UPDATE November 18 2015:
Poll Added at end of Post – Please Vote!
USCitizenAbroad, responding on Brock to a comment from @Andy05, makes the very provocative argument that our friendly cross-border tax professionals, who live with us in our own communities, are really “‘bounty hunters’ who receive a “cut” for turning their victims over to the IRS.”
These are strong words.
Wikipedia teaches that a “bounty hunter” is a person who captures fugitives for a monetary reward (bounty) and is sometimes called in the United States a “fugitive recovery agent”.
Is USCitizenAbroad correct? Here is USCitizenAbroad’s argument:
“@Andy05
A thought provoking comment indeed. Towards the end you write:
Of course many of those cases — like Sidney Jaffe — involve bounty hunters. And if the USG privatises tax collection we might see more of that, perhaps combined with ne exeat republica writs like those served on the Barretts.
Actually, the USG has privatised tax collection. Person after person has said that they have called the IRS and the IRS response has been: “you must consult a tax professional for the answer to that question”.
What this means is that the the “tax professionals” both (1) MAKE THE LAW and (2) ENFORCE THE LAW.
Some thoughts on each.
(1) Tax Professionals MAKE THE LAW
We can see the attempt of some tax professionals to MAKE THE LAW on the issue of the proper way to interpret the Exit Tax provisions of S. 877A of the Internal Revenue Code. I am reminded of the following post that appeared earlier this year – 26 U.S. Code §877A – The “Exit Tax” rules: Do you see them as applying “prospectively” or “retrospectively” or both? :
This is an excellent example. The post discusses two groups of tax and legal professionals with conflicting views of whether the U.S. Exit Tax rules would apply to someone who relinquished U.S. citizenship prior to 2004. The consequences are staggering. One group argues that the rules are retroactive. The other group argues that the rules are prospective. That said: if enough tax professionals treat the rules as being retroactive, the rules will (in application) become retroactive. This is how tax professionals MAKE THE LAW. (Significantly this means that whether one pays an “Exit Tax” will NOT depend on what the statute means, but on how your choice of tax professional interprets (or chooses to interpret) the law).
(2) Tax Professionals ENFORCE THE LAW
This is quite obvious. People go to a tax professional for assistance with taxes and compliance. After having interpreted the law, the tax professional will then enforce the law on the client. In fact, the tax professional is likely to ENFORCE THE LAW in a manner that is least advantageous to the taxpayer and most advantageous to the IRS. This is the penalty (or “tax/form premium” that one pays for using the “tax professional”). Remember that all tax professionals are dependent on the IRS for their livelihood. Although you pay the tax professional, the the tax professional is working for the administration of the Internal Revenue Code (i.e. the IRS).
Tax professionals are in private business. They are NOT government employees.
So, what is actually happening here is this:
The combination of an Internal Revenue Code that is incomprehensible coupled with an IRS that is overworked (and probably doesn’t understand the rules of international tax any better than you do) has created a system where:
1. The IRS has downloaded the interpretation/creation and enforcement of U.S. tax law to PRIVATE “tax professionals”; who
2. “Take a cut” (in the form of their fees); for
3 Turning the person over to the IRS (which collects taxes).
Sounds to me as though the IRS has ALREADY privatised enforcement of the U.S. tax system and that the “tax professionals” are “bounty hunters” who receive a “cut” for turning their victims over to the IRS.
It’s about “People”, “Forms” and “Form People” …
Looks to me like the IRS is already using “Bounty Hunters”, or am I missing something here?
@Queensten
You write:
Tax compliance would be an issue of the person were a U.S. citizen. A CLN is proof of non-U.S. citizenship. But, on the question of past debts …?
This is an interesting and common factual scenario. One of the arguments used by the Condors is this:
What if you die as a U.S. citizen? Your estate would be required to file U.S. taxes …. A number of people who relinquished U.S. citizenship before anybody knew what a CLN was and been frightened into:
1. Pretending they were still U.S. citizens, so that they could
2. Renounce in real time and get a CLN.
The question is whether one is or is not a U.S. citizen at the time of the death. It seems to me that this is complicated by the problem that since 2004, the Internal Revenue Code has been amended to create the “tax citizen”. This then raises the question of how these rules apply, etc.
Anyway, the answer is that the Condors will always argue that the only way to be completely safe is to have a CLN. I find it difficult to imagine that any “self respecting condor” would go further and say that even with a CLN, the estate should treat the decedent as a U.S. person. That is not the same thing as the decedent dying with U.S. tax debts.
