FATCA and Australia – Part 1 of 2

1,187 thoughts on “FATCA and Australia – Part 1 of 2”

1. Good letter

   © 2016 Atlantic Insight

   An Open Letter to the United States Government on citizenship based taxation
   February 25, 2016
   To the President, Secretary of State and members of Congress of the United States of America,

   Being a U.S. citizen should be a privilege. Citizens should expect the US to be a country that values the idea of its citizens living all over the world and acting as ambassadors for a country that protects its citizens abroad as opposed to complicating their lives.

   However, being an American has become a handicap if living abroad. The U.S.’ actions when it comes to requiring financial reporting on worldwide income and taxing Americans abroad even when the only connection they have to the country is a passport are simply wrong. The U.S.’ double taxation policy aims to make Americans pay the same amount of tax as if they were living in the U.S. and speaks to an embarrassing problem: the U.S. government’s indifference to Americans living abroad. It speaks to an injustice that can no longer be left undiscussed and that has resulted in Americans renouncing their citizenships all over the world in record numbers.

   Dealing with U.S. tax returns is such a complicated task that people need to hire expensive consultants for help, when they are already filing tax returns in their country of residence. In addition many foreign banks simply will not open accounts for U.S. citizens and strict limits are placed on the securities that Americans can invest in from abroad. Keeping such tabs on citizens living abroad and placing such limits on what they may do with their own capital seems like the height of hypocrisy coming from the country that claims to be the champion of freedom and capitalism.

   Our understanding is that the U.S. was largely built on doing what is right and on fighting injustice – the Boston Tea Party illustrates this point well. In renouncing citizenship, former Americans are not being anti-American, they are protesting an injustice. That, in our opinion, is the most American action a person can take. The reason the author of this letter renounced his citizenship is exactly that.

   A strong interest in U.S. politics and foreign policy has shown us that the U.S. is capable of doing many great things but often fails to question its own actions. Americans who renounce their citizenship are not anti-American and deserve no criticism for taking this action. The U.S. government is to blame for requiring mountains of information from its citizens abroad, for taking their money even though they derive no benefit from the services that taxes are directed towards and for having an incomperehensible tax code.

   We understand that reporting worldwide income is aimed at preventing American citizens in the country from hiding large amounts of assets abroad but American citizens who reside abroad and are only connected to the U.S. by their passport have become casualities of this policy.

   Ladies and Gentlemen, we respectfully write this letter to say that it is time to right a wrong. It is time for American citizens living abroad to be treated fairly. Finally, it is time for the U.S. to hear the protests of renunciants and to repeal an unfair policy that no other country in the world has – apart from Eritrea.

   We urge you to offer your support and protection to Americans who do not live in the United States. They deserve to be treated fairly and not to be put in a situation that makes them want to renounce the citizenship of a country that has achieved so many great things.

2. Re letter: (yes a good one)

   are not being anti-American, they are protesting an injustice

   They are protesting anti-American laws.

3. Mr Obama previous to your election you said you would look into expat tax I would ask that you fix this problem as one of the memorable acts that presidents are known for when leaving office. (above letter to all 4 addresses in 2 parts)

   Submit Your Comments and Questions Online
   President Obama is committed to creating the most open and accessible administration in American history. To send questions, comments, concerns, or well-wishes to the President or his staff, please use the form below.

   https://www.whitehouse.gov/contact#more

   Anyone else ?

4. Called http://www.andrewhastie.com.au/contact-0
   (08) 9390 1211
   Secretary informed me the first call she received regarding this matter
   May be worth a call

5. Niels (ex ambassador) is door knocking and working hard for us with a delegation in US talking to Senators and Obama administration.

   Below is an exert from his newsletter

   Feel free to email him and put up your comments on his efforts I will remind him of our link

   A Message from the CEO
   Niels Marquardt, CEO, American Chamber of Commerce

   This month I am writing to you from the belly of the beast – Washington DC – where our annual Washington Doorknock has just begun. Here at the epicentre of the US political machine, we are meeting with the Obama Administration and leading think tanks to highlight the trade, tax and investment issues that matter most to our members. In particular, we are here to lobby Congress to ratify the Trans-Pacific Partnership (TPP). Despite an abundance of anti-trade rhetoric on the US campaign trail, it is difficult to overstate the importance of securing passage this year of the TPP for Australia’s – and indeed the region’s – economic future. As Australia’s Ambassador to the United States, Joe Hockey, remarked in a recent speech , “like the United States, we’re a nation whose prosperity has been built on free, open markets and participation in global commerce.”

