Today (11/16/2017) the floor of the House passed the House tax reform bill. The earlier version is here .
Today also the Senate Finance committee passed the Senate tax reform bill. See link
Do not yet have the final versions of either bill but suspect that we are not helped in the bills. Will post here final versions when they become available.
Listen to the C-span clip found by BB in which Residence-based taxation is mentioned by Golding and Brady in the House tax bill debate — none of this however, appears to have been incorporated into the House or Senate bills passed on 11/16/2017
Republicans Overseas (RO) continues to press on, to make changes in the final tax package that will help us. The fight is not yet over, but it continues, right from the beginning, to be an uphill battle — and the odds don’t seem very good right now. RO says: “Again we need to focus on the Senate side since this fight is far from over.”
Personally, it makes no sense to me to blame Solomon and the handful of people at Republicans Overseas for trying to make a change and, so far, failing. Yesterday a friend reminded me that there was this Ismene, who kept telling her sister Antigone that it was pointless to even “try”: “…but you’re bound to fail…No sense in starting a hopeless task…Go then, if you are determined, to your folly, etc. etc.” Antigone responded: “When I have tried and failed, [then] I shall have failed.”
On my way to the airport. Home in a few hours. A posting re: the UN Complaint will be up tomorrow (for those like me who have no choice but to continue the fight). Doubt there’s any hope now.
Solomon Yue of RO should resign from post as being the right thing to do.
Every person who renounces needs to state publicly that they renounced because the Republican Party AND Donald Trump not only LIED but they LIED in WRITING to abolish FATCA, the IGAs and CBT.
For some of us (duals from birth with no US assets, particularly) this changes nothing.
Don’t become compliant. Renounce if you need a CLN, otherwise why spend the money?
@Nononymous
I ask again, why shpuld I follow Marx?
With no US assets or financial ties, what is the disadvantage of just renouncing without compliance? You’re a covered expatriate – so what? Unless they rewrite the tax treaty, the US cannot touch anything in Canada.
I’m not the only one with this idea, you know.
Personally I won’t pay to renounce before I start having FATCA problems, which I currently do not. It’s the unsuspecting duals who are at risk of giving the “wrong” answer to citizenship questions.
@Andrew
“@Nononymous followed by @Japan T share the gold medal for dumbest idea of the day.
If you renounce and don’t file, IRS gets notified by state Department when COLN is issued. You might as well put a target on your back to get flagged, made not eligible for Streamline, and here come the penalties, interest, and/or tax notices. Game over.”
Actually, I have been saying that it is unsafe to just renounce and not file. Been arguing that for many, myself included, professional help is well beyong the realm of reality.
My question to Nonymous is in reference to and ealier remark by Nonymous.
That being said, if I went to the trouble and expense of renouncing I’d probably spend a few hours filing very vanilla zero-owing tax paperwork to exit cleanly. Salary income under the FEIE, FBARs on the chequing account, minimal net worth and leave it at that.
@Nonymous
Once you start having FATCA problems, it is too late to renounce.
@JapanT
A simple witticism. Let it go.
@JapanT
Depends on the FATCA problem. Bank starts making noises, you make the call. Doesn’t mean the SWAT team is outside your door already.
I think the fear level is way out of control. (Usual disclaimer here about second passport, US family and financial ties, etc.)
Eric,
On the Senate floor their is technically the possibility for unlimited amendments. Let’s see if that happens.
@Andrew
1. Currently not permitted by the US-Canada tax treaty. Could that one day change? Possibly yes but politically very, very ugly.
2. That one has been debated here and is indeed a concern. However, if executor is not aware of US citizenship and nothing about nationality or place of birth is reported on a death certificate, is it a real-world problem? I imagine quite a few non-compliant duals have died without the IRS receiving a payday.
@Andrew
You know Andrew I think you are a asshole. I WILL take down FATCA by hook or crook.
I want to get the FATCA IGA’ to get thrown out in Canadian Court and for 30% withholding to be imposed and then for a massive 2008 style bank bailout to put in place again. I want myself Tim Smyth to be the next Dick Fuld, Jimmy Cayne, etc that causes the next great 2008 global financial crisis. I want to be burned in effigy and blamed for all the world’s problems of poverty because I was an arrogant son of bitch who just decided one day to take down FATCA because I felt like it damn the consequences.