That said, there is another problem raised by your question. The problem is this:
As you may know, those who relinquish U.S. citizenship and were “covered expatriates” cannot leave bequests (in the will) to U.S. persons without the recipient U.S. person paying a 40% tax. A few months ago the IRS issued their proposed regulations for how this rule is to be applied/interpreted. The regulations appear to allow the IRS to presume that ANY bequest from a former USC was from a “covered expatriate”. This is a rebuttable presumption. So, it’s seems to me that for estate planning purposes, a USC who is NOT a “covered expatriate” and who renounces should keep independent proof of why they were not a “covered expatriate”. Keep those tax returns. Have a video showing your life of poverty. Ensure you have lots of debts, credit card bills, judgments against you (I am half serious), etc.
So, what is the “work around” to the IRS taking a “second bite” at your assets?
It’s simple, renunciation of U.S. citizenship needs to become a “family affair”.
Queenston. No they would not. It would be easy to find one with no interest in involving US estate rules for 2 non US citizens who each have a CLN
This problem of professionals who seem to be working for the government even though they are being paid by the taxpayer isn’t limited to cross-border scenarios. Some years ago (fortunately well before I was even aware of the US taxation fiasco) I suffered a massive tax hit when I sold my Canadian business and retired. My accountant at the time could easily have assisted in arranging the sale in such a way as to minimize the capital gain and the resulting tax liability by splitting the deal between two successive tax years.
Instead she was so concerned about risking her professional status with the CRA that she purposely said nothing and allowed me to blunder into incurring a huge one-time cap gain. I never forgave her for what I believe amounted to professional misconduct and never used her services again.
The moral of the story? These people are far more concerned about maintaining their professional status than they are about optimizing your tax situation. The only ones I would trust are the ones who are operating out of their home office and have no professional status. At least they aren’t scared to pursue an “aggressive” tax strategy. In the end I found it best to educate myself and handle my own tax returns. At least I know who I am representing.
As far as choosing an executor goes, pick one who is blissfully unaware of US CBT regardless of whether you have a CLN or not. And don’t have US heirs. Curiously, if you do, as far as I can tell you can give them as much as you like before you die without suffering a 40% tax hit.
P.S. I’d slightly modify that description of the two types of US expats:
1.) Those who are NOT US tax compliant.
2.) Those who BELIEVE they are US tax compliant.
It’s questionable whether it is ever possible to be totally US tax compliant if you are an expat. The IRS will certainly never tell you. Even those who have suffered through the whole renunciation/CLN/exit tax/8854 rigamarole cannot be guaranteed the IRS won’t come back years later and bite them in the ass.
How about obtaining an estate lawyer or someone other than a trust company (presently with) to distribute funds from discretionary trust (to seamlessly provide monthly expenses formerly provided by provincial disability funding when that is no longer accessible because over the asset limit for provincial funding) for disabled person who cannot renounce a US-deemed US citizenship?
“Duke of Devon says
November 18, 2015 at 12:11 pm
Queenston. No they would not. It would be easy to find one with no interest in involving US estate rules for 2 non US citizens who each have a CLN”
The CLN only ensures you are non re-portable for FATCA. Unless you have completed the exit taxes stuff the USA may still consider you a USA persons for tax purposes. Therefore if you have assets in USA or cross the border that will be a problem. In addition your children may be considered a USA citizen. My understanding is that estate taxes mainly effect children. You may see sooner or later some 90 person wanting to marry their son or daughter to avoid estate taxes. A no sex marriage.
George 3rd. Why muddy the water? A CLN is what it says it is. A certificate that you have lost your citizenship. You are not a ‘US person’ Period. There is no reason for a Canadian estate or trust lawyer to involve the US in any way.
Calgary411 . It was easy for us to find a lawyer with no U.S. ties who wasn’t interested in our past history. Calgary is a big town with lots of lawyers.
Duke of Devon
Blaze did not even get a CLN and she is protected by FATCA rules.
“Generally, it is the CRA’s view that an explanation demonstrating a relinquishment of U.S. citizenship (other than by a renunciation before a U.S. consular or diplomatic official) before June 4, 2004, and in accordance with the U.S. Immigration and Nationality Act (Title 8 of the U.S. Code) as it existed at the time of relinquishment, is sufficient to demonstrate a reasonable explanation as to why an account holder does not have a CLN. Financial institutions are not expected to be experts in U.S. nationality law; any such explanation accepted by a financial institution is accepted for the purposes of Part XVIII and the Agreement only and is not finally determinative of tax or nationality status.”
http://www.cra-arc.gc.ca/tx/nnrsdnts/nhncdrprtng/gdnc-eng.html
But the IRS will still consider her an US person for tax purposes if she crosses the border.