   Ambassador Hockey goes on to say, “In this, the business sector has a crucial role to play. The strong voice of business and industry needs to be heard, highlighting the benefits and break-throughs the TPP will deliver. TPP needs business to champion the deal, fearlessly, because they’re the beneficiaries and their shareholders and employees are the beneficiaries. Advocacy from the private sector will be instrumental in convincing the public and their elected representatives that this deal will have a positive impact on jobs and the economy.” Let me go a step further and ask – no implore! – each of you to push your global CEOs to make a few phone calls to key American lawmakers like Speaker Paul Ryan, Ways & Means Chairman Brady, Senators McConnell, Hatch, and Wyden, or others who relate to your business. Your CEO should implore them each to bring TPP to a vote by the end of the year. As we get more clarity on when and how the vote will be organised, AmCham will have further advice to offer. But we already know that letters to lawmakers are ineffective; you must call if you are serious about having an impact!

   Meanwhile, there’s no escaping the fact here in Washington that the US election cycle has well and truly kicked into a higher gear. The ascendance of Donald Trump to the Republican candidacy has many investors spooked and is spawning jokes about Americans fleeing to safe havens like Australia. Yet in an interesting twist, it turns out the record numbers of expats renouncing their US citizenship are doing so due to tough federal reporting requirements and penalties for assets held overseas by US citizens, as well as the generally onerous tax arrangements that uniquely affect Americans abroad. This is because of America’s unique position among OECD nations in taxing the global income of its citizens – not just what they earn from American sources. AmCham’s response is to call for a territorial tax system like that of every other advanced economy. Furthermore, under US regulations “FATCA “, foreign banks must report to the US whether their clients are US citizens – assuming they don’t just stop allowing Americans to open accounts, as some banks have done, just to avoid the burden of compliance. While we understand and support the goal of preventing tax avoidance, the overreach is significant and the negative impact on Americans overseas is becoming, for many expats, an unbearable burden. AmCham is arguing this week in Washington that US law should favour, not discourage, the robust participation of Americans in the global economy, including by repealing FATCA and adopting a territorial tax system.

   Another factor that is central to future prosperity, both in Australia and the United States, is innovation. Indeed, the SelectUSA Investment Summit that concludes today here in Washington has had a strong focus on the role of innovation in boosting economic growth in advanced economies such as ours. I was honoured to lead the Australian delegation to SelectUSA, which included more than a dozen companies seeking to expand into the US. We have had great access to US leadership, including hearing President Obama speak at lunch yesterday!

   Here at AmCham, we are continuing to champion this innovation agenda through a range of initiatives, especially our annual Innovation Mission to the USA. From 30 October – 4 November, we will visit major players in Seattle and Silicon Valley such as Microsoft, Amazon, Boeing, and HP Inc. Don’t miss your chance to join our delegation this year! We are also planning an “Innovation Mission around Melbourne” on October 6 which you are encouraged to join! Meanwhile, it is encouraging to hear of other organisations who are also working to advance Australia’s national innovation agenda. One such organisation is AVCAL, a soulmate on innovation issues whose message is very similar to our own. AVCAL’s compelling policy blueprint on funding the ‘next wave’ of economic transition through innovation is well worth reading, and is available here.

   On the home front, we have many other exciting events coming up right around the country. In Melbourne, Ahmed Fahour, CEO of Australia Post will present on 10 August. We also have some high-profile speakers lined up in Sydney: David Rohrsheim, Uber Australia’s General Manager on 22 July, and a terrific panel event on Reducing the Risk of Cyber Compromise on 28 July . Everyone interested in the disruption phenomenon must come hear what David has to say! In Perth, we have Mary Hackett of GE Oil and Gas on 21 July. Adelaide is bringing you a panel event on Healthcare on 1 July. In Brisbane on June 24 we have a discussion on Sustainability and the Future of Natural Gas with an outstanding expert panel including AmCham Director Page Maxson. Last but not least, who could forget our annual Fourth of July celebrations, which will be held in Sydney and Melbourne again this year. Check out our website http://www.amcham.com.au for the full list of upcoming events.

