Liberty and justice for all United States persons abroad

The Isaac Brock Society

Monthly Archives: August 2018

“Business is Going Great: My Customers are Good as Dead” Says Black Marketeer

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Good As Dead
Good As Dead

“…. and the US government is my best business promoter”

“I’m livin’ high on the hog”, says Blackie the Black marketer in my followup interview. “I’m selling non-US citizenship like hotcakes…..I can’t keep up with demand.

Some of you might remember that I interviewed Blackie years back, when President Obama had hiked the fee to $400 for renouncing U.S. citizenship. Blackie had established a business selling fake Certificates of Loss Of (United States) Nationality (CLN), after the fake-American-passport business had dried up.

Not long after that, demand for non-citizenship was so high that President Obama hiked the fee again to $2350. “The business model I started based on $400 competition skyrocketed when the fee went to $2350” explains Blackie. “Whereas the president was marketing a product at the $2350 level, I undercut it and gave them the same paper at a fraction of that price”

“I’ve been able to make this into a full-blown enterprise, with employees…I even hire marketing consultants to analyze my market segments and give me tips for where to go next” he explains.
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German Foreign Minister Calls for an Independent EU “SWIFT” System

Posted on by Posted in Issues regarding US persons abroad 24 Comments

Update 27 August 2018

For anyone interested in more details about this development please see: here
and here
Hat tip to Tim Smyth

interesting: One of the factors irritating to the EU is the “repatriations of billions of dollars in profit from Europe by U.S. based tech giants” (Bloomberg) an outcome of course, from recent U.S. tax reform (TTFC)
*******

I have become fascinated by an ongoing development in Europe stemming from Trump’s actions against Iran. First, there is the United States pulling out of the Joint Comprehensive Plan of Action
JCPOA, (aka the Iran nuclear deal in which Iran promised to stop development of its nuclear program in return for a lessening of sanctions and increased trade relations). After the withdrawal, Trump issued harsh sanctions against Iran.
 
Over the last couple days, a number of expats have tweeted/posted a
condensed version of this story. I was curious know more about it.

On August 21, German Foreign Minister Heiko Maas wrote an editorial for the German paper, the Handsblatt. He called for a “balanced partnership” as counterweight to the US actions regarding Iran.
 

At first, this might seem completely unrelated to our situation however, one aspect of this “Balanced Partnership” may include an option for trading outside of the U.S. SWIFT system.
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Why Is Bank of America Asking Clients About Their Citizenship?

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info citizenship

from The Nation

Interesting that FATCA, which predates CRS is not mentioned here.If the U.S. were interested in reciprocity, wouldn’t this be the focus? In fact, this is not FATCA or CRS. It is plain and simple discrimination. If the U.S. continues making the U.S.an unwelcome place for immigrants, we may no longer have to listen to the nonsense that our leaving is irrelevant due to the much larger numbers of people clamoring to get into the United States of America.

Excerpts:

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Speculate on the percentage (85%? 5%?) of Canadian citizen-residents, deemed by U.S. to be U.S. citizens — who do not have, accept, or want, any meaningful relationship with the U.S.?

Posted on by Posted in Law & Morality 93 Comments

Many responses, but only a few have tried to answer this question:

What do you speculate is the percentage of Canadian citizens, resident in Canada, who are deemed by the United States to be U.S. citizens who:

— have NO meaningful relationship with the United States (e.g., no passport [unless demanded by U.S. border guard], no U.S. voting, no IRS filing, consider themselves only to be Canadians and not Americans) and do not want to be an American)

Most readers won’t speculate, but Portland (below) speculates that that percentage is around 85%, a very large percentage.

Is that percentage likely to be correct? No? 5% is a better estimate?

Former Hamilton school superintendent pleads guilty to forging documents to get his children U.S. citizenship

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Brock project: Comparing the comments on the French version of the @LizT1 @USTransitionTax article to the comments on the English version

Posted on by Posted in Issues regarding US persons abroad, Tax Residency, Tax Treaties, Transition Tax 9 Comments

Reference to the English version of Elizabeth Thompson’s recent article on the U.S. Transition Tax was posted here. A person in Europe found the French version and forwarded it.

The French version has far fewer comments. But, I thought it would be interesting to perhaps do a bit of translation and see if they are as ridiculous as the majority of the comments on the English version.

Live Interview with Solomon Yue – Tweet Your Questions, Ideas in Advance!

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http://www.thatchannel.com that channel graphic for interview
 
 
 
 
 
 
 

More about the @USTransitionTax issue from @LizT1: Finance Minister Morneau responds (sort of)

Posted on by Posted in Accidental Americans, Canadian Government, Issues regarding US persons abroad, Tax Treaties, Transition Tax 14 Comments

Following up from yesterday’s CBC article by Elizabeth Thompson, CBC has today published a shorter article describing Mr. Morneau’s response or non-response (whatever the case may be) to the “transition tax”. Her article begins:

The Canadian government is talking to the U.S. government about the impact a retroactive tax signed into law by U.S. President Donald Trump is having north of the border, Finance Minister Bill Morneau revealed Monday.

Speaking to reporters in Windsor, Ontario, Morneau said he is aware that some of the U.S. government’s tax changes affect Canadian residents with U.S. or dual citizenship.

It is, at the end of the day, going to be up to them to manage their own tax code.
– Finance Minister Bill Morneau
“We’re continuing to consult with Americans to make sure that we fully represent the challenges that these changes have made for Americans or dual citizens living in Canada,” Morneau said. “That’s an ongoing process. We certainly hope that we can make progress.”

Here is Mr. Morneau in the Q and A:

The comments (at least so far) reflect the difficulty of understanding the issue.

Nevertheless, this is significant because it is now clear that the Trudeau Government is well aware of the “transition/repatriation tax” and its effect on Canadians. This is good news.

And across the ocean and and the question of legislative change …

The following message appeared from Lawyer Monte Silver:

Americans Abroad with small businesses subject to Repatriation/GILTI taxes:

To get an exemption for American small businesses abroad from the Repatriation tax, last month we focused on Senator Cassidy of Louisiana who volunteered to assist. It worked and we have a draft bill in hand.

Now we focus on Ohio Senator Portman for a bill exempting us from GILTI. Portman responded and wants to speak to Americans abroad impacted by GILTI. If you or someone you know owns a small business abroad and is impacted by GILTI – or the Repatriation tax, IT IS URGENT THAT YOU CONTACT ME BY PRIVATE MESSAGE OR AT MS@SILVERCOLAW.COM

Another article by @LizT1 about the @USTransitionTax – Just when you thought it couldn’t get worse!

Posted on by Posted in Issues regarding US persons abroad, Non Resident Taxation, Tax Treaties, Transition Tax, TTFI 28 Comments

Another good article by the Elizabeth Thompson. It would appear that compliance with the “transition tax” is getting more and more difficult. The article begins with:

Thousands of Canadian residents hit hard by a retroactive tax signed into law by U.S. President Donald Trump have been dealt another blow, CBC News has learned.

Newly proposed regulations issued by the U.S. Treasury Department and the Internal Revenue Service threaten to increase their tax hit.

“You have to almost empty out your company and pay a lot of Canadian tax to avoid the U.S. tax,” said Kevyn Nightingale, a partner with the accounting firm MNP.

Interestingly, Ms. Thompson does reference the Solomon Yue American Chamber of Commerce meeting this Thursday August 16 in Toronto.

The comments seem less vicious today (at least so far).