Her mother died a while back and there may have been an estate. I do not know how that was handled. In Switzerland you have to completed the exit tax to be considered an Non US person
Calgary 411 did the exit tax stuff so she can visit her family.
“Second Citizenship – Citizenship for Tax Purposes
What could be better than U.S. citizenship? Why not a second U.S. citizenship? The United States Congress rewarded U.S. citizens by giving them all a “Second U.S. Citizenship”. On June 3, 2004 the American Jobs Creation Act gave all U.S. citizens a second citizenship. To be specific, on June 3, 2004 all U.S. citizens became U.S. “Tax Citizens”. Interestingly, the U.S. public never asked for “Tax Citizenship”. The status of “Tax Citizen” was simply conferred on them. “Tax Citizens” have no rights. They have only obligations. The obligation is pay taxes. I recently heard it said that:
“U.S. citizenship is the gift that keeps on taking.”
Purpose of this post: The purpose of this post is two-fold:
1. to explain the two kinds of “U.S. citizenship” (“Citizens” vs. “Tax Citizens”); and
2. to explain how one can cease to be a “citizen” but still be considered to be a “tax citizen” . In other words one can cease to be the first type of “Citizen” but still be the second type of “Tax Citizen”.
Although “Citizenship” can be relinquished, “Tax Citizenship” can linger on! In order to cease being a “Tax Citizen” you must perform specific requirements under the Internal Revenue Code. Yes, this is scary! At present these requirements are imposed by the combined effects of S. 7701(a)(50) and S. 877A(g)(4) of the Internal Revenue Code.
Those who don’t want the “technical analysis” can stop here. Those who do want the “technical analysis” can (if you can stomach it) read on.
___________________________________________________________________
The analysis is very technical and will make use of the following defined terms:
“Citizen(s)” = A “U.S. citizen” as defined by the 14th Amendment and the provisions of the Immigration and Nationality Act
“Relinquishment” = Committing an act pursuant to which one ceases to be a U.S. “Citizen” pursuant to the provisions of the Immigration and Nationality Act.
“Relinquishment Date”* = The date that a U.S. “Citizen” performs an expatriating act and cease to be a U.S. “Citizen” pursuant to the Immigration and Nationality Act.
“Tax Citizen(s)” = Either a current U.S. “Citizen” (who has not performed a “Relinquishment”) or a former U.S. “Citizen” who is still considered to be taxable as a U.S. “Citizen”
“Expatriate” = A “Citizen” who has performed an expatriating act act under the Immigration and Nationality Act which results in a “Relinquishment”
“Expatriation Date”* = The date that an “Expatriate” ceases to be a “Tax Citizen” within the meaning of S. 877 or S. 877A
“Expatriation Tax” = The taxes payable (if any) according to the law that applies on the “Expatriation Date” (after June 16, 2008 this would be the “Exit Tax”).
*after June 3, 2004 the “Relinquishment” Date will be different from the “Expatriation Date”.
Relevant U.S. Laws:
“Immigration and Nationality Act”
Let’s Begin …
The United States of America – One Country – Two Citizenships
The two kinds of U.S. “citizenship”: “Citizens” and “Tax Citizens”
First: “Citizens” – A “bundle of rights”
U.S. citizenship for “Immigration and Nationality” purposes is determined by a combination of the U.S. Constitution, statues of Congress and U.S. Supreme Court decisions. Although one’s status as a “Citizen” is a function of law, “Citizenship determinations” are made by the U.S. Department of State (State Department). “Citizens” have the right to vote, travel on a U.S. passport, enter the U.S. work in the U.S., etc. “Citizens” enjoy this particular “bundle of rights“.
How does one acquire the status of “Citizen”?
At the risk of oversimplification, the following two presumptions (which can be rebutted by specific facts) are accurate:
1. Those born in the U.S. are U.S. “Citizens” (as per the 14th Amendment) unless they have relinquished U.S. citizenship (as per the Immigration and Nationality Act).
2. Those born outside the U.S. are NOT U.S. “Citizens” without proof of additional facts (bearing on the citizenship and residence of the parent(s) at the time that they were born).
Second: “Tax Citizens” – A lifetime of taxes, reporting, penalties and life restrictions
The U.S. is the only developed country in the world that attempts to levy taxes on:
– non-U.S. residents; and
– and tax those non-U.S. residents on income earned outside the U.S.
