11 thoughts on “Reminder for Info Sessions in Innsbruck, Vienna & Budapest”

1. JFK, of course, was president when the U.S. government started taxing the foreign earned income of U.S. citizens who unquestionably resided outside the U.S. He was also behind the CFC rules and the rules against foreign trusts (although he was thinking about the shenanigans of his wealthy acquaintances, not Canadian pensions or somebody owning a restaurant abroad with their foreign relatives)

2. Presumably USCs who live on Mars will qualify for the automatic filing extension the IRS grants to foreign residents so their returns are not due until June 15. (Or not, because the US might consider the Mars base to be US territory.)

   The big question for those filing from Mars is exactly what the IRS will consider to be “timely filed”. For US residents a postmark before midnight on April 15 is deemed to be timely filed but the IRS has not yet issued any guidance for Mars residents.

   If I were a USC on Mars, I would be tempted to blow off US tax filing. It is very unlikely the IRS would have any effective means of seizing Mars assets and presumably those who are Mars bound will have wound up their financial affairs here on Earth. (But never underestimate the IRS; they might decide to prepare one of those “substitute returns” and see if they could squeeze something out of a Mars resident.)

   Only one thing is for certain. All amounts must first be converted to US dollars.

3. Just had one interesting conversation. A guy from an EU country and working in the US temporarily is in the US with his heavily pregnant wife. The child is due next month.

   Of course I had to make him aware of FATCA and IBS and gave him IBS’s web address. They plan to go back to Europe soon. The child is in danger of becoming an ‘Accidental American.’

   Told the guy about the implications of the child’s interactions with banks and FFIs in his home country but not if it all fully sunk in.

   IMO he’d be better off driving the 250 miles across the Canadian border, have the kid born in Canada, have the American Health Insurance company pay the Canadian hospital bills, and save his kid a load of hassle from the US Government going forward.

   He made a big deal about not being a US citizen, but as always most people don’t realise how complicated FATCA is.

4. One other thought – Canadian hospitals could arrange ‘US tax free births,’ the exact opposite reason a Mexican girl crosses the border to ‘drop’ the kid.

   If for example, a woman lived in Vermont, had the kid in Montreal, the kid would still entitled to live in the US, but would lose the US place of birth.

   Not having a US place of birth would certainly be a big benefit from a living abroad point of view. Being free from having to prove continually by foreign banks that you’re not a ‘US person’ and being treated the same as everyone else.

5. @maz57: my guess is that the IRS could easily figure out a way to make some earthbound entity pay for the tax deficiencies of the Martian colonists, e.g. by claiming that their shipments to the colonists are U.S. source income or something to which “backup withholding” needs to be applied.

6. @Eric: You may be right. If so, logically the Martian colonists would simply arrange for their shipments to launch from a non-US space facility. But the IRS could also exercise a little common sense and come up with a special Fact Sheet (or Rev. Procedure??) announcing the Martian Earned Income Exclusion (MEIE). Its not likely a Mars colonist would have much in the way of investment (or passive) income so that should do the trick.

   Still wouldn’t get them off the hook for FBAR, however.

   @Don: Brilliant idea! Think of the income that could create for Canadian hospitals. Plus the kid would also then have Canadian citizenship which is better than US citizenship any day of the week.

7. @Publius

   Yes, quite true about JFK. But back then, the only portion of income that was taxed was capital gains on stock disposition and debt obligations and some foreign source income was deemed to be US income. At least there was nothing on earned income, nor the estate or gift tax.

8. Pingback: Repealing “Citizenship Taxation”: The difficult we do today, the impossible takes a little longer | Alliance for the Defence of Canadian Sovereignty

9. http://blogs.wsj.com/expat/2015/02/11/foreign-expats-in-u-s-find-themselves-rejected-by-banks-back-home/

   FATCA is becoming a hindrance for the US to attract foreigners to be based in the US. Because foreign banks don’t want to deal with anyone labeled a ‘US person,’ they’re faced with a financial upheaval to satisfy US tax reporting for a few year assignment in the US?

   Will some people bother? The US is losing out attracting people and gaining very little tax revenue for its troubles.

   Unless foreigners try to stay under the radar and not change their address with their foreign bank and be careful not to ‘tip them off,’ somehow, FATCA complicates their lives enormously.

10. Excellent advertisements for these meetings … eye-catching and clever attention-getters! Well done! Hope the meetings are going well!

11. @Muzzled

    I will be sure to pass that on to the person who created them!
    We will start to do more like this from now on!