[OCTOBER 1 UPDATE: THANKS EVERYONE WHO SENT LETTERS!]
Today is the very last day to support — by your letter and petition — a Republicans Overseas (RO)/RNC proposal that would replace citizenship-based taxation with a form of “territorial taxation”.
Info is at this website: https://republicansoverseas.com/territorial-taxation-individuals/#petition
RO’s Solomon and Michael will personally bring the letters and petition to the White House on October 2, but they need to receive everything by September 30 — WHICH IS TODAY.
USCA suggests that you consider:
“…The comments in this thread have reflected a diverse collection of views. The RO proposal has been severely criticized for various reasons (mostly revolving around the taxation of nonresident aliens). It’s true that the RO proposal has many flaws.
That said, I think it’s important to recognize in broad terms, that the RO proposal that will change the impact of CBT as it currently stands. In that respect the proposal is at least a start and that start is described as “Territorial Taxation For Individuals”. It is possible (and I think advisable) to support the broad principle of changing CBT without necessarily agreeing with every aspect (or any aspect) of the specific RO proposal. Some of you may have read the most recent ACA proposal which does a good and interesting job of explaining what “territorial taxation” (borrowing from the language of the RO proposal) could mean for individuals. (Interestingly what “territorial taxation” COULD mean for individuals is what most of us think of as “residence-based taxation…)
I am simply trying to argue that change will require education. Education will require engagement. Engagement requires personal interaction.
Your sending a letter and/or signing the petition will help RO achieve the personal interaction that they need to engage and educate. If you care about this issue at all, then you must participate.
I don’t believe that the mere fact of sending letters or signing petitions will make a difference. But, I do believe that WITHOUT YOUR EFFORTS and support that NO CHANGE IS POSSIBLE. Therefore, you are really deciding whether you want to act in a way that makes change possible or if you choose to act in a way that makes change not possible. It’s your choice. This is NOT about supporting a specific proposal. This is about behaving in a way that opens the door to discussion in change.If it matters, I am not a Republican. I am not a Democrat. To the extent that I am political, I would be an independent. I am not primarily a U.S. citizen. So, these comments are not partisan. But, I am deeply committed to the struggle to getting these unjust laws changed. Furthermore, I believe that change can happen ONLY if all those affected create a united front in opposition to CBT. It is the opposition to CBT that unites ALL Americans abroad.
It’s very simple really. Where laws are made through a democratic process: If you don’t make your view known you can’t expect change.
Your participation may or may not make a difference. But, your NONPARTICIPATION will make a difference because it will ensure that no change will happen….”
@Mike: “I understand this, but try getting our local politicians to get this.”
Dead right. I have been trying to “educate” both my local MP and my country’s Treasury on this for more than five years now. On every occasion — and there have been dozens! — the response has been a shrug accompanied by some variation on “it is a matter for the US how it taxes its citizens.” My own government clearly has no interest in addressing the issue in any way. Perhaps they don’t even see it as an issue. Or maybe they are just in thrall to the US.
Either way, it is like flogging a dead horse.
Well if you are giving up then you are helping the USA impose CBT on your country – just saying.
I have signed the petition and sent the letter. This was difficult as I renounced quite a while ago and I have kept low–thinking of my US citizen adult children. But we will not get the attention we need unless we speak up, so I also included some of my own thoughts on why CBT has to go.
@USCitizenAbroad
I haven’t given up. I still needle my MP on this regularly. And any Treasury official that seems like they might take an interest. And they just as regularly brush it off. Aside from derogatory commentary, do you have something more constructive to suggest?
Tim: I, too, am very grateful for your positive comment. When reading Mr. Buckley’s version of the conversation I was dismayed to learn that the 9 pages published on Saturday was *it* for this year and that we’d have to wait until next year for anything further. Where tax reform is concerned I don’t believe there IS a next year. I hope you can provide us with a different interpretation of the conference call very soon.
@USCitizenabroad
Many of us here are not apathetic, we have been here for the duration.
We have never been in a sea of negativity but in a pool of constructive assessment and criticism.
RO are not suggesting a move to RBT, they have introduced there own version of TBT which in the opinion of many here is set to fail because of the affect of a downturn in inward investment to the US and the negation of just about every tax treaty the US has entered with other countries over the decades.
PLEASE READ Karen, Watcher, Badger and many other’s assessment of their proposal. RO have been given the facts but have not listened.
http://www.angloinfo.com/blogs/global/us-tax/international-tax-reform-public-hearing-scheduled-by-senate-committee-on-finance/
Virginia is reporting on a public hearing to be held on October 3 (next Tues) by the Senate Finance Committee. The JCT staff has prepared a report “International Tax Reform.”
This is unreal. Previous JCT reports have outlined our issues and we all know of our 2015 submissions to the SFC.
