What an idiot -does he have any idea what is going on? #FBAR #FATCA #TransitionTax #GILTI doh……Former Hamilton school superintendent pleads guilty to forging documents to get his children U.S. citizenship https://t.co/2dc9RKkViK via @torontostar
— Tricia Moon
Just a little something likely to amuse most Brockers
Really, it boggles the mind……..would appear nothing further reached the Consulate.
Those kids don’t know how lucky they are!Excerpts:
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Author Archives: Patricia Moon
Live Interview with Solomon Yue – Tweet Your Questions, Ideas in Advance!
http://www.thatchannel.com 
Can't make "Live Toronto Event" to discuss end of @citizenshiptax https://t.co/pk6PVMNAKc? @Expatriationlaw interviews @SolomonYue LIVE: Friday Aug. 17 – 11:00 a.m. EST (Toronto) – VIEW it @thatchannel anywhere in the world! Tweet questions to @expatriationlaw in advance and RT! pic.twitter.com/bWFBBPv2Zz
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) August 14, 2018
Reminder – Solomon Yue Visits Toronto
A LIGHT AT THE END OF THE TUNNEL OR ANOTHER ONCOMING TRAIN: THE POSSIBLE END OF U.S. CITIZENSHIP-BASED TAXATION
Solomon Yue, CEO of Republicans Overseas will present publicly shareable information about the TTFI bill, and discuss its progress as it journeys through the legislative process. He will be encouraging AmCham Canada to lend its support in the global effort to encourage Congress to move forward with this legislation. Joined by John Richardson and Elena Hanson
When: Thursday, Aug 16, 2018 – 18:15 to 21:00
Where: St. Michael’s College, Alumni Hall, Room 400; 121 St. Joseph Street,Toronto Ontario M5C 3C2, paid parking near building; nearest subway station is Museum)
Cost: $20 +tax. Pre-registration is required. Registrations due August 13.
If you have any questions about the event, please contact carmina@gathersome-events.com
AmCham Toronto TTFI Event
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Identity Theft, and Social Security Numbers in a CRS and FATCA World
An excerpt from “Identity theft in a #FATCA and #CRS World: The Role Of the U.S. Social Security Number” cross-posted from citizenshipsolutions.ca
This morning I received a fascinating message from a third party who writes:
IDENTITY THEFT, SSN & CRS
With the creation of Social Security in the US after World War II, Americans were issued individual social security numbers for retirement contribution tracking and disbursement purposes. Over time, by convenience and not by design, these social security numbers morphed into national tax ID numbers and the only identification number used in all aspects of Americans’ lives — from getting a driver’s license, buying a car, enrolling in university, opening a bank account, buying health insurance and soon. The list is endless.
The IRS and the Social Security Administration regularly entreat Americans to be careful about to whom, why, and how they reveal their precious SSN. Indeed, identity theft is the fastest growing industry in the US and rarely a day goes by without yet another data breach making headline news (need a list??) or a warning of fake IRS forms (such as the W8-Ben) enticing people to provide private data never asked on those forms.
Europe, on the other hand, provides its nationals with distinct tax ID numbers. No single identifying number can provide access to and take control of all aspects of an individual’s life.
In comes FATCA and CRS.
And what does the IRS and USG compel us to do? Fork over our SSN to FFIs and foreign governments — and their myriad service providers, data bases and servers.
Aside from this requirement’s dubious legality under GDPR, having to fork over one’s SSN is akin to leaving your front door open with a big “Welcome” sign while you go off on holiday.
Americans get to choose between the risk of privacy violations and identity theft and the ability to bank. If they can find a bank that accepts them that is — not one online European bank will accept a client with the slightest whiff of “American-ness”, even if said client is a dual national. Discrimination anyone?
It’s not as if there were no other options and the USG had no CHOICE but to put its citizens at risk. The IRS could issue TIN numbers separate from SSN. Americans abroad could prove their identity with a passport number and show their compliance with redacted FBARs and 8938s. Most FFIs in Europe are not even aware that our SSN is the unique number that controls our lives and understand the Solomon’s dilemma once it is explained to them. Yet they cannot do anything about it, they too are victims of the IRS’ extra-territorial reach.
While we wait for various efforts to reform or repeal FATCA to bear fruit, solving this dangerous conundrum should be simple and SSN numbers must no longer be used.
Conclusion
The U.S. tax compliance industry regards FATCA as “The Gift That Keeps On Giving!”
For Americans Abroad, FATCA is “The Nightmare That Just Keeps Happening!
So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 4 – Conclusion
cross-posted from citizenshipsolutions.ca
Part F – A “U.S. citizen” cannot use a “tax treaty tie breaker” to break U.S. “tax residence”. How then does a “U.S. citizen” cease to be a “U.S. tax resident”?
Q. I am a U.S. citizen. I do not live in the United States. I live in Canada. I am a Canadian citizen. How do I stop being subject to the all of the FBAR and other reporting rules, tax rules (including PFIC), life restrictions and inability to effectively invest and plan for retirement imposed by the Internal Revenue Code?
A. You relinquish U.S. citizenship. Please note that a “renunciation” is one form of “relinquishment”. In general, the date of relinquishment of U.S. citizenship is more important than the form of relinquishment of U.S. citizenship. A Certificate of Loss of Nationality (“CLN”) may or may not (depending on the date of relinquishment) be necessary to cease to be subject to U.S. taxation.
Q. In simple terms, where do I get information about the process of renouncing U.S. citizenship?
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So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 3
cross-posted from citizenshipsolutions.ca
Part D – Different definitions of “tax residence” – Not all countries define “tax residence” in the same way
Q. What is the criteria that different countries use to define who is a “tax resident” of the country?
A. The circumstances that constitute “tax residence” will differ from country to country. Generally speaking “tax residence” is based on definitions of (1) “residency” (deemed and actual), (2) “domicile” and (3) (in the case of the United States and Eritrea) “citizenship”. Note that different countries may define “tax residency” differently.
Q. How can I learn the definition of “tax resident” for the OECD countries?
A. In an earlier post about “OECD tax residency” I referenced the following chart which summarizes the definitions of “tax residency” in OECD countries. (I suggest that you use these definitions as a “start” to your research and not as the “last word”.)
Q. What is the significance of the “OECD” and why does “OECD tax residency” matter?
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So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 2
cross-posted from citizenshipsolutions.ca
Part B – The Combined FATCA/CRS Letter
This letter is particularly worrisome for Canadian residents (whether Canadian citizens or not) who were either born in the United States or are (otherwise) U.S. citizens or U.S. permanent residents (AKA Green Card Holders). Could this mean that they would be required to apply for a U.S. Social Security number?
What follows is a sample letter…
Dear Valued Customer:
We appreciate our relationship with you and we are committed to informing you about matters that affect you. We are writing today to inform you that changes have been made to the Canadian Income Tax Act (Part XVIII and Part XXIX), requiring TD to provide information about customers who have a tax residence in other countries to the Canada Revenue Agency (CRA). The CRA may then share information with other countries through existing provisions and safeguards under the Tax Convention.
To comply with this legislation, we have reviewed our records (eg. address) in order to identify customers who may be residents of other countries for tax purposes.”
Part C – “Tax Residency 101”: It’s about where you should be paying your taxes
In a #FATCA and #CRS world – the most interesting thing about a person is where has @taxresidency ESPECIALLY when he has > one. @Expatriationlaw interview with CPA @1040Abroad: ‘Episode 1 of: "A Tax Residency Primer"- Tax, Residency and #TaxResidency" https://t.co/6swfQmJO7i
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) August 8, 2018
Some Question and Answer …
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So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 1
cross-posted from citizenshipsolutions.ca
So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer
Introduction – So, what’s this “tax residence” stuff about? What does “tax residence” mean?
