The American Citizens Abroad Global Foundation has just launched its educational program with a forum/debate on the merits of Citizenship-based taxation vs. Residence-based taxation.
This is a full day event, sponsored and organized by the ACA, that will be held at the University of Toronto on May 2. Registration and Information
UPDATE re booking accommodations:
My understanding is that the speakers will be staying at the Holiday Inn 280 Bloor Street West in Toronto phone 416-968-0010.
At the moment all rooms at this hotel are booked up at the central reservation service for May 1, but I called the hotel and arranged for a University rate of about C$130 night plus tax. There are 20 or so rooms still available at that May 1 date (many more for May 2). The rooms cannot be held for us but you can book now until all are taken.
To book a room you email cn312res@whg.com and request a $130 room for the RBT vs. CBT conference. You also have to provide a code. I asked the conference person to choose between RBT vs. CBT and she came up with the correct answer RBT (!) which will be your code.
If you are interested in coming to the conference I would book right away.
To my knowledge, this is the first public debate — worldwide — devoted to this important topic.
The speakers will include academic tax specialists Bernard Schneider and Michael Kirsh, who have different approaches to the taxation of US citizens abroad, with the program moderated by Toronto lawyer John Richardson.
Dr. Stephen Kish, who co-authored with Mr. Richardson a submission to the U.S. Senate Finance Committee (see below), will be the academic host.
Bernard Schneider:
The End of Taxation Without End: A New Tax Regime for U.S. Expatriates, Virginia Tax Review, Vol. 32, No. 1, 2012, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2186076
Michael Kirsch:
Revisiting the Tax Treatment of Citizens Abroad: Reconciling Principle and Practice, October 23, 2013, Florida Tax Review, (Forthcoming), Notre Dame Legal Studies Paper No. 1457, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2346458
Richardson/Kish:
John Richardson, Willard Yates, Stephen Kish, Request for Tax Rules Changes for U.S. Citizens Overseas: Submission to the Senate Finance Committee, January 2014, http://citizenshipsolutions.ca/wp-content/uploads/2014/01/RichardsonYatesKishJan232014SFCSubmission.pdf
Keynote Speakers
Prof. Michael S. Kirsch, Professor of Law, Notre Dame Law School
Dr. Bernard Schneider, Teaching Fellow, Centre for Commercial Law Studies, Queen Mary University of London School of Law
Phil D.W. Hodgen, International Tax Attorney, Hodgen Law Group PC, Pasadena, CA
David Kuenzi, Certified Financial Planner,® Founder, Thun Financial Advisors, Madison, WI
Charles W. Cullen III, Certified Financial Planner, ® RBC Dominion Securities, Inc., Halifax, NS
Neil Sinclair, Chapter Chair, Amcham Canada – Ontario Region
Closing comments: Jackie Bugnion, American Citizens Abroad, Inc., Director of Tax Team
Shadow Raider
Agreed.
@IRSCompliantForever, thank you so much for the information about both the conference and the hotel. Much appreciated!
Shadow Raider,
I will make your point as part of my opening comments at the conference. You are right.
@IRSCompliantForever: I’ve contacted the administrator at the ACA Global Foundation because I’m having a problem with the payment portion of the registration process for the forum. I want to pay by credit card but the website makes it impossible to do so without opening a paypal account. I’m definitely not a paypal person. My registration has apparently been accepted although my invoice # obviously states the account is not paid up.
I don’t know how long it will take for the administrator to get back to me and I want to be sure that my registration will not be canceled. I’ve already booked my flight! If I can’t pay the registration fee online with the normal credit card procedure I could mail you a bank draft in U.S.$ or bring the payment to the session on May 2. Would either of these methods be acceptable?
Sorry to bother you with this. I’m sure you didn’t intend to be dealing with registration issues in addition to your other efforts!
@Muzzled,
I contacted the ACA and was told that the registration problem was fixed. You seem to be having a different issue and I just passed this on to ACA.
I also suggested to ACA that if the registration procedure does not work for you, you just receive an email confirmation that you have in fact registered, all is ok, and that you would just pay the regular rate at the door.
Your registration will not be canceled.
Many thanks, IRSCompliant, for your assistance, once again. I look forward to meeting you on May 2!
@Muzzled,
ACA will be fixing this problem and just asks that you contact info@acaglobalfoundation.org , explain the problem, and say that you are in fact registered and will pay at the door.
It’s times like these that make me appreciate even more GwEvil’s smooth donation setup for our little CCCF fund.
See you there!
@IRSCompliantForever,
Done! Many thanks!
RE getting media coverage for this event – – someone who is involved with organizing may want to include a contact with Jeffry Simpson; while he is an award-winning very long-standing national affairs columnist for the Globe & Mail, he also is a US-born Canadian. No reason not to approach him on that basis.
Here’s Jeffrey Simpson’s e-mail:
jsimpson@globeandmail.com
Here’s his profile:
http://www.theglobeandmail.com/authors/jeffrey-simpson
I taste tested some of his articles (generally not impressed) and FATCA does not appear to be on HIS radar. Wonder if the banks and the CRA will soon have HIM on theirs though. He has to have read other G&M articles about FATCA and connected it to his own US connection by now.
cant make it from London in UK but will be there in spirit and cant wait to see the video/read the trasncript. awesome work , people!