I don’t know how much support we can get going for pressuring them before Tuesday but maybe at least a Twitter deluge?
Am on phone but will be back with SFC list and see if will be televised….
https://www.jct.gov/publications.html?func=download&id=5025&chk=5025&no_html=1
A paragraph on pp8-9 briefly acknowledges that foreign tax credits don’t reliably prevent double taxation.
It’s hard not to be pessimistic, I agree.
I have no idea what will happen with tax reform in the US. It’s something I’m not going to follow in detail. I did my bit by writing a letter and signing the petition. The current administration is proving to be both evil and incompetent, which comes as no great surprise.
I suppose there’s a chance that some change from CBT could be snuck in via some committee, but given that the tax package (should anything ever emerge from Congress) is likely to be a giant gift to the plutocrat class, it’s hard to imagine they’d also risk the optics of eliminating taxes for expats. Just as likely they’d kill the FEIE as part of some sleazy bargain and make the situation worse.
Whatever. The US is a shit-show and there’s probably not much anyone can do about it. In the meantime, we have a couple of angles worth pursuing. Pressure on one’s own government, of which the FATCA lawsuits are a part, might provide further relief for dual citizens.
Otherwise our job is to spread the word that staying off the radar is a viable option, provide helpful tips on how to avoid US reporting and taxes, and warn against condors. Renouncing is something I’d personally only recommend in the event that banking services are being denied. And of course all questions of compliance and citizenship are greatly complicated by financial and other ties to the US.
The ones in greatest danger are US expats without a second citizenship. Dual citizens (particularly accidentals) have protection in their countries of residence, and far less incentive to expend energy fighting something they likely have little ability to change.
The ttfi proposal could work, if was predicated on a different funding method.
Favorite would be abolition of the IRS as per Ryan’s Better Way plan.
I found a quote from J.R.R. Tolkien today which made me dream a little dream of anarchy. I’m sick to death of control, no matter who or what is the purveyor and/or enforcer of it.
We can’t just sit back and wish for freedom though. There may only be a slim chance of anything of significance to us coming out of US tax reform but if we don’t push our particular concerns forward in whatever manner is made available to us, slim becomes zero.
Solomon and Michael need petition signatures and letters. I hope they get enough in time.
EmBee: I couldn’t agree more. Our fight is worth every ounce of energy we spend and I am bolstered in this belief by a few facts that I mentioned on another thread: women have the vote and African-Americans no longer have to sit at the back of the bus. And just in the past week Saudi Arabia has decided to allow women to drive! These all represent enormous societal changes that, at the time, no one would ever have believed could be achieved. Compared to these issues, rooted in centuries of seemingly intractable ignorance, the issue of who a government has the authority to tax SHOULD be an easy matter to solve.
If they don’t solve it, we’ll solve it for them, perhaps until there isn’t an American left outside US borders and there isn’t one dime flowing to IRS coffers from “overseas”.
Patricia: I sure hope some good news starts coming our way soon. Maybe the Yue/De Sombre presentation on October 2 can somehow be made known to the SFC on October 3. But it boggles the mind how the SFC could possibly NEED to see any more than they already have in the submissions made to them over the past number of years. What is it about international tax reform for individuals that they don’t feel is worth mentioning in their agenda?
The Republicans Overseas global teleconference with Grover Norquist, President of Americans for Tax Reform, was informative, insightful, interesting, and actually encouraging.
It is true that TTFI is not in the current GOP Tax Reform package. The territorial taxation for corporations proposal is included. US corporations have been lobbying Congress on this issue for the last 10 years. Trump campaigned on this issue and now he has to deliver his campaign promise. It also is true that GOP members of Congress felt uncomfortable with TTFI due to the fact it has not been fully scored and vetted.
Congress will use the Regular Order, which allows congressional hearings to pass the tax reform. This means TTFI could be added to the package if overseas Americans participate in this process. That was the reason Mr. Norquist suggested Congress needs to hear from the 9 million overseas Americans, especially GOP members. The best argument is that overseas Americans will vote in 2018 and 2020. Mr. Norquist expects very a few Democrats will vote for the tax reform because Democrats don’t believe in tax cuts.
RO has excellent arguments for TTFI inclusion: TTFI will create stateside American jobs when the 35% premium, due to CBT and FATCA, for hiring Americans to work overseas is eliminated. Overseas Americans are the most effective advocates for, and exporters of, American-made goods and services. TTFI is not only revenue-positive, but also supports the America First initiative by eliminating tax loopholes for foreign billionaires. Mr. Norquist also suggested to Solomon Yue, RO Vice Chairmen, that he solicits the support of President Trump’s Director of the National Economic Council Gary Cohn.
Thank you.
