— Two different members of the tax compliance industry are now saying that the House/Senate tax bills are harmful to US persons overseas.
Previously, Max Reed, a Vancouver tax consultant, expressed the opinion that the November House tax bill is bad news for Canadian citizens deemed to be US persons who have small businesses that are incorporated: see Max Reed article:
Now a second Tax Consultant (Kevyn Nightingale) has come up with the same interpretation of the House/Senate tax bill: In part, a one-time transition tax will be imposed on US persons overseas owning small incorporated businesses.
Like Max Reed, Nightingale feels that the harm in the tax reform proposal was “…not designed to catch individuals (I think), and certainly not Americans abroad – they are collateral damage. it’s incredibly unfair.” and suggests “Americans should call their Congressmen and Senators to complain. Ask that individuals – at least those residing abroad – be exempted from this level of unfair taxation and tremendous complexity.”
Here is Nightingale’s opinion:
“Here’s my commentary on the Senate’s version of tax reform dated November 9, 2017.
The United States is doing tax reform – a good idea for many reasons. The driver is the need to bring US corporate tax rates down, to make the country competitive with others. Also, they’re going to make the US corporate system “territorial”, meaning that most income earned by foreign subsidiaries will no longer be taxable.
To make that change politically palatable, they’re also dropping personal taxes.
But the cost of this is big – trillions of dollars. So legislators have to find some way to limit the revenue loss. They do that by increasing some other taxes.
— Accumulated deferred foreign income
One thing they will do is apply an immediate tax (well, sort of immediate – it’s to be paid over 8 years) to the retained earnings of those foreign subsidiaries. And there’s some logic to this as well. Those earnings have been tax-deferred until now. If they fell into the “exempt” system in future years, US multinationals will have effectively gamed the system by keeping them offshore long enough to completely escape tax. Yes, Congress could have developed rules to tax those earnings as they were eventually repatriated, but that would have been arbitrary, complex, and invited even more gaming of the system. And immediate taxation generates revenue. So this solution is reasonable – in principle.
One problem is that if you’re an American individual, and you own shares in a foreign corporation directly, this provision will create an immediate tax in your hands.
You won’t get a foreign tax credit for the corporate tax (like a US domestic corporate parent). You won’t get a special deduction (like a US domestic corporate parent). You just have to pay tax on the retained earnings.
It’s a double whammy if you live abroad
If you live in a country where it’s common to run a small business through a corporation (say, Canada), you already have enough double-tax issues to worry about (Subpart F, filing forms 5471, FINCEN 114, etc.). This new provision will probably lead to double taxation. And even if you can pay out dividends to limit that, it probably will create extra tax in your country. The US tax probably isn’t creditable in your country (in Canada, it isn’t).
— Global intangible low-taxed income (“GILTI”)
Yeah, isn’t that a giveaway – a foreign tax provision called “guilty”. This is the Senate’s version of the House’s “high-return income” inclusion I blogged about recently.
The ostensible objective is to stop American companies from putting intellectual property in foreign low-tax jurisdictions. That might make some sense. But that’s not how it actually works.
The title is deceiving – it’s not about intangibles. The shareholder (yes, including a US citizen living abroad, in the same country as the company) has to include an amount in his income.
The amount is the company’s total income less a deemed return (10%) on tangible assets. This means that any type of income is caught. Companies that provide services are especially vulnerable, because they typically have only a small amount of tangible assets. Incorporated professionals are going to be hit hard. They’ll be taxed on their companies’ incomes, even if the company doesn’t distribute it to them. And that tax will apply at full tax rates, not qualified dividend rates. And they’ll pay the local (say, Canadian) tax later, when they pay out a dividend.
There are provisions lessening the impact for US domestic corporations (a deduction and a foreign tax credit), but they don’t apply to individuals.
Can this be avoided?
This provision is not designed to catch individuals (I think), and certainly not Americans abroad – they are collateral damage. it’s incredibly unfair.
When I saw the House version, I expected that individuals would be exempted after a sober second (or third) thought. Or at least individuals living abroad would be exempted. But seeing a parallel provision in the Senate version makes me expect the worst.
These provisions are not yet law. Americans should call their Congressmen and Senators to complain. Ask that individuals – at least those residing abroad – be exempted from this level of unfair taxation and tremendous complexity.”