   Since my last message, we are pleased to welcome the following new members on board: Artes Data Solutions Group, eBay Australia & New Zealand, Power Cantwell Pty Ltd, Redshift Consulting, Talent International, MAW Action Pty Ltd and Veracity Worldwide. Please view our newest members here. If you are not already a member of AmCham, now is the time to join and increase your access to opportunity for 2016.

   AmCham are now producing and publishing more relevant and interesting content than ever before. We encourage you to view the Access BLOG and get to know us socially on Twitter, LinkedIn and Facebook! We also have a number of LinkedIn Groups for AmCham’s various Committees, publishing informative content on a range of topical policy issues. Plus, check out the expanding library of podcasts on http://www.amcham.com.au, featuring many CEOs and MDs of a range of AmCham member companies.

   Until next time,

   Niels Marquardt
   nielsmarquardt@amcham.com.au

   Follow me on twitter: @CEO_AmChamAU

   P.S. If you would like to increase your access to opportunities, information and services of the Chamber, please select this link and AmCham will send you more updates with information about upcoming events, programmes and initiatives in your state.

7. Also sent to Senators on list

   more Senators

   http://www.ctvia.org/index.cfm?folder=175&open=0&doc=252

8. Interesting

   http://www.yourpension.com.au/pension-calculator.html

9. Contrasting Scott Morrison “ScoMo” and Boris Johnson “BoJo”

   Retweets welcome:

   https://twitter.com/JCDoubleTaxed/status/746505855156248576

10. Hastie is a know-nothing who was spliced into a seat because the previous MP had a heart attack & died.

    He is a LNP boy, through & through. I’m not thrilled with a guy who tries to score votes using his military outfit on posters whilst campaigning, when he knows fully-well that it is NOT allowed. He was asked by the Army not to, ignored them (why follow principles when you’re already guaranteed the job?). He’s a typical opportunist.

    http://i.imgur.com/tCnKS5l.jpg

11. @Jane – He is a person of interest as he has a US person wife (only MP with US person spouse?), and can be outspoken. I’ll add to complaints listed: he does not have a Twitter account.

12. When is OUR treaty fixing Superannuation TWENTY THREE years ago going to happen ?

    This last week I believe ISRAEL tax treaty talks commenced in Australia

    Three treaties with Israel: on Industrial Research and Development; collaboration in Science and Technology, which will place innovation at the centre of Australia’s transitioning economy; and a double tax agreement that will provide greater certainty for investment and enhance the integrity of both countries’ taxation systems.

    http://www.aijac.org.au/news/article/head-to-head-1

13. ASK
    taxtreatiesunit_consultation@treasury.gov.au

14. http://www.hallandwilcox.com.au/israel-and-australia-double-tax-agreement/

    The Australian government believes that there are opportunities for Australian companies to take greater advantage of Israel’s knowledge-based economy,

    http://www.taxinstitute.com.au/news/australia-israel-double-tax-agreement

    Ask them too
    tti@taxinstitute.com.au

15. New comment on The Isaac Brock Society

    badger commented on Australia: Dealing with Superannuation.

    in response to Petros:

    Dealing with Australian Superannuation has come up frequently at Brock, sometimes on the FATCA and Australia page and sometimes on various other threads. JakDac suggested we have a post for this specific topic, so people can post helpful information (or ask questions) on Superannuation in one location, so people won’t have to search throughout the […]

    @all, I don’t know anything about Australian superannuations, so not attempting to weigh in, but I try to post what looks like useful stuff when I see it. Wise to be wary of the sources out there and doublecheck against other info if and when possible. This has tended to be a reliable source for info over the years, and he has at some points invited people to send questions on various issues he was blogging about. For ex. http://hodgen.com/noncovered-expatriates-and-superannuations/