Solomon Yue
Republican National Committeeman for Oregon
Vice Chairman and CEO
Republicans Overseas, Inc. and Republicans Overseas Action, Inc.
https://www.facebook.com/republicansoverseas
https://republicansoverseas.com/
@Muzzled
The SFC is not calling for any submissions; I just felt it was worth at least a Twitter Blast since there is no reasonable mention of us……
There are apparently issues that are more important as well as those that they cannot stomach. I think in general, they just don’t care……..It isn’t just SFC, it is across-the-board generally.
What does surprise is to read what HAS been mentioned (in no less than JCT report 2013) before and continually gets buried by whatever…….they know, simply no excuse for it.
It is why I actually do believe that for anyone who needs clear closure, there is no arguing with the adage “All roads lead to renunciation.”
@Muzzled
Examples- in case not emphasized enough in a previous post.
from the
Competitiveness Report by the Senate Finance Committee, May 9, 2013. The following members of the Committee in 2013-2014 (113th Congress)are also members of the current SFC.
DEMS: Wyden, Stabenow, Cantwell, Nelson, Menendez, Carper, Cardin, Brown, Bennet, Casey, and Warner. Ms McCaskill was not a member at that time and the committee then included Schumer and Rockefeller.
GOPS: Eleven members are the same in 2013 & 2015. Mr. Scott, Mr. Hellman & Mr. Cassidy. were not members in 2013.
IV. NON-RESIDENT U.S. CITIZENS
1. Provide an election to citizens who are long-term nonresident citizens to be taxed as
nonresident aliens if they meet certain conditions (Schneider, “The End of Taxation
Without End: A New Tax Regime for U.S. Expatriates,” 2013; similar to the law in
Canada)
a. Require a minimum period of residence abroad
b. Impose an exit tax on electing taxpayers where deemed to sell all assets at the
time of election
2. Repeal the foreign-earned income exclusion (H.R.2 (108th Congress), Jobs and Growth
Tax Relief and Reconciliation Act of 2003, sponsored by Rep. Thomas)
Perhaps a lot less complicated than trying to implement RBT or TTFI. Though the exit tax part would depend and those in lower tax countries would likely not elect when no FEIE. Nonetheless, it cannot be said that the SFC was unaware of these options BEFORE the 2015 submissions.
This is why I am unforgiving, extremely angry and in general, tend not to have a lot of hope. Sorry to any this negativity offends.
For lists of previous members of the SFC: https://ballotpedia.org/United_States_Senate_Committee_on_Finance
Patricia: Thanks so much for the overview of the SFC’s involvement in this. It really is unforgivable how they keep dropping the ball on this. We’ll see what the next month brings. For now, I’ll put my remaining hopes in the Yue/De Sombre effort and my faith in this community that it will pull together in the coming hours to answer Stephen’s call.
http://isaacbrocksociety.ca/2017/09/26/five-days-left-to-send-repeal-citizenship-based-taxation-letters-and-petition/comment-page-3/#comment-8007026
Quite the gap in reality and expectations?
Last day to send letters
Well, exactly. Norquist and perhaps some other American lobbyists and politicians may hear that estimated figure of nine million and think there’s a pool of nine million voting, filing, FATCA-hating American-identifying US citizens living outside the USA and ready to
There’s not. It would be more realistic to start with the 1.1m filers, subtract a realistic number to allow for those who can’t vote, those who will never vote, those who will never vote Republican, those who accept FATCA, those who’ve never heard of the solution offered by RO, and those who know of it but don’t support it.
The US smears people with US citizenship without their consent. That’s how they get the estimate up to nine million.
ready to vote Republican.
@Embee sums it up very well:
The comments in this thread have reflected a diverse collection of views. The RO proposal has been severely criticized for various reasons (mostly revolving around the taxation of nonresident aliens). It’s true that the RO proposal has many flaws.
That said, I think it’s important to recognize that in broad terms, the RO proposal will change the impact of CBT as it currently stands. In that respect the proposal is at least a start and is described as “Territorial Taxation For Individuals”. It is possible (and I think advisable) to support the broad principle of changing CBT without necessarily agreeing with every aspect (or any aspect) of the specific RO proposal. Some of you may have read the most recent ACA proposal which does a good and interesting job explaining what “territorial taxation” (borrowing from the language of the RO proposal) could mean for individuals. (Interestingly what “territorial taxation” COULD mean for individuals is what most of us think of as “residence-based taxation”.)
The Isaac Brock Society began in 2011. Since that time, the following things have happened or are happening. All this would have seemed to be nothing more than a fantasy in 2011:
– 2013 submissions to the House Ways and Means Committee
– 2014 ACA Debate with Kirsch/Schneider in Toronto on the University of Toronto campus
– 2015 submissions to Senate Finance Committee
– 2015 live meeting with staff of Senate Finance Committee in DC
– 2017 FATCA Hearing in DC (Meadows)
– ADCS FATCA lawsuit in Canada which raised nearly $600,000 and is alive and well
– RO Bopp lawsuit in the USA
– Recent testimony in front of the European Parliament
– Possible litigation in France
– Open discussion and support of a general lawsuit against CBT in the USA
– French Commission report acknowledging the effects of U.S. extra-territorial legislation on other countries
– although not always popular ACA has run a long fight against CBT and a move to RBT
– Democrats Abroad is now “officially” supporting RBT for individuals
– and now (the subject of this thread) the RO initiative to attempt to get “territorial legislation for individuals” in the actual tax proposals for Tax Reform 2017
(and countless blogs, twitter accounts, Facebook groups, individual meetings, etc.)
