (no tax would be owed) now amount to more than my Canadian savings and there is that not so trivial threat of possible imprisonment too (probably only if I was rendered to a US site though).
Conclusion? I have absolutely no advantage and a heckuva lot of disadvantage for having a US connection. If US CBT did not exist there would never have been a problem. You, Dash, would probably be able to find an advantage somewhere, somehow, but I just don’t know what that might be.
@Dash, Perhaps I should not have allowed such a concession to those who would monetize relationships. It’s like saying I owe may friend’s loyalty–can that or should that be monetized? I think not–in most cases.
Let’s put it this way: I owe the United States the fleeting sense of wistful nostalgia for a once great nation that is about to crash and burn. I will experience Schaden Freude when the US crashes, but I owe it to the US to experience it with a twinge of regret.
@Dash
“I’m talking more about employees who remain on the payroll of the company in their country of residence. Usually such people DON’T pay tax in the countries they travel to on business. For example, as a US citizen, and an employee (not shareholder) of my company, I’ve traveled on business to Singapore, Korea (South), and Canada. I haven’t paid any income tax to any of those countries. Did I make a mistake? Will Singapore, South Korea and/or Canada be coming after me for income tax one of these days?”
I don’t know about Canada, Singapore or South Korea, but in the US, yes, foreign business visitors employed by foreign companies are supposed to pay US income tax on the income they earn while working in the US, if it’s for more than 90 days or they earn more than $3,000:
http://www.irs.gov/publications/p519/ch03.html#en_US_2012_publink1000222277
As I explained above, tax treaties may override this rule to simplify things (for example, the US-Canada treaty increases the limit to $10,000), so visitors from treaty countries usually have to pay tax only to their country of residence (and please read my paragraph about tax treaties above, if you think the host country is losing anything with it). But visitors from other countries are still supposed to pay US income tax if they earn more than $3,000 while in the US (for example, if their monthly salary is $3,000 and they work in the US for a month). So in your example, replace Canada with Brazil, and both employees would have to pay US income tax.
B-1 visitors can do many kinds of temporary work in the US if they are employed by a foreign company. They can’t work in the US for a US company (without a work visa), or work as self-employed in the US.
http://travel.state.gov/pdf/BusinessVisa.pdf
Basically, what I’m trying to show is that just having US citizenship does not enable any economic advantage. The use of that citizenship to do the few things that foreigners can’t do without authorization in the US can result in an economic advantage, but in that case, this use results in income that is taxed by the US regardless of citizenship. There is no reason to tax people only because of their citizenship.
You may feel that US citizenship has value (even if just sentimental value) and that all US citizens should “pay for it”, but please stop and think rationally. Citizenship is an arbitrary definition. Taxes exist to fund government services, period.
@Dash
Picking up on your comment:
Agree that the From 5471 applies to all U.S. taxpayers who meet the CFC requirements. This of course includes: citizens, Green Card holders and those who spend too much time in the U.S. The point is that the U.S. citizen/taxpayer living abroad, who runs a business in the U.S. will be subject, under certain circumstances, to additional requirement because they are U.S. persons. This is the same as Shadow Raiders example where he compares the situation of two Canadian residents doing business in the U.S. (one who is also a U.S. citizen and the other who is only Canadian).
This demonstrates the unfairness of US Person/CBT. My point is that U.S. citizens abroad attempting to do business in the U.S. have more requirements imposed on them than non-citizens.
Why, for the purposes of carrying on business in the U.S. should it be more difficult and costly than for a non-U.S. citizen? Why, for the purposes of doing business in the U.S., should someone benefit for NOT being a U.S. citizen?
@dash
Any rights I have granted to me as a US citizen are due to citizenship, not taxation, otherwise no other country’s citizens would have the right of entry.
If you’re suggesting that I’m part of any detax movement you’re wrong. I would have told the IRS to take a hike on taxing the sale of my home in Canada, wouldn’t you think?