BTW, I am one of the “founders” of this site who doesn’t post as much as I used to
BTW,
One of my other little projects is to get your friends at Moody’s LLP stripped of their Canadian law licenses.
“If you renounce and don’t file, IRS gets notified by state Department when COLN is issued. You might as well put a target on your back…”
The requirement is not so much that one file, it is that one fill out IRS 8854 certifying under penalty of perjury that one has met one’s tax obligations (which may or may not involve filing). It is possible to imagine that some would rather commit perjury than become a covered expatriate (or file IRS forms for five years, also under penalty of perjury).
@ Andrew,
Renouncing without filing has been the preferable alternative, a carefully thought out choice, for some who have posted here. There’s no one size fits all. Like *all* aspects of how one deals with this situation of being a US person outside the US, to-file-or-not-to-file depends on the individual’s evaluation in light of their own fact set and what course of action they feel most comfortable taking.
Since we’re on the topic, if anyone’s interested in some general information on the relationship between DoS and IRS re expatriation, I’ve posted more details at this link.
@Andrew,
Re:
Don’t forget in between articles 26 and 27, there’s Article 26A. There is no mutual collection against persons who were a citizen of Canada at the time the tax debt arose. As I mentioned above, there no one-size-fits-all for “US persons” outside the US.
Thank you Tim. Considering what some Brockers went through with Moodys I can only wish the same for him.
@Andrew
“It’s never going to happen. Stop dreaming. This is the definition of insanity. CBT will be here for our lifetimes.”
You are most likely correct, CBT most likely remain for many years to come.
“Pay to stay compliant or renounce. Bottom line.”
You too forget two important points. 1). Many can not renounce until they have citizenship with another country an that this may not be possible for them to obtain. 2). Many can not pay to stay or get compliant nor to renounce.
“Stupid website of false hope….”
If one does not fight against such things, one owns part of the blame.
If you’ve been a Canadian citizen for most of your adult life, your financial affairs are relatively straightforward, and you know what to say when anyone wearing a tie asks where you were born, then you most likely don’t need a “renunciation guy”.
@Nonymous
“@JapanT
Depends on the FATCA problem. Bank starts making noises, you make the call. Doesn’t mean the SWAT team is outside your door already.”
Who said anything about a swat team?
Have you not been following what has been happening in Europe and perhaps elsewhere. Many banks have not made any noise. USPs have just found their accounts closed or frozen. Other FIs have demanded proof of non USP status within a short time frame threatening to freeze the account if the deadline is not met.
“Solomon Yue of RO should resign from post as being the right thing to do.”
Or change RO’s name with the mission to help in renounciations.
Mark Fitzpatrick @zuludogm
2h2 hours ago
Replying to @HouseGOP
#TaxReform comes once in a generation and the highest taxed families on the planet, by order of US law, were excluded. This is stunning. You had us on your side and then left us out. Why? #FATCA
Please RT AND Like
https://twitter.com/zuludogm/status/931286265655328769
https://twitter.com/zuludogm/status/931285607657156608
I am ashamed that I defended Republicans in 2016 and urged expats to support Trump and the Republicans.
The gloves are now off……..family members are now looking to the media to explain to the media that they are renouncing because the Republican Party LIED and had the balls to LIE in WRITTING;
“We call for its repeal and for a change to residency-based taxation for U.S. citizens overseas.”
https://prod-cdn-static.gop.com/media/documents/DRAFT_12_FINAL%5B1%5D-ben_1468872234.pdf
After all this, Solomon Yue has a choice…..does he have honour or does he lay in bed with liars?
This was the biggest bald faced lie perpetrated on voters, PERIOD.
The Republican Party owns FATCA.
The Republican Party owns the IGAs.
The Republican Party owns FBARs.
The Republican Party owns CBT.
The Republican Party owns every single renunciation from this moment on.
.
This is a long shot and I do not do social media…like embee.
That Alabama Senate Candidate Roy Moore is a firebrand and basically hates the establishment GOP. Folks disregard his politics that you may or may not agree with.
He just may win and he could be an ally on this.
Is there a way to twitter him on this as he would shame the GOP?