It will be interesting to see when the pro-CBT debater tries to argue that having US citizenship is beneficial for expats a la Cook vs. Tait.
I have an answer for him:
If US citizenship were so “beneficial” for expats, why are they paying money to get rid of it?
Expats have no representation in US congress and no access to US public goods and services. Expats don’t use US highways, roads, dams, bridges, schools, hospitals, fire rescue, police, courts, Medicare, Medicaid, Obama care, unemployment insurance, food stamps and so on. Only homelanders consume these things.
But what about all the embassies and consulates all over the world that provide services for Americans?
Any public services that expats use at embassies or consulates are paid for in the form of fees (very high ones at that). The last time I walked into an embassy I was surprised to see the fee schedule posted on the main wall like a fast food restaurant menu, but no specials. It was very comprehensive. Virtually every little service, no matter how routine requires payment.
http://jerusalem.usconsulate.gov/service/schedule-of-fees.html
The Cook vs. Tait “benefits” argument falls flat on its face. No cost / benefit analysis would support expats retaining US citizenship. The ones who do retain US citizenship either intend to live in the US in the future or do not want to lose a military pension or some other retirement plan. Most other expats who do not formally relinquish US citizenship by obtaining a CLN do so out of fear from the costs and penalties of coming into tax compliance. Instead, they go underground and live in the shadows like the illegal aliens inside America.
It is very difficult (if not impossible) to come into compliance when an expat’s entire life is considered to be a crime.
America’s immigration problem is widely acknowledged. But its emigration problem is far worse.
Speaking of consular fees, last week I was told by a friendly gentleman in customer service at Wells Fargo that all I had to do to close my now deceased mother’s bank account was go to a branch in WA State with a copy of her death certificate and a copy of her will. I did just that today and was told by the bank person there that I had to go to the US embassy in Canada and get the documents notarized before they would accept them! Well I tell you right now that I won’t be doing that and driving to Bellingham again for $68 even with exchange rates what they are today – but they are getting a nasty letter of complaint from me. Not only that, they took copies of my private documents knowing that they weren’t going to grant me my request.
This has got me reflecting on something I’ve mentioned here before. How can Canadian banks be expected to verify the authenticity of another country’s documents, namely CLN’s?
@bubblebustin:
That’s a good question. It is probably a good idea to get a few notarized copies of the CLN from the embassy.
Citizenship based taxation (CBT) is America’s “peculiar institution.” So was slavery.
According to Wikipedia, http://en.wikipedia.org/wiki/Peculiar_institution:
It may be more cost-effective to get notarization from other than a US Consulate or Embassy. Why wouldn’t a notarization from a Canadian lawyer who notarizes serve the same purpose? Why should it have to be at a US institution?
Another horrible experience, bubblebustin’. By reporting your experience, you’ve just alerted others that may have to do the same.
Like SLAVERY, CBT is indeed “AMERICA’S PECULIAR INSTITUTION” and should be referred to as such in as many discussions as possible. It needs to make its way into the media headlines:
CBT is America’s Peculiar Institution! Together with FATCA and FBAR it is why so many expats are ditching their passports or going underground. Full stop.
Then maybe the expat haters in congress (there’s plenty of them) will start to figure out that CBT, like slavery, is a human rights abuse and bad for America’s image.
World opinion needs to start asking the question, why would so many citizens from the “LAND OF THE FREE” renounce US citizenship, unless the land of the free is nothing more than a GRAND HOAX?
@ FromTheWilderness
Thank you for your fabulous posts! “Most other expats who do not formally relinquish US citizenship by obtaining a CLN do so out of fear from the costs and penalties of coming into tax compliance. Instead, they go underground and live in the shadows like the illegal aliens inside America. It is very difficult (if not impossible) to come into compliance when an expat’s entire life is considered to be a crime.” You have articulated the position of so many of us with great clarity!
CBT is, indeed, a peculiar law, in any sense of the word!
Cheers MuzzledNoMore.
I will try to post on this thread more arguments against “America’s Peculiar Institution” of Citizenship Based Taxation with hopes that some of the Toronto Forum debaters may be reading this blog and could perhaps use them.
The great thing about this blog is that it really tells it like it is from the POV of long-term expats (emigrants). I’m not talking about short-term expats such as government contractors or employees of US companies who work outside the homeland for a few years while maintaining strong ties with the intent of returning. I’m talking about the people who move away permanently and homestead somewhere else, either while they were children or at some later point in life.
The bottom line is the Peculiar Institution of CBT was designed to keep Americans tethered to the plantation.
And although America’s Peculiar Institution of Citizenship Based Taxation may be legal, it should be remembered that the America’s Peculiar Institution of Slavery was legal at one time as well.
@Joe Blow
Circumstances being the same, wouldn’t a Canadian bank require the Canadian embassy notarized the US issued CLN?
@Bubblebustin
The short answer to your question is that I don’t know much about verifying foreign documents. However, the bank could easily cross reference the on-line Federal Register (CLN Honor Roll), provided the person’s name is actually on it.
In any case, anyone getting a CLN might as well request a couple of notarized copies from the consulate or embassy while they’re at it. Just in case the original gets misplaced.
Yes, Joe Blow, something that precious should have notarized copies made!
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http://www.dukascopy.com/tv/en/#127190
May 12, 2014 Interview with Jackie Buignon talking about the CBT/RBT debate event