All of these achievements (and I believe each and every one of these things is a HUGE achievement) involved the tireless efforts OF A VERY SMALL GROUP OF INDIVIDUALS. But, these SMALL GROUPS OF INDIVIDUALS RECEIVED THE WIND IN THEIR SAILS FROM A LARGER GROUP OF PEOPLE WHO SUPPORTED THEM. This support came from encouragement. This support came from small individuals, who did small things, often by writing small letters (see for example: http://fatca.eu.pn). This support came from the willingness to do the small things that are necessary to make the big things possible!
I am not a fan of the U.S. Government. I am not a fan of their tax policies. I am not a fan of their abuse of Americans abroad. But, (for the most part) I don’t think the U.S. Government has been fully (or in some cases) even partially aware of the effects of the combination of their tax and reporting rules. (They don’t even understand these rules let alone how they impact Americans abroad).
A necessary condition to change these laws is to make those involved in Tax Reform:
1. Aware of what these laws are
2. Understand how these laws actually impact Americans abroad
3. Aware that there is significant awareness of and opposition to these laws.
On October 2 two members of RO have made it clear that they will be having direct interaction with those who can make a difference in tax reform. They are asking for your support in doing ONE THING. That ONE THING is to write and “support territorial taxation for individuals”. You don’t have to support their specific proposal to support “territorial taxation for individuals” (which in its most basic terms is a move away from CBT). The purpose of the exercise is to make it clear (awareness point 3) that the current tax policies are a problem. Without this awareness NOTHING is possible.
Even with the awareness, change will be difficult. Change will involve compromises. Change will be time consuming and frustrating. Unfortunately, that’s what the democratic process is about. You/we have lived with the problems of CBT. The lawmakers don’t even know that CBT exists (let alone the problems). For RO to be able to personally deliver these letters could be a huge step in educating the lawmakers. It’s NOT that the lawmakers are supportive of CBT. The lawmakers don’t even know that CBT exists. On this point, think of Rep Connolly in the FATCA hearings where he said something to the effect that: “All countries tax their citizens” (obviously equating citizens with residents).
I am NOT defending the behavior of U.S. law makers or the administration (few have been more critical than I have been and continue to be). I am simply trying to argue that change will require education. Education will require engagement. Engagement requires personal interaction.
Your sending a letter and/or signing the petition will help RO achieve the personal interaction that they need to engage and educate. If you care about this issue at all, then you must participate.
I don’t believe that the mere fact of sending letters or signing petitions will make a difference. But, I do believe that WITHOUT YOUR EFFORTS and support that NO CHANGE IS POSSIBLE. Therefore, you are really deciding whether you want to act in a way that makes change possible or you choose to act in a way that makes change not possible. It’s your choice. This is NOT about supporting a specific proposal. This is about behaving in a way that opens the door to discussion about change.
If it matters, I am not a Republican. I am not a Democrat. To the extent that I am political, I would be an independent. I am not primarily a U.S. citizen. So, these comments are not partisan. But, I am deeply committed to the struggle to getting these unjust laws changed. Furthermore, I believe that change can happen ONLY if all those affected create a united front in opposition to CBT. It is the opposition to CBT that unites ALL Americans abroad.
It’s very simple really. Where laws are made through a democratic process: If you don’t make your view known you can’t expect change.
Your participation may or may not make a difference. But, your NONPARTICIPATION will make a difference because it will ensure that no change will happen.
The lack of response to the request for letters makes it clear that Americans abroad are NOT willing to support this important move towards the abolition of CBT. Why not? You don’t have to support every aspect of the RO proposal to support this RO initiative.
This is not a political issue! It is a human rights issue that can be remedied through the political process!
USCAbroad: THANK YOU for your words and the time it took for you to share them. I hope that all here take them to heart.
@ USCA
That sound you hear is me clapping. Well said. I would sink into despair if we didn’t have small yet significant lights ahead like the White House meeting, another SFC hearing, the lawsuits (here and in the USA) and who knows what else is coming. I think of them as the match flickers that could/should eventually ignite a flame of understanding which will burn the supports out from under CBT/FBAR/FATCA. The process seems terribly slow but the fact that there are match flickers at all attests to the determination of enough people who pushed to make them happen. My heartfelt thanks to all of them.