Still nothing about residency-based taxation. In fact, the international corporate tax proposals are going to make things significantly worse for Americans abroad who have corporations. https://t.co/iwdTtaJxDQ
— Kevyn Nightingale (@ustaxcanada) November 17, 2017
RT This article from @USTaxCanada which discusses how U.S. tax reform "may" (get the opposition going) impact #Americansabroad (including Canadian citizens living in Canada who own Canadian Controlled Private Corporations). Bottom line: It's confiscation of your retirement plan! https://t.co/OhskTGJAyj
— Citizenship Lawyer (@ExpatriationLaw) November 17, 2017
https://www.linkedin.com/pulse/american-own-shares-foreign-corporation-get-ready-pain-nightingale/
[Badger asks: “What is with the reverence for or tacit acceptance of US law on Canadian sovereign autonomous soil?”
— One answer: The majority of U.S.-tainted Canadians have answered this question by refusing to accept or revere U.S. IRS compliance.— USCA responds in a comment below with a question “Is there a duty to obey a [foreign, U.S.] law [e.g., the transition tax in House bill] that clearly was NEVER intended to apply to you and can be construed to apply to you ONLY because of the literal wording? That is the question.”]
Beware of the “call of the condor”.
What’s stopping the compliance industry from advocating on the part of their clients? After all, if this is true, it might just put a dent in their business when certain people either stop filing or renounce.
Advice given was to call US politicians and complain. Those affected are Canadians. Why is the Trudeau government actively or passively (sinning against us by omission or commission or both) enabling a foreign country who continues to demonstrate their intent to extend ever growing and unbounded extraterritorial claims to the Canadian-generated, Canadian-sited and Canadian-owned assets of the people they have sworn to represent and have a duty of care towards?
Why is it that those in the compliance industry advise Canadians as if remedy will come from the US. Why would those concerned with homelander votes in the US actually listen to those outside the US when they have already had a front row seat to witness firsthand how FATCA was shoved down our throats, they know very well of the many unconscionable treaty gaps that are gaping and growing in the Canada US tax treaty, the tortured treatment of the Canadian RRSP by the IRS, the limbo of our RDSPs and RESPs, the maltreatment of Canadian mutual funds, the extraterritorial imposition of the ACA investment tax, the extortionate renunciation/relinquishment fees which are basically ransom, etc. etc.
So interesting that regarding US extraterritorial actions, Canadians are continually being told to look for remedy from a foreign extraterritorial power unassisted by their own home government when they are living inside Canada’s borders, with Canadian citizenship or permanent resident status.
Are Canadians and their lawful local assets in Canada just another of the Canadian ‘natural resources’ the Canadian government is willing to squander?
To clarify, this sentence should have read;
“Why would those concerned with homelander votes in the US actually listen to those outside the US? Why would those in the crossborder compliance industry in Canada advise recourse from US politicians when they themselves have already had a front row seat to witness firsthand how FATCA was shoved down our throats in Canada and they know very well of the many unconscionable treaty gaps that are gaping and growing in the Canada US tax treaty, the tortured treatment of the Canadian RRSP by the IRS, the limbo of our RDSPs and RESPs, the maltreatment of Canadian mutual funds, the extraterritorial imposition of the ACA investment tax, the extortionate renunciation/relinquishment fees which are basically ransom, etc. etc.”
Where is the exhortation to the Canadian government to protect Canadians affected by US extraterritorial predations?
The Canadian government should have been exhorted to resist or deny US extraterritorial demands re FATCA rather than capitulate or accommodate.
https://openparliament.ca/committees/finance/41-2/34/max-reed-2/
http://www.mnp.ca/en/posts/fatca-is-not-your-enemy
What is with the reverence for or tacit acceptance of US law on Canadian sovereign autonomous soil?
I think people will simply refuse to pay this. It is outrageous. Some of the CCPCs have been compliant all along. The tax is to make sure the corps that will not be bringing the money back will pay something. If one has already been paying SubpartF all along……..
People who are not in the system will probably do nothing. The ones who are at risk are as usual, the ones who did their best to “do the right thing” i.e., comply. So what does the US do? Make sure they are punished.I wonder how many will also refuse to pay and just dump compliance.
I am not aware that there has been any effort yet, to get an opinion from our spineless government. While I would not expect much, I suppose there is some possibility they will not like the US confiscating money that they want to take more of (the Morneau plan-if that is still an issue? – have not been keeping up much).