    (The other info I found and posted earlier re Australian Superannuations and IRS confusion about them was the info a US law practice obtained via FOIA http://isaacbrocksociety.ca/2016/05/15/australia-dealing-with-superannuation/comment-page-1/#comment-7548369
    http://isaacbrocksociety.ca/2016/05/15/australia-dealing-with-superannuation/comment-page-1/#comment-7548376 )

    Reply Comments

16. About a year ago NO reply feel like asking ? tony_coughlan@finance.senate.gov

    Thank you. We appreciate knowing you read our report and agreed with it. Chairman Hatch is very committed to an overhaul of the US international tax rules. We are spending considerable time working on it, and we surely hope we can succeed.

    Kind regards,

    J. Anthony Coughlan
    Tax Counsel
    U.S. Senate Finance Committee, Republican Staff
    Senator Orrin G. Hatch (Utah), Chairman
    219 Dirksen Senate Office Building
    Washington, D.C. 20510-

    __________________________________________________________________
    Read our report and agreed with it ?
    I do NOT agree with the minimal amount of effort within the report (section F) .This gives NO solutions for 8.7 million ExPat Americans whom are under much duress physically, mentally,financially etc. This is affecting marriages, bank accounts people are crying giving up citizenship of a country they have fond memories of. Remember your forefathers broke away from Britain because of UNFAIR taxation. The US is the ONLY westernised country using CBT, We have come a long way since the horse and carts of the Civil War. Relationships and newer and better planes takes settlers to new countries. Engelbert had it right “Please release me let me go” (re taxation). Please give feedback regarding this SPECIFIC concern as reflected in 75% of the International (and a fair amount of the INDIVIDUAL ) tax submissions received. Frankly the answer we got reflects what some people are putting to the section reference F (guess the rest)

    Please help this has been known to the government for many many years along with previous submissions

    Fingers crossed

    US international tax rules ? The ones relating to EXPATS not just business . Am I correct that on your web site we may find hearings related specifically to this issue ?

17. WSJ /PENSIONS

    Hey American Abroad, Do You Really Want to Make that Pension Contribution?
    Six key questions every U.S. expat should ask before contributing to a foreign pension plan

    By DAVID KUENZI
    May 31, 2016 5:20 am ET
    9 COMMENTS
    American workers are constantly fed the mantra of retirement savings: “Max out your 401k or IRA contributions.” Tax deferral and company matches make this generally sound advice. For Americans abroad, however, this simple equation often leads to disastrous U.S. tax complications when applied to foreign pension plans.

    America’s system of citizenship-based taxation usually doesn’t treat favorably standard employer pension plans in most foreign countries. So Americans abroad must tread very carefully when it comes to deciding whether or not to participate in these plans. Below are the six most important questions every American expat must be able to answer in order to make effective decisions about participating in a pension plan while residing abroad.

    MORE IN PENSIONS

    Expat Estate Planning: A Tragedy Prompts Adviser to Weigh In
    Expat in the U.S.? Tips for Avoiding Tax and Investment Stumbles
    The Expat Guide to U.S. Personal Finance
    Personal Finance Tips for Americans Considering Retiring Overseas
    Tax Traps & Retirement Planning Opportunities for American Entrepreneurs Abroad
    Does the U.S. have a double tax treaty with my country of residence that covers pensions?

    Advertisement

    The U.S. has double tax treaties with more than 70 countries. Some of these treaties provide comprehensive agreements to mutually “qualify” the other country’s system of employer-sponsored pension plans. That is, each government respects the tax benefits and structure of the other country’s plans. Modern tax treaties with countries such as Canada, the U.K. and Germany fully qualify the other country’s employer-pension system. Therefore, participation by Americans is generally tax-wise and not excessively complicated. With other countries (e.g. Spain, or France, or Australia), older tax treaties provide limited agreement concerning how to treat pension plans in the other country. In these countries, Americans participating in local plans will need very sophisticated tax advice regarding how to report their local pension plan on a U.S. tax return. In countries without treaties (for example, Hong Kong, Brazil, Singapore) