158 thoughts on “1,313 published expatriates in Q1 Federal Register honour roll; 1,484 renunciants added to NICS for same period”

1. @Iota
   Iota says
   “Allison Christians has got a great infographic showing prices around the world. It seems to be one of the fastest-growing commodities at the moment. Would be very interesting to know how many purchasers are USCs”
   A great many I would think. We have been trying to encourage my son-in-law to do just that for insurance, but the prices have almost doubled in the two years he has been thinking about it!

2. @Paul S.

   Why not just nip it in the bud and block Americans from emigrating to Canada?

3. @Paul S.
   I brought up the issue of people who were too poor to comply and too poor to renounce with my senator, but all I got was a form letter in response. All they care about is money, unfortunately. I don’t see why they think it takes a lot of money to move abroad. There are lots of types of people who end up abroad without having great wealth: English as a foreign language teachers, ex-military, people who left the U.S. during a downturn, full-time parents.

4. Bubblebustin said, “I’m afraid you’ll have to hang the “pipe dreams” comment on me.”

   I asked: “Which is more of a pipe dream? Easier renunciation of US citizenship or the USA ending CBT”

   Bubblebustin replied: ” @Paul S.
   Why not just nip it in the bud and block Americans from emigrating to Canada?”

   So are you saying you think ending CBT is more of a realistic endeavour than putting heads together to think of ways to help people renounce a little less painlessly?

5. edit: So are you saying you think ENDING CBT is more of a realistic endeavour than putting heads together to think of ways to help people renounce a little less painlessly?

   Publius, I was thinking more of a home country approach rather than trying to deal with US politicians directly. Let our home governments deal with the foreign government on our behalf. That is their job.

6. @ Paul S
   As a non-US born individual, naturalized at one time, I would not hid the fact that I was a US citzen at one time and never proud of it but for other reasons. If simply asked I would say yes .If not asked ,why the need to advertise. That is not hiding.

   What you are proposing is for Canada to fork out money to the US, as if we can afford it.

7. @BB

   ” Why not just nip it in the bud and block Americans from emigrating to Canada?”

   Also you would need to put all americans living here under some form of birth control so that the disease wouldn’t spread.

8. “Basically the IRS does not accept that we transact in any currency except dollars. That our functional currency is dollars. Depending on the exchange rate on the day of buying the mortgage and paying it off, there may be a gain.”

   When your employer pays money into your bank account, you’re supposed to figure the value in US dollars. When you withdraw money to buy food, you’re supposed to figure the value in US dollars. If the exchange rate fluctuated during those 5 minutes or 12 days or whatever, you have a phantom gain or loss in US dollars. If it’s a phantom gain you’re supposed to pay real US tax on it, but if it’s a loss you eat it … no wait, you took the withdrawal to buy food, so you don’t get to eat.

   If you withdraw a 20 Canadian dollar note from your bank, the Bank of Canada owes you 20 Canadian dollars, even though the notes aren’t worded that way any more. If you spend it to buy food, and get 5 Canadian dollars in change, then the Bank of Canada only owes you 5 dollars. If the exchange rate fluctuated between withdrawing and spending, you have a phantom gain or loss on 15 Canadian dollars, and you can figure out what you have to do.

   The IRS publishes average annual rates so I used those instead of the required calculations (except when trading futures contracts to gain or lose from exchange rate fluctuations). The IRS never complained about that; the only years the IRS complained about were when the IRS needed to frame me for the embezzlements performed by IRS employees. But I think the IRS ought to audit me and perform all those calculations.

9. “unfortunately. I don’t see why they think it takes a lot of money to move abroad.”

   Well I see why. They know how much money a person has to have in order to pay all the penalties the IRS will trump up.

   (No different from the penalties the IRS used to obama up.)

10. Robert Ross,

    You said, ” If simply asked I would say yes .If not asked ,why the need to advertise. That is not hiding.”

    I think you misunderstood the dialogue I was having with Badger. Sorry to confuse, or to offend in any way.

    Also, you said, “What you are proposing is for Canada to fork out money to the US, as if we can afford it. ”

    I don’t think you understand what I am proposing at all. Either that or I do not understand your comment. I don’t have a particular plan in mind, but more a general suggestion that people step back a bit and consider an oft used phrase at this board: “all roads lead to renunciation.” Perhaps the dream of ending CBT is a dead end street. Perhaps it would be more realistic to find ways to promote and facilitate a less painless path towards renunciation of US citizenship. How exactly? I don’t claim to know what might be the best ways, though I did give a couple of suggestions, neither of which involved giving the USA any money.

