Another confounding dispatch from the inimitable Mr. Mopsick, this time offering some armchair quarterbacking of the June 18th IRS announcements.
Some CanCon highlights amongst the head-scratching tally of winners and losers:
With the Streamlined Express, the IRS has recognized that it is ill-equipped to hold everyone’s hand including old ladies in Canadian nursing homes who swear they see armed IRS special agents lurking around the bushes at night ready to arrest and humiliate them because they have disgraced themselves by failing to recognize their obligation as dual citizens to honor America with an annual tax return for all these years.
The Canadians were not loser’s [sic] here.
At worst, they were reminded that the IRS cannot give them what they need and deserve, which is for the United States to back off, enact a residency based tax structure, and some assurance that despite the fact that Ottawa rolled over like the Swiss and other European FATCA Friendly Co-conspirators, something must be done to address the fundamental and very real privacy and Charter issues Allison Christians, Lynne Swanson, and Victoria Ferauge have been talking about. With its shared culture and proximity to Washington, there should be a great incentive now for a follow up with both governments to craft an arrangement which addresses these highly complex issues. A repeal of FATCA is simply not going to happen and Congress is not likely to be up for a debate on RBT vs. CBT, but that does not mean the privacy and Charter issues are going to go away.