During the #InvestmentMigrationForum 2018, @ExpatriationLaw discussed multiple #Tax residencies, tax treaties and tax treaty tier breakers in #CRS and #FACTA world. pic.twitter.com/Y3hJ1PlJBz
— IMC (@IMCouncil) August 2, 2018
In 2014, as people started to receive “FATCA letters” I wrote a lengthy post describing “What to do if you receive a FATCA letter“. Information exchange under the Common Reporting Standard “CRS” has begun in 2018. As a result, I am writing this post which is to explain what the CRS is and how it relates to the FATCA letter. It is important to understand that the “CRS letter is actually a combined “CRS/FATCA” letter which is more likely to be received than the original FATCA letter. I urge that those who have received a letter of this type to read this post PRIOR to seeking professional advice!!!
The #OECD Common Reporting Standard combined with @FATCA is forcing people to reveal where they have @taxresidency: "Thousands of bank accounts closed due to foreign information sharing law" https://t.co/aOLhsYFzd0
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 29, 2018
Update on UK Accidental Americans
Back in June we were asked to do a post on the formation of several new Accidental American groups. There seemed to be some confusion as to whether these were “real” groups or just new attempts. Today, while doing something completely different, I came across the UK group and want to make sure this is posted so as many in the UK as possible, will become aware of the work they are doing there.
The FaceBook Page is here. Please check out the Page and “like” it as well as inviting other friends to do the same.
The FaceBook Group is here. This is a closed group. You must ask to join and answer two questions first.
Further, this article was posted on our Media and Blog Articles Open for Comment page but I only noticed one comment. I want to make sure it is seen on a larger scale. There were also some other similar articles:
“Accidental Americans” must be protected from draconian US tax system
Labour MEPs: Time to give accidental Americans their independence from US tax authorities
And last but not least, our colleague Fabien Lehagre has once again managed to get media and government attention on the plight of French Accidentals Macron Backs Accidental Americans . Truly outstanding effort and results – great stuff Fabien!
If anyone knows anything further concerning the new Accidental American groups in Ireland Italy or Poland could you please update us with a comment or ask one of our admins to do it for you? Thanks.
Two Programs with Solomon Yue in Toronto August 12 & August 16, 2018
In addition the meeting mentioned below, we would like to have a second, more informal program for expats and their families and friends. This format would be a more intimate question and answer which will be focused on individuals subject to the CBT regime. This would take place on Sunday, August 12, from 2:00 – 4:00 pm on the U of T campus. We need a confirmed number of individuals before booking a room. If you are interested, please email nobledreamer16 at gmail dot com Cost: $20
A LIGHT AT THE END OF THE TUNNEL OR ANOTHER ONCOMING TRAIN: THE POSSIBLE END OF U.S. CITIZENSHIP-BASED TAXATION
If you are an American citizen residing and doing business in Canada, you bear the pain of the heavy tax burden endured by all U.S. citizens due to the fact that the U.S. is the only major country that imposes worldwide taxation on its citizens no matter whether they live in the U.S. or in another country. In addition, the U.S. imposes significant penalty laden reporting requirements on U.S. citizens living in Canada and abroad.
Change is a possibility.
Did you know that there is a possibility that the U.S. Congress may introduce, debate and vote upon a bill that may ease this worldwide taxation burden on U.S. citizens living and working in Canada? This bill would enact ‘Territorial Taxation for Individuals (TTFI)’. It is a tax cut for 9 million overseas Americans by ending double taxation.
Solomon Yue, CEO of Republicans Overseas has been involved with drafting the TTFI bill. Mr. Yue, who is currently working with AmChams throughout the world, will present publicly shareable information about the TTFI bill, and discuss its progress as it journeys through the legislative process. He will be encouraging AmCham Canada to lend its support in the global effort to encourage Congress to move forward with this legislation.
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