If you look on Tax Analysts there is currently a pay walled article with this title under the Today’s News/International Tab. It is no joke.
If this is what I think it is it means WAR.
See also Jack Townsend, IRS CI Is Looking at Renunciations of Citizenship Just in Case (3/1/13)
Are you American? Don’t ask, don’t tell.
Cook vs. Tait would have been more accurate if it had read, “… government, by its very nature, THREATENS the citizen and his property wherever found…”
Expat, stay in the closet where you belong!
I read on another web site… the advantage of having an american passport… when there is trouble.. u will be moved to the front of the line not for help either. Sad part… its true… friends who are dual… were so proud of having an american passport… after their trip… they gave it back… got back their european ones… they said… they didn’t realize how americans are hated in the world….
@US_Person_Foreigner says “they didn’t realize how americans are hated in the world….” Why does the USA have to have their “cooking spoons” all over the world?What is first,the chicken or the egg?Or political unrest everywhere before or after the US has stirred in the various pots?(In the name of “democracy” ? etc.)VERY SCARY
@From the Wilderness, re http://isaacbrocksociety.ca/2014/03/01/irs-starts-criminal-investigations-of-renunciants-and-relinquishers/comment-page-5/#comment-1203233
You read my mind. And every time I read that excerpt I think how very flimsy a subjective self interested rationale that is, while masquerading as self evident or empirical fact. And every time it is cited as justification for the CBT and FATCA juncture we find ourselves at, the more it rings false – as you point out.
I think the claim in Cook vs. Tait fits the definition of a ‘rhetorical tautology’ as in; “In rhetoric, a tautology (from Greek tauto, “the same” and logos, “word/idea”) is a series of statements that form an argument, whereby the statements are constructed in such a way that the truth of the proposition is guaranteed or that, by defining a dissimilar or synonymous term in terms of another, the truth of the proposition or explanation cannot be disputed. Consequently, the statement conveys no useful information regardless of its length or complexity making it unfalsifiable. It is a way of formulating a description such that it masquerades as an explanation when the real reason for the phenomena cannot be independently derived. A rhetorical tautology should not be confused with a tautology in propositional logic, which by the precepts of empiricism is not falsifiable.” http://en.wikipedia.org/wiki/Tautology_%28rhetoric%29
The CBT and FATCA rationale only benefits the US. The US makes statements to maintain the convenient fiction: ‘because I said so’ (US CBT law) and ‘because we’ve always done it this way’, and because ‘might makes right’ – pitiful positions for a so-called ‘democracy’ to take towards those abroad.
And then, the US rhetorical rationale is made even more ludicrous when Canadian politicians preface their remarks about it that assert any ‘respect’ for the US to make its own tax laws in the context of extraterritorial CBT and FATCA – regardless of the outcome and consequences of that as applied to Canada and the rest of the Globe – which makes Finance Minister Flaherty’s remarks; …”..To be clear, Canada respects the sovereign right of the U.S. to determine its own tax laws….”…. (ex. at http://www.carp.ca/2012/06/15/minister-flaherty-canada-continues-to-press-for-fair-tax-deal-with-united-states/2/#sthash.jxNyqhWy.dpuf..”.. and this from the IGA announcement is even more singularly OFFENSIVE coming from the mouth of our Canadian Finance Minister and the Ministry, even if it is followed by qualifying commentary:
“….Canada respects the sovereign right of the U.S. to use citizenship as a basis for taxation…….” http://www.fin.gc.ca/afc/faq/fatca-eng.asp
Which of course is in stark conflict with the coming OECD proposal for a global ‘common reporting standard’ wherein for the entire rest of the globe (other than the US and Eritrea) residency and not citizenship/nationality is and will continue to be the international norm. http://taxpol.blogspot.ca/2014/02/oecds-plan-for-global-tax-info-exchange.html http://www.oecd.org/ctp/exchange-of-tax-information/Automatic-Exchange-Financial-Account-Information-Common-Reporting-Standard.pdf
If the OECD can specifically note that the standard they support is based on residency and not on citizenship/nationality, then it seems particularly egregious for Canada’s federal government, via the Ministry of Finance (who is entirely aware of and involved in the OECD efforts) to choose to go even further at this time than in previous statements http://business.financialpost.com/2011/09/16/read-jim-flahertys-letter-on-americans-in-canada/ and take pains to state that;
“….Canada respects the sovereign right of the U.S. to use CITIZENSHIP as a basis for taxation.” http://www.fin.gc.ca/afc/faq/fatca-eng.asp
What were Harper and Flaherty thinking when they CHOSE to use the term ‘respect’ vs. ‘acknowledge’ – and this time specifically acknowledge the CITIZENSHIP basis? Knowing full well the ramifications?
Do they ‘respect’ the extraterritorial aspect too?
Great points. How is it our government can choose to respect the US’s tax laws and not Eritrea’s? Oh I know the answer: 30% withholding.
Would ‘rhetorical tautology’ also be known as ‘circular reasoning’?
“Mar 12, 2014 As the Foreign Accounts Tax Compliance Act Takes Hold, U.S. Sees Expatriates at All-Time High,” from Ifrah Law