Although this is referred to as “citizenship-based taxation”, it includes those who are U.S. “Citizens” and others. In fact, it can include “Citizens” who have performed a “Relinquishment” and are therefore no longer “Citizens”.
Since June 3, 2004 – “Citizens” are not necessarily the same as “Tax Citizens”. (U.S. citizenship for “tax purposes” continues after U.S. citizenship for “immigration and nationality” purposes ceases.)
Furthermore, under the guise of “taxation” the U.S. imposes significant “reporting obligations” and “life controls”. As London Mayor Boris Johnson recently noted: “U.S. citizenship is difficult to give up“. He likely did not mean this in a “nostalgic sense”. He meant this in a costly and logistical sense. Many “middle class Americans” could be subject to a punitive “Exit Tax” and other costly IRS compliance requirements if they attempt to “Relinquish” their status as U.S. “Citizens” and become an “Expatriate”. Such is the cost of being a “Citizen” of the Land of the Free.
The world prior to June 3, 2004:
If you were a U.S. “Citizen” then you were also a “Tax Citizen” (subject to U.S. taxation); and
If you were NOT a U.S. “Citizen” then you were not a “Tax Citizen” (not generally subject to U.S. taxation).
To put it simply: If you were a “Citizen” who had performed a “Relinquishment” with a “Relinquishment Date” prior to June 3, 2004 then you were not a “Tax Citizen”.
The world after June 3, 2004 – The “Brave New World” of “Tax Citizens” – No more benefits, but the “burdens” of U.S. citizenship continue
Until June 3, 2004 the definition of “U.S. citizen” for tax purposes followed the definition of U.S. citizen for “Immigration and Nationality” purposes. In other words “Citizens” were the same as “Tax Citizens”. Since June 3, 2004, the U.S. Congress via two successive pieces of legislation (imposing taxes on “expatriation”) have defined “individuals” as “tax citizens” even though they have ceased to be “Citizens”. (To put it simply: The U.S. does not care that you are no longer a “Citizen”. You are still a “Tax Citizen” and must comply with the tax laws of the United States of America.)
“Expatriation Tax” Legislation 1: The American Jobs Creation Act – Effective Date June 3, 2004
The American Jobs Creation Act specifically states that it applies to those who become an “Expatriate” after June 3, 2014. Pursuant to the American Jobs Creation Act, individuals who performed a “Relinquishment” and ceased to be “Citizens” were considered to be “Tax Citizens” until they followed a prescribed procedure related to notifying the State Department and filing information with the IRS.
“Expatriation Tax” Legislation 2: The Heros Earnings Assistance and Relief Tax The Heart Act (“HEART” Act) – Effective Date – June 17, 2008
The 2008 “HEART” Act replaced the 2004 American Jobs Creation Act. The principal purpose of the HEART Act was to impose an “Exit Tax” on those relinquishing U.S. citizenship. IRS Notice 2009-85 describes the “heart” of the Heart Act as follows:
irs.gov/irb/2009-45_IRB/ar10.html
Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 (the “Act”) added new sections 877A and 2801 to the Internal Revenue Code (“Code”), amended sections 6039G and 7701(a), made conforming amendments to sections 877(e) and 7701(b), and repealed section 7701(n) with respect to individuals who on or after June 17, 2008, relinquish U.S. citizenship or cease to be lawful permanent residents of the United States. This notice provides guidance for individuals who are subject to section 877A. This notice does not provide new guidance regarding section 877, which continues to apply to individuals who relinquished U.S. citizenship or ceased to be lawful permanent residents prior to June 17, 2008. Additionally, this notice does not address new section 2801, which imposes transfer tax on U.S. persons who receive gifts or bequests on or after June 17, 2008, from individuals who are subject to section 877A (but see section 9 of this notice).
To whom does the 2008 “HEART” Act apply?
S. 301 of the Heart Act makes it clear that S. 877A (including S. 877A(g)(4) applies to those who “expatriated” after June 16, 2008. S. 877A(g)(4) continues to distinguish “Citizens” from “Tax Citizens”.
Are the provisions of the “HEART” Act prospective only or retrospective as well?
It is obvious that S. 877A(g)(4) operates prospectively. Those who perform a “Relinquishment” after June 16, 2008 (ceasing to be “Citizens”) continue to be “Tax Citizens” until they meet the requirements of notification prescribed in S. 877A(g)(4).