@Petros
Re: citizenship being a fundamental right and the taxation of a fundamental right
You make in interesting point and raise an interesting question.
What seems clear is that, since U.S. citizenship is a right guaranteed by the 14th amendment that the U.S. cannot, through taxation, destroy the right of citizenship. The combination of FBAR, FATCA, other assorted examples of “Form Crime”, the filing complexity and more, do result in “the forcible destruction of citizenship”. (The SCOTUS decision in Afroyim makes it clear that this is prohibited.) For this reason, I believe that, CBT as practiced by the U.S., violates the 14the amendment.
http://renounceuscitizenship.wordpress.com/2013/07/10/cook-v-tait-12-the-implications-of-afroyim-and-the-14th-amendment/
In other words, CBT can go too far.
What about CBT in principle? Is a “milder” form of CBT constitutional? This is a very interesting question. The case of Cook v. Tait (which is now almost 100 years old) suggests that some form of CBT may be constitutional. This case needs to be reheard. At least three things are different now:
1. The idea of what taxation is has changed; and
2. The world is far more global
3. Dual citizenship is now very common.
Here is a post on Cook v. Tait
http://renounceuscitizenship.wordpress.com/2013/01/04/does-cook-v-tait-really-mean-that-citizenship-based-taxation-is-constitutional-in-all-cases/
If Cook v. Tait were reconsidered (is CBT constitutional) I suspect the factors considered would be very different.
@Dash,
In my heart, I know that CBT is wrong. In my heart, I know that I am severely disadvantaged for being a Canadian from birth, yet having a US birthplace. In my heart, I know that the benefits you say are possible for some Canadian-USA citizens are not realized by the vast majority of us; they may not be ‘rare’, but neither are they the norm. Most Canadian-USA duals do not have any US earned income or businesses. The vast majority live their lives as Canadians only, many for decades or entire lifetimes.
I have lived 50 of my 51 years in Canada, never earned a dime of US income, yet according to US law I am a US tax evader who FATCA will soon rat out to the USA. There is a reason that only the USA and Eritrea have CBT in common. Stop trying to find one or two ‘plus situations’ applicable to the minority of duals, in order to justify an endless list of ‘minus’ situations applicable to most duals.
The disadvantages of being a Canadian-US dual are not only more numerous, but also much more commonly experienced than are the few advantages you’ve described. All Canadian-US duals are at a disadvantage in numerous ways, and of those, only a few can actually realize any of the benefits you have attempted to ascribe as being ‘not so rare’, and you say that ‘in my heart I know it’. That is a BS statement!
I like most Canadian-US duals, don’t do any business in the USA, and never will. I have experienceed absolutely no advantages for having been born in the USA, and yet am experiencing an innumerable list of painful disadvantages – all because of CBT. For example, I cannot take advantage of Canadian government registered plans for saving for my children’s education (RESPs), or for my retirement with Canadian Tax Free Savings Accounts, or invest in Canadian mutual funds – all of which are normal Canadian things to do. Any benefit is wiped away simply because I was born in the USA.
@ Shadow Raider
Thank you for being the measured voice of reason that you are.
I would add, in my typical less than measured manner, that having been hijacked and now being held prisoner by US deemed “US personhood” means that the USA (as in brand USA, not US people) holds little, if any, sentimental value to me. If I had to monetize it I would put it at about a loonies worth. The USA lost most of that sentimental value for me with its irrational and horrifying response to the false flag op of 9/11. The process actually began long before that in the so-called First Gulf War and then there was Kosovo and so on and so on, right up to the death of a family member in Afghanistan who thought he was somehow “defending Canada” by fighting in a US initiated war which was purported to be for revenge but actually it was for profit.
I think the big advantage that Dash should really be appreciating is that Canada did not inflict CBT on him when he emigrated to the USA. He was free and clear to make a killing in his chosen land, without Canadian encumbrances. Unfortunately Canada had no advantage to offer him (i.e. no job prospects) … other than his freedom. It worked well for him and that’s as it should be.