I watched a good portion of the House and the Senate markup sessions. What is immediately obvious is that the US govt does not care very much for Homelanders either-it was painful to hear them toss off numbers in the millions of people who would lose their health insurance. As if they were not worthy of any consideration whatsoever. People who make $25k and were penalized because they could not afford Obamacare. Heartless.
Badger, your comments are spot on (as always) but I think the CDN govt has ceased to be the protector of its people and unlikely to “rise to the occasion.”
I wonder-the CDN govt went to such trouble to take in refugees and does so much to make CDNs look like the “good” nation. But really, they are not much better than the US. They probably see the refugees as potential taxpayers and they certainly abandoned us.
@Patricia, I wonder if the Canadian government has ever been an actual protector of the Canadian people where the US was involved. If they ever had been, they wouldn’t have let the US get away with taxing and tormenting those trying to be compliant (both inside and outside Canada) with reporting RRSPs for years, and then knowing all that, letting the tax treaty gaps gape even wider in the face of the IRS refusing to clarify re treatment of TFSAs, RESPs and RDSPs, and then signing onto FATCA and taxing Canadians to pay for its implementation and offense against our Charter and constitution. The Canadian government of whatever stripe -whether CONs or GLibs passively let the US do whatever it likes, or actively colludes with it against the best interests of Canadians.
Anyone who thinks that the Canadian government of either Glib or Con will actually act re the treaty to help us only has to look at how long Canada let the US torment Canadians over legitimate government registered locally held and created RRSPs. See this 2013 history and overview of the US mistreatment of RRSPs;
‘IRS Introduces Two Unique Remedies for U.S. Persons with Unreported Canadian Retirement Plans and Accounts’ January–February 2013
By Hale E. Sheppard, Esq.
https://taxblawg.files.wordpress.com/2013/02/sheppard_intertaxjrnl_2-4-13.pdf
Note the RRSP apparently originated in 1957 (who knew? cause my family had no spare money to invest or save in one anyway, and I never heard of them until sometime decades later, and thought they were a more recent invention). And in 1989, the IRS introduced Rev. Proc. 89-45. Don’t know what other US extraterritorial reporting and rules applied to RRSPs before that, or if the IRS just ignored them. So, from at least 1989 to 2013 the IRS taxed, penalized, and form crimed RRSPs – or at least those brought to their attention. And that is apart from FBARing of them. The FBAR didn’t come along until the 1970 Bank Secrecy Act ( see ‘EVOLUTION OF THE FBAR: WHERE WE WERE, WHERE WE ARE, AND WHY IT MATTERS’ By Hale E. Sheppard http://www.hbtlj.org/v07p1/v07p1_sheppard.pdf ) (so FBARs didn’t exist until long after my family left the US). And the weaponizing of the FBAR via invention of the NON-willful penalty structure didn’t come until FINCEN gave them to the IRS to enforce, and they asked for and received the new penalty in 2003 (?).
Just based on those aspects of US extraterritorial taxation of Canadians, one can see that the Canadian government is unlikely to help us timely or at all.
When was the last time the Canada US treaty was renegotiated – other than the BS pretense cooked up between the US and Canadian governments for sale to the Canadian public that the FATCA IGA was just some kind of insignificant ‘enhancement’ to what was pre-existing?
And as we know, the Canadian government not only did not protect us from FATCA imposed on Canadians which then Finance Minister Flaherty initially rejected ( http://business.financialpost.com/news/read-jim-flahertys-letter-on-americans-in-canada ), they (the Cons and now the Glibs) are now abusing our Charter and constitutional rights using our own Canadian tax money against us to defend a unilateral and non-reciprocal foreign law imposed extraterritorially on Canadians – implemented and enforced at our expense.
As Stephen said recently on another thread, going to court against the Canadian government was the right thing to do. Not only will a win help us with FATCA, but we can hope that it may force the Canadian government to not only not collude so freely with a foreign power against its own citizens, but also shine some much needed light on its repeated failures to actually negotiate a tax treaty that protects Canadians instead of passively or actively allowing the US to widen the treaty gaps to extraterritorially claim even more of our local legal savings and assets and create even more double taxation without remedy or recourse.
What successive federal governments have allowed to happen is a best a sin of omission, and at worst, active commission – choosing to throw some segment of the Canadian public into the gaping maw of the US Treasury as human sacrifices to the US emperor in appeasement or exchange for a trade or other policy goal they hope to achieve.
It really makes me question the whole idea that there is any actual democracy or consent of the governed at all. It appears to me to be more and more a sham, while forces like the financial sector, corporations and political parties sell us what they want us to believe in order to be free to pursue their own selfish interests – using our tax money and our collective assets and national resources to advance their own agendas. That is certainly what has happened with the FATCA IGA. The banks lobbied government for the result they wanted. The powers that be kept the banks apprised behind the scenes even as they kept from us that they had done an about face and were ‘negotiating’ the IGA. The call by Finance for public commentary on the IGA was a joke – buried on a government webpage, and as we know, our comments weren’t shared with Parliamentarians voting on the legislation which was buried in an omnibus bill pushed through by a Con majority.
And Canadians were told by our Canadian representatives to take it up with the US – a foreign country. The Liberals in power don’t tell the softwood lumber industry that do they? Ex. “…In a written statement, Foreign Affairs Minister Chrystia Freeland said Canada will “forcefully defend Canada’s softwood lumber industry.” http://business.financialpost.com/commodities/u-s-softwood-lumber-prices-near-all-time-high-as-canadian-producers-pass-on-slapped-duties-to-u-s-consumers
“The U.S. Department of Commerce’s decision on punitive countervailing and anti-dumping duties against Canada’s softwood lumber producers is unfair, unwarranted, and deeply troubling,” she said…..”. But even though the Chamber of Commerce recently raised FATCA as a NAFTA priority issue they wanted addressed in the NAFTA negotiations (see July 2017 letter to Minister Freeland http://www.occ.ca/wp-content/uploads/2013/05/OCC-NAFTA-Letter-with-CCC-July-2017.pdf ) she and the Glibs remain silent on FATCA – while still pretending that it is defensible and constitutional instead of an obvious discriminatory treatment of certain Canadians based solely on immutable characteristics such as national origin, birthplace, and/or parentage. They’ll defend wood shingles and shakes, but not Canadian families from US predation.
Canada is just a branch plant of the US unless government is willing to actually say no to the emperor’s demands for tribute. Maybe it was the US who actually won the war of 1812, just over two hundred and 5 years later.
What is the Charter worth if the son of the leader of the government that helped bring it into being ( http://www.thecanadianencyclopedia.ca/en/article/canadian-charter-of-rights-and-freedoms/ ) gives lip service to praise it; “…. Charter protects all Canadians ‘even when it is uncomfortable..” http://www.cbc.ca/news/politics/trudeau-omar-khadr-1.4196183 , but in our case, subverts it and defends subverting it ( http://www.adcs-adsc.ca/ ) in the name of the extraterritorial interests of a foreign power ?
What are the words of our Prime Minister ( http://maplesandbox.ca/wp-content/uploads/2015/08/Reply-Trudeau.pdf ) and his government actually worth ( https://www.thestar.com/news/canada/2016/03/30/the-liberal-privacy-campaign-that-died-with-the-election-tim-harper.html https://ipolitics.ca/2016/03/17/trudeau-liberals-reverse-position-on-controversial-irs-information-sharing-deal/ ) ?
Bubblebustin: “What’s stopping the compliance industry from advocating on the part of their clients? After all, if this is true, it might just put a dent in their business when certain people either stop filing or renounce.”
Stop filing and renounce.
It’s necessary to do both.
Stop filing, because when a person files a US tax return they’re acknowdging and accepting that they are subject to US law. They’re signing away their rights.
Renounce, because the minute you renounce, you’re free. Not a year later, or ten years later, but there and then. You walk into the consulate a USC and you walk out legally free.
Eyes on the prize.
badger: “What is with the reverence for or tacit acceptance of US law on Canadian sovereign autonomous soil?”
Exactly. Why accept US law, US/Canadian duals residing in Canada?
Stop filing and renounce.
Patricia Moon: “The ones who are at risk are as usual, the ones who did their best to “do the right thing” i.e., comply.”
It’s not the right thing. It’s what keeps CBT on its feet.
The UN is not going to help. Canada is not going to help. Europe is not going to help. The US Congress is always going to do the opposite of help. If CBT eventually ends, it won’t be due to sympathy for expats.
Courage, corporation owners. Stop filing and renounce. Freedom’s through that door.
North Korea may help, though.