11. Badger, I’ve thought more about your concern regard those who cannot renounce on their own due to incapacities. Perhaps there could be lobbying efforts towards the Canadian government to promote facilitation of renunciation of US citizenship for Canadians with US person status, with specific attention to the plight of such individuals. They are a perfect example of how low the Canadian government has sunk. Perhaps we could persuade the Canadian government to negotiate a ‘get out of jail free’ card for the most vulnerable of Canadians.

12. A few days ago I wrote “Form 8821”. I should have written Form 8822 because that is the notification of change of address, which the IRS ignored.

    In fact though, the IRS ALSO ignored Form 8821, Tax Information Authorization. By weird coincidence one of the rare times that the IRS replied to one of my letters, the IRS acknowledged my Form 8821 requesting that they send copies to my sister in the US every time they send me any correspondence. But they haven’t sent her anything, not even a copy of the letter which acknowledged Form 8821.

13. I’m for the US returning to RBT and making it easier for people to renounce.

    Many people including Prof Allison Christians believe the current renunciation fee could be challenged in US court. Why not approach the issue from that angle?

    The Canadian government has already proven that they don’t really care about helping us.

14. Re: persuading the Canadian government(s) to act on our behalf with a foreign government, their job — here are the Conservatives and then we got the flip-flopping Liberals…

    http://isaacbrocksociety.ca/2014/02/23/finance-minister-flaherty-has-responded-to-carp/

    The chances based on history of our many efforts in Canada? We are, says the Canadian government, US Citizens who happen to abide in Canada. If we have a problem, best we take it to the US says history.

15. “We are, says the Canadian government, US Citizens who happen to abide in Canada. If we have a problem, best we take it to the US says history.”

    By following the “take it to the US” approach, you are in effect agreeing with the Canadian government that you are “US Citizens who happen to abide in Canada.” How’s that worked for y’all so far?

16. The Canadian FATCA lawsuit is not a ‘take it to the US approach’.

17. Bubblebustin you say: “I’m for the US returning to RBT and making it easier for people to renounce. ”

    That is a great sentiment. I agree with you. You also said that the latter is a “pipe dream”. Do you think the former is a “pipe dream” also? If not, why not?

18. The Canadian FATCA litigation says we reject the Canadian government definition, that we are Canadian citizens who should have the same Charter rights as any other Canadian — that *A Canadian is a Canadian is a Canadian*; that we should not be deemed second-class to any other Canadian citizen because of the place of our birth or the place of birth of our children’s parent(s) or the place of birth of children born to Canadian parents in the USA who left that country with their Canadian parent(s) as children. Discrimination by national origin.

    http://isaacbrocksociety.ca/fatca/comment-page-130/#comment-7612681

    Finally, after many months a form letter reply from the Min. of revenue.

    “I understand (our) policy can create a compliance burden….. For U.S. tax obligations these individuals can contact the IRS or consult with a tax professional qualified in U.S. tax matters….. I trust the information I have provided is useful.” Signed Hon. D. Lebouthillier.

    Give me a break- not worth a further letter.

    http://isaacbrocksociety.ca/2016/04/18/april-14-2016-canadian-parliament-ethi-standing-committee-on-access-to-information-privacy-ethics/comment-page-3/#comment-7523702

    To: Carol Tapanila
    Sent: Wednesday, May 4, 2016 3:38:14 PM
    Subject: the Canada–U.S. intergovernmental agreement

    Ms. Carol Tapanila

    Dear Ms. Tapanila:

    Thank you for your correspondence about the Canada–U.S. intergovernmental agreement to implement the U.S. Foreign Account Tax Compliance Act provisions, and U.S. taxation of U.S. citizens who are residents in Canada and are unable to renounce their citizenship because of mental incapacity. I apologize for the delay in replying.

    I would first like to mention that I am sympathetic to the difficulties regarding U.S. filing obligations that have been expressed by many Canadians who are residents of Canada, but are also considered U.S. persons.

    With respect to the U.S. tax-filing obligations of Canadian residents who hold U.S. citizenship, the agreement does not impose any new taxes, penalties, or tax return filing obligations, and does not affect any U.S. domestic laws related to citizenship. It relates only to the sharing of information. The U.S. policy of taxing its citizens, even those who are not residents, has been in place since 1913. While this is different from the approach followed by Canada and most other countries, Canada respects the right of the U.S. to tax on this basis.

    The Canada–U.S. tax treaty offers relief in many areas, for example, for income earned in a registered retirement savings plan. However, income earned in a registered disability savings plan or registered education savings plan is taxable in the U.S., while it is exempt in Canada. An amendment to the treaty would be needed to provide for an exemption from, or deferral of, tax in the U.S. on these plans. The Department of Finance Canada is responsible for tax policy, including tax treaty negotiations. Therefore, I have forwarded a copy of your correspondence to the Minister of Finance.

    I am also sympathetic to your frustration regarding the inability to renounce citizenship in the U.S. due to mental incapacity. I understand that the intention is to protect those individuals, however, I cannot comment further on a U.S. domestic law issue.

    I appreciate the opportunity to respond to your concerns.

    Sincerely,

    The Honourable Diane Lebouthillier, P.C., M.P.
    Minister of National Revenue

    c.c.: The Honourable Bill Morneau, P.C., M.P.

    Sympathy from The Honourable Diane Lebouthillier, P.C., M.P., Minister of National Revenue is not enough for me and other families like mine — or the sum total of *US Persons in Canada*.

    I want to know now what The Honourable Bill Morneau, P.C., M.P., Minister of Finance, is working on regarding the US-Canada Tax Treaty in regard to, among other issues, the Registered Education Savings Plan and the Registered Disability Savings Plan – how soon will we see a result? Until then, will the Minister of Finance or the Minister of Revenue issue a warning so anyone with any kind of *US taint* will not in the first place enter into these investments that were intended to benefit ALL Canadians? Will there be a statement issued that *All Canadians* does not include *Americans who happen to reside in Canada* even though they took their first breath on Canadian soil? We tainted *US Persons in Canada* need clarification that our Liberal Prime Minister’s pre-election statement, *A Canadian is A Canadian is A Canadian* is not inclusive after all.

    I also want to know from the Prime Minister of Canada why my Canadian-born son’s (and other Canadian *Accidental Americans*) Canadian rights do not take priority over any US-deemed US citizenship. How can a person who has never lived a day of his or her life in the US and has had no benefit from the US, but because of lack of requisite mental capacity, be so entrapped into complex and costly US compliance by the barriers placed by the US, including the fact that such a person’s Canadian’s parents, guardians or trustees cannot act on such a person’s behalf — especially in light of the consequences of US citizenship-based taxation? There was an amendment offered that the Conservatives and now the Liberals ignore, thrown to the winds, government officials never even attempting to negotiate the rights of Canadians with the US, the government who our own government representatives now seemingly take their orders from without question or negotiation on behalf of their own country’s citizens.

    The problem needs to be and is being addressed on all fronts to achieve freedom from the consequences of US CBT, the most common sense one, however remote, a change from US CBT to RBT as (most of) the rest of the world.

19. Excuse me, but I meant that getting the Canadian government to subsidize our renunciations is a pipe dream, not the concept of making it easier for people to renounce. Sorry for the confusion.

    Have you written to your MP about your proposal?

20. “The problem needs to be and is being addressed on all fronts to achieve freedom from the consequences of US CBT, the most common sense one, however remote, a change from US CBT to RBT as (most of) the rest of the world.”

    “All fronts” are not being addressed in the sense that GROUP focus has been on ending FATCA and ending CBT, but not ending US citizenship which has been left for the INDIVIDUAL to deal with.

    If a change from CBT to RBT is “remote”, what are the alternatives? Could group advocated (as opposed to each man for himself) renunciation be an alternative?

21. Bubblebustin, Given that we have a finite life span, which is more of a “pipe dream”, RBT or easier renunciation?

22. @Paul S

    That’s really stuck in your craw, hasn’t it? Tell you what. Write to your MP about your proposal and I may consider endorsing it.

23. Bubblebustin, you said, “As a Canadian taxpayer, I will use not approve of using my taxes to subsidize US renunciations.”

    I don’t understand how you would not support your fellow Canadians in their attempt to get free from the USA. Not everyone has the funds to become compliant, and sit back and watch and wait, and hope for RBT.

24. https://travel.state.gov/content/travel/en/legal-considerations/us-citizenship-laws-policies/renunciation-of-citizenship.html

    @Paul S.
    Many would be interested in seeing an outline of your proposal for group advocated renunciation of US citizenship — just how that might proceed given the above US citizenship laws and policies.

    We know by what followed that the Canadian government representatives in their negotiations took to heart the US statement:

    Congress has spoken.

25. “you may consider endorsing it”. Thanks so much.