The question is whether S. 877A(g)(4) operates retrospectively. Does it mean that those “Citizens” who performed a “Relinquishment” prior to June 16, 2008 AND who did NOT notify the state Department of the “Relinquishment” (as required by S. 877A(g)(4)) continue to be “Tax Citizens”.
Relinquishment of U.S. Citizenship prior to June 16, 2008
The answer is complicated by the recognition that those performed a “Relinquishment” prior to June 16, 2008 include two groups:
First, those who performed a relinquishment prior to the invention of the “Tax Citizen” on June 3, 2004 (and who are arguably NOT subject to the S. 877A rules); and
Second, those who performed a relinquishment after the invention of the “Tax Citizen” on June 3, 2004 and were required to meet the requirement of S. 7701(n) of the Internal Revenue Code.
Readers are advised to keep the following facts in mind:
1. The concept of “Tax Citizen” did not exist prior to June 3, 2004.
2. “Relinquishment” is defined in the Immigration and Nationality Act. There is NOTHING in the Immigration and Nationality Act that makes “Relinquishment” dependent on notifying any branch of the U.S. Government about the “Relinquishment”.
3. There is nothing in the “Immigration and Nationality Act” that makes the “Relinquishment” dependent on receiving a “Certificate of Loss of Nationality” (CLN) from the U.S. Government.
Many former U.S. citizens performed a “Relinquishment” of their U.S. citizenship prior to June 3, 2004 with:
– the intention of relinquishing U.S. citizenship;
– with the full understanding that by so doing they would no longer be U.S. “Citizens”;
– with the full understanding that after their “Relinquishment” that they were no longer “Citizens”
This group relinquished their U.S. citizenship pursuant to the laws of the United States of America that applied at the time (the law has been amended over time) that they performed their “relinquishment”. They have subsequently been living their lives as non “Citizens”. A common example of this scenario is a U.S. “Citizen” who moved to Canada and became a Canadian Citizen.
Does S. 877A(g)(4) operate to turn those who relinquished prior to June 3, 2004 into “Tax Citizens”? Should they be subject to the horrors of the Exit Tax?
This issue has attracted the attention of the American Bar Association.
http://www.citizenshipsolutions.ca/2015/03/04/the-united-states-of-america-one-country-two-citizenships-introducing-the-tax-citizen/
The plain reading of S. 877A suggests that those relinquishing U.S. citizenship prior to June 3, 2004 are NOT subject to the Exit Tax provisions.
Share this:
http://www.citizenshipsolutions.ca/2015/03/04/the-united-states-of-america-one-country-two-citizenships-introducing-the-tax-citizen/
just a simple summary
“Until June 3, 2004 the definition of “U.S. citizen” for tax purposes followed the definition of U.S. citizen for “Immigration and Nationality” purposes. In other words “Citizens” were the same as “Tax Citizens”. Since June 3, 2004, the U.S. Congress via two successive pieces of legislation (imposing taxes on “expatriation”) have defined “individuals” as “tax citizens” even though they have ceased to be “Citizens”. (To put it simply: The U.S. does not care that you are no longer a “Citizen”. You are still a “Tax Citizen” and must comply with the tax laws of the United States of America.)”
FATCA does not use the rule but the IRS does.
DO not cross the border if you have a large estate from someone in USA expect problems.
When I am referring to FATCA I am referring to USA Canada FATCA IGA.
For non tax compliant people
DO not cross the border & if you have a large estate from someone in USA expect problems.
Thanks, Duke.
@GeorgeIII George trois (one alias only is necessary on Brock-pls choose one only)
It is not appropriate to post so much material verbatim without permission of the author. This is strictly followed by authors at Brock due to copyright laws. I spoke with John Richardson and he said it is ok this time. For future please either get permission or post short excerpts with the links only.
https://www.fin.gc.ca/treaties-conventions/pdf/FATCA-eng.pdf
Article 1
Definitions
1. For purposes of this agreement and any annexes thereto (“Agreement”), the following terms shall have the meanings set forth below:
ee) The term “U.S. Person” means (1) a U.S. citizen or resident individual,
This subparagraph 1(ee) shall be interpreted in accordance with the U.S. Internal Revenue Code.
Tricia I had an opening quote ” and I had copied the link twice. Is that a problem?
If I had a long explanation from the IRS do you think I should ask them?
The most important point is that unless your tax compliant do not cross the border.
Also if you expect a large inheritance there could be problems.
Calgary 411
Do not ever use an accountant with a CA as well as CPA designation.
CPA is only for Canada, CA is an american designation. Some Canadian accounts have a CA destination as well
Norman Diamond can inform you about Kovel letters from lawyer to accountants.