Just a note to all those who had waited for some relief from CBT and are now hoping to renounce before the end of this year.
If you are having problems getting an appointment, and you are able to travel, then you can try emailing any of the US Consulates listed here.
http://isaacbrocksociety.ca/2016/04/07/almost-no-u-s-citizenship-renunciation-appointments-left-during-2016-in-dublin/
Some of us have renounced quickly outside our home countries in places such as Iceland, Mexico, Amsterdam, Luxembourg, Vienna.
Note that if this bill were to be passed without amendment (unlikely), graduate students would also be screwed.
https://mobile.nytimes.com/2017/11/16/opinion/house-tax-bill-graduate-students.html?referer=https://www.google.co.uk/
@Plaxy quoting @Badger writes:
__________________________________________________________________
After having watched the proceedings at both the House Ways and Means Committee and the Senate Finance Committees, I can say with absolute confidence that:
– the members of the these committees don’t even understand how these provisions affect Homeland Americans
– have no consciousness that the USA has “citizenship-based taxation” that would apply to people living outside the United States
– do NOT understand the technicalities of how “territorial taxation” for corporations is being implemented
– have no understanding that there is a “transition tax” and/or that it could possibly apply to the owners of Small Business Corporations living outside the United States.
There is no possibility that the “transition tax” could possibly have been intended to apply to the small business corporations owned by Canadian citizens resident in Canada.
BOTH Mr. Reed and Mr. Nightingale state their views that the application of the “transition tax” to CCPCs is NOT intended; but
The plain wording of Sec. 4004 (by making the statute apply to individual U.S. persons as defined in the subpart F rules which reference back to the definitions in Sec. 7701) means that it would apply to any U.S. citizen (regardless of where he has “escaped to”) anywhere in the world.
Please remember that the U.S. legislators:
– equate citizenship with residence (didn’t you know that a citizen is a resident and a resident may or may not be a citizen)
– don’t know there is a world beyond the USA
– are therefore NOT thinking at all about the application of U.S. law outside the USA
Also, again I make the point that the Internal Revenue Code does NOT anywhere explicitly mandate “citizenship-based taxation” – referring only to “individuals” and then allowing the inference that “individuals” include “citizens”. My point is only that the application of U.S. tax laws outside the USA is not something that is even on the radar in Washington.
Also, to the extent that U.S. laws impact Americans abroad, they are NOT enforced directly by the USA anyway. The USA has downloaded enforcement to the banks and tax compliance professionals. Think about it this way:
FATCA is enforced NOT by the USA directly but by the banks. Yes, your friendly neighborhood bank is a FATCA enforcement agent.
U.S. CBT is enforced ONLY by the compliance industry. If you stay away from the tax professionals you will not be within their “enforcement area” … The ONLY people with U.S. tax problems are those who have attempted U.S. tax compliance. Leaving aside the complicated legal/moral/ethical issues of “to comply or not to comply” (tax compliance people are amoral) the individuals who have been brutalized are those who have attempted compliance. The people who must renounce are those who have complied. Those Americans abroad who want to retain U.S. citizenship do so by NOT attempting compliance.
So, where are we now?
The early commenters from the compliance industry are saying: Bad luck, although NOT intended, this new and exciting instrument of confiscation applies to you. Okay, they should also add to their “news bulletin” that: Because they are compliance “professionals” that they will NOT sign the returns of anybody who does NOT pay this tax.
This poses an interesting question:
What is a poor compliant person, dependent on his tax professional, doesn’t believe this tax applies to him and needs professional help to do? Completing his return (that form 5471 is not easy for an individual to do). Will you let your friendly neighborhood tax professional force you to turn your retirement fund over to the IRS?
The question it seems to me is this:
This is the question that should have been asked in some other interesting contexts which include:
Were the PFIC rules really intended to apply to the Canadian mutual funds owned by Canadian residents?
Were the S. 877A Exit Rules intended to apply to those who clearly relinquished prior to 2004?
Were OVDP and OVDI appropriate compliance options for Americans abroad who have lived for many years outside the USA?
Were the CFC rules intended to apply to Americans abroad, etc. …
Are you going to allow your assets to be confiscated yet again?
