Author Archives: recalcitrantexpat

Look who is getting into America’s banking system now.

http://ca.news.yahoo.com/3-big-chinese-banks-enter-us-banking-market-185200086.html

I have been thinking about the IRS concept of Horizontal Equity and it has occurred to me that Horizontal Equity actually attempts to do something that the U.S. tax code has never claimed as one of its goals, and that is to “equalize outcomes” for all taxpayers.  The U.S. income tax system has always publicly been portrayed by the politicians as being a “progressive” tax system. A progressive tax system places the burden of income taxation on those citizens who have increasingly higher outcomes while putting little to no tax burden on those with lower incomes.  Having a tax system that varies the amount of income tax charged by using income as the guide for collecting tax is much different from having a tax principle that attempts to guarantee equality of outcome or assure that everyone strictly has access to only the same taxation rules without regards to differing circumstances.

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Well today one of my children was able to renounce U.S. citizenship.  The monkey of U.S. citizenship is now off the back of one more Canadian citizen.

I am watching the Public Broadcasting, NewsHour show, and they are going to have a segment on the U.S. lecturing China about what it says are its Human Rights violations. Now to me it seems most ironic that the U.S. on the one hand tells the other nations of the world that they do not have the right to tell the U.S. how to treat it’s citizens but yet the U.S. is always lecturing other nations on how to treat their citizens.

Those of you who, as I did, may have received a letter from Canada’s Minister of Finance, the Honorable J. Flaherty, will remember that inside the body of the letter that the minister’s way of distancing Canada from the IRS problem, was that Canada will not tell the U.S. how to tax its citizens. Well as far as I am concerned that hands off position is a bunch of crap. Canada has good legal grounds upon which to oppose the U.S. practise of citizenship based taxation. I believe that it has at least the law of “precedent” on its side because the U.S. has for so long ignored enforcement of this law and enforcement of FBAR filings. Certainly those who renounced before 1986 have a legitimate Human Rights complaint and Canada, as their representative, needs to take their case to the U.N. or the World Court.

Let the unjust U.S. laws see the light of day!

So the U.S. wants to impose a 30% withholding penalty on the U.S. source payments of; interest, dividends and securities transactions that are conducted by non FATCA compliant Foreign Financial Institutions and recalcitrant account holders. Now of course the question is, what happens if there is a mistake that is made by the U.S.? Will you get your money back? I believe that the short answer to that question is, no one knows. What the U.S. may promise to do and what it ends up doing are often two different things. From what I have observed of U.S. policy is that when it comes to returning ill-gotten gains the U.S. doesn’t give everything back. A case in point is the softwood lumber dispute.

In the softwood lumber agreement that was reached between Canada and the U.S. the U.S. only agreed to give back 80% of what it had collected. Now why would you as an investor take a chance that 30% of your rightful financial property could be withheld? What would it cost you in time and effort to get the money that is rightfully yours? What is to stop the U.S. from using this 30% withholding requirement as a means to fund its failed government fiscal policies?

http://www.cbc.ca/news/background/softwood_lumber/

As a person who is not a U.S. citizen this whole legislation introduces a new degree of risk without any financial return possible so why would you expose your precious capital to such a ruinous outcome? With FATCA and of citizenship based taxation the U.S. has just found another way to cripple world capital markets by introducing more regulation and risk. Neither of which will generate a dollar in wealth.

As of the latest figures there are deemed to be 196 countries in the world. Now because of U.S. based taxation and the Foreign Account Tax Compliance Act, U.S. citizens will be unable to live and work in all but one of those countries the U.S.

It is forbidden by the U.S. government that it’s non-resident citizens be allowed to live the same lives as those of their compatriots.  How this cannot be seen as a violation of the Human Rights of U.S. citizens by the U.S. government is hard to fathom. When restrictions on your life abroad are so onerous as to discourage you from seeking to live outside of the jurisdiction of the land of your birth then surely you are the victim of oppression.

http://rendezvous.blogs.nytimes.com/2012/04/16/americans-the-tax-man-cometh-wherever-you-are/

I was just at the above link, where Steven Mopsick’s comment was, and I could not find any of the comments that had been left. Thinking that maybe there was an error with the page loading I refreshed my screen several times but they never appeared. Does anyone know what could be the reason? Does anyone possibly know whether the comments were still up yesterday? Is there a policy on the length of time that comments are displayed?

http://www.thefloridanewsjournal.com/2012/04/10/miami-marlins-coach-ozzie-guillen-suspended-after-complementing-fidel-castro-and-saying-h

If this man or anyone in America loves Fidel Castro why isn’t he allowed to say so without there being an uproar? Doesn’t America believe in freedom of speech? Secondly why should anyone care about what is said about politics by a man whose life is coaching grown men to play a child’s game? What kind of an apology is it when it is given under duress? How is this any different then when a terrorist group forces a U.S. hostage to make a video denouncing America?

When you consider that America has diplomatic relations with many other governments that are ruled by more unsavory characters then it seems apparent that America’s obsession with destablizing Cuba is irrational and should be an embarrassment to the nation.

Estimated world population as of Oct. 31, 2011    7 billion

Estimated population of the U.S. for 2012             313,281,000

Estimated number of U.S. citizens living abroad  6 million

Estimated costs to administer FATCA and chase those 6 million- billions of dollars forever. Net benefit to be derived at the best is most likely zero but is more than likely to be negative because the taxes collected are not likely to ever exceed the cost of FATCA compliance.  Of course we will never know because the U.S. very conveniently refuses to establish any criteria for costs calculation.