The good news is that this stuff is so complicated that its a virtual certainty that nobody at the IRS (at least at the operational level) understands it either! You have just described why it is probably best to just simply self-relinquish and skip applying for a CLN. Why invite the State Dept. to announce to the IRS that you have just expatriated? Don’t turn yourself into a nail head which sticks up.
I, too, don’t have a CLN. Once I became a Canadian I stopped filing anything with the IRS. My plan going forward is to totally ignore the bastards. For all the IRS knows I got sucked into a black hole. I don’t expect problems. There’s nothing they can do about it anyway.
And, GeorgeIII, please stick to one alias at Brock. Thanks.
‘In the UK today they have a “pay now, litigate later” law that is bankrupting some who were conned into tax shelters by major accounting and law firms’
That’s the same practice the IRS, and courts except sometimes Tax Court, use in assessing penalties and bankrupting people who made the mistake of writing honest declarations on tax returns, who were deceived by the “under penalty of perjury” clause and therefore refrained from committing perjury.
‘And just think: how perverse it is that some couples are divorcing so that their future newborns will not acquire American citizenship at birth.’
But that trick only works for children of US fathers, not for children of US mothers. A pregnant female has less than 9 months to get that appointment at a US consulate, and might have to make herself stateless to protect the fetus.
“Norman Diamond can inform you about Kovel letters from lawyer to accountants.”
No I can’t. My only contribution to that sub-thread was that for 99% of us it is not affordable to go that route, even if it’s cheaper than other unaffordable routes.
Norman
Did the lawyer want to charge your extra to explain the kovel letter or was it in lawyer speak?
Of course you now live in a country with a 22 year stock market slump.
http://www.forecast-chart.com/historical-nikkei-225.html
George III
Doing that with IRS info is not the same as taking from an author directly.
This is not my rule but is a copyright issue. Yes it is a problem. You put up the title, copy/pasted a huge amount of material and put a link. Next time, it needs to be/will be truncated if you do not have permission to use the material. You can always use excerpts with a link, just not all of the material.
“Did the lawyer want to charge your extra to explain the kovel letter or was it in lawyer speak?”
Mu.
I would qualify for a Low Income Tax Clinic in any state in the IRS’s list, but Tokyo and Ontario aren’t in the IRS’s list.
Someone who was a friend before he became a lawyer took a glance and estimated that a lawyer could clean up one tax year in my US filings for a fee that would have been around a year of my salary at the time. But he wouldn’t really have cleaned it up. He didn’t understand that US withholding was US withholding. He thought I was declaring large foreign tax credits, which coincidentally is the same as some IRS employees were telling each other, even though the $0.00 of foreign tax credits was plain as day in two forms 1116 (general and passive) and the corresponding line of form 1040. He’s not a tax lawyer though. Tax lawyers charge more.
Kovel letters were never mentioned.
“Of course you now live in a country with a 22 year stock market slump.”
Yes, like the US’s slump from 1929 until whenever it came back. Does this mean you think a cross border tax lawyer here would be more expensive or less expensive than one who resides in the US?
Norman
Lawyer are lawyer and they are always the winners. I have even heard that some lawyer complaining that lawyer in bigger cities are more arrogant.
I only mentioned the Tokyo stock market slump because it so out of line of most developed countries and hopefully you did not put all your money in Tokyo stock market.
You may also want to take a glance at Petros personal story thread most recent comments to see if you think IRS will have a different opinion them him.
I don’t understand…
http://www.theglobeandmail.com/report-on-business/canadian-accountants-merge-under-cpa-designation/article19299464/
I have used the services of a CA in Canada for many, many years and hers is not a US designation.
Other opinion regarding Canadian designation of CA (Chartered Accountant) and the merger: http://www.iwanttobeaca.com/2011/11/cpa-merger-is-bad-for-us.html
(I am not worried about the accountant whose services I use but need an estate lawyer who can monthly distribute a discretionary trust for my son — and what that would mean about having to disclose my son’s US-deemed US citizenship status after I die. i.e. I do not want one penny that should go for my son’s well-being to go to the IRS. They have already robbed his RDSP and the Canadian government/Canadian taxpayer US$3,661 for the matching bonds and grants contributed to my son’s RDSP (as I am the Holder of that account / my son the beneficiary) in order for finalization of all of my requirements to be able to file an 8854 form to certify I was in compliance with all of my US tax obligations — not a huge amount but any amount is too much. Other than that, I owed the US $0.00)