When the “Call Of The Condor” becomes the “Law Of The Land”
Neither the IRS nor Congress really know how these laws apply (or not) outside the USA. What happens is that the compliance industry becomes the single most important vehicle for determining how these laws are to be interpreted. Once enough tax people start behaving in a certain way, the others are sure to follow. Put it another way: In general (and I am not referring to either Mr. Reed or Mr. Nightingale) tax professionals know less about this than you do. So, if you call a tax professional and ask:
But, to get back to my original question:
I expect that different people will have different answers to this question. But, I don’t think that the “tax professionals” are worth asking. After all, they can’t sign your returns unless you comply with their interpretation of the law.
I have previously explored this issue in the following comments (which I am including here so that I can find them again later):
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-9/#comment-8045126
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-10/#comment-8046032
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-14/#comment-8049389
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-25/#comment-8053507
And on the compliance choice …
http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/comment-page-16/#comment-8049549
USCA, I mostly agree with your comment, but after seeing the present “tax reform” charade, I would qualify this:
“…the application of U.S. tax laws outside the USA is not something that is even on the radar in Washington.”
with the words “not yet.”
Until recently I took the view as others have done, that a USC had three options: comply, ignore, or renounce.
I would now say that anyone who is complying or has previously complied would be wise to choose between (a) continued compliance, or (b) stop filing and renounce.
The avid search for available money can be expected to continue. They may not be enforcing CBT now, but that could change at any time, and the change could be both retroactive and enforceable.
Those who’ve never complied and don’t use the passport needn’t worry, but those with recent jurats on file with the IRS would be safer to stop filing and renounce, if possible.
@Plaxy
There is NO QUESTION that those who have been filing MUST renounce.
As I have said time after time:
The only Americans abroad who can retain U.S. citizenship are those who are not in the U.S. tax system.
Or those who continue to comply. Some can’t renounce, while for some the benefits of US citizenship may outweigh the disadvantages.
@plaxy
“Do the right thing” was meant sarcastically. If you read anything I have written recently I believe you would know that I do not suggest compliance unless it is only to renounce. Exactly what I did nearly 6 years ago.
And if you have NOT already submitted your fate to the inscrutable mercy of the Eye of Mordor:
To paraphrase Nancy Reagan, JUST SAY NOTHING.
Consider all U.S. Embassies and Consulates as radioactive as Chernobyl or Fukushima – stay well outside their exclusion zones.
Think of your local bank and the CRA as Stasi field offices that somehow fell out of a wormhole.
Regard duplicitous politicians as you would sewer rats: “I don’t hate you – I’m just not necessarily excited about your existence.”
Treat all condors as the Living Spawn of Satan who would defile your parents, siblings, spouses and children for a measly buck.
Live your life day-by-day to the fullest and try not to worry so much about things over which we truly have no control. The system is clearly broken, but are we going to allow it to break us? Hell no.
@ Deckard 1138
You’re back with a fury. Good stuff! i’ve never fed a condor and I never will. I hope as many people as possible will be able to avoid their claws too.
Patricia Moon: Sorry, I expressed myself badly. I apologize for offending you.
To rephrase and elaborate, I was thinking about how some comply only because they believe (without irony) that it’s the right thing to do. They may feel it’s doubly unfair that they, who in their own eyes have tried so hard to do the right thing, should suffer the most. But in reality, they’re perpetuating their own suffering by complying. If they would stop complying and renounce, they’d stop suffering, and in the process help make CBT that little bit less worthwhile for the US.
Not easy for those brought up under US indoctrination to make the mental shift to seeing that not filing IRS returns might be not only more virtuous but actually safer.
@USCA
“The early commenters from the compliance industry are saying: Bad luck, although NOT intended, this new and exciting instrument of confiscation applies to you. Okay, they should also add to their “news bulletin” that: Because they are compliance “professionals” that they will NOT sign the returns of anybody who does NOT pay this tax.”
Should this become law, it will be very interesting to see how this condor’s conundrum plays out with individuals within the compliance industry.
@plaxy
Without getting into details, some of us can’t renounce without inflicting equal or worse damage to our livelihoods than this law would do. Akin to committing suicide to prevent being murdered.
@trish
As mentioned earlier on Brock somewhere, I have a letter addressing this in to the Deputy Director of Tax Policy in Morneau’s office. I suspect I’ll be told that my obligations as a US taxpayer outweigh my rights as a Canadian citizen. At least they are consistent.
BB: as I said, I’m talking about those who are complying only because they think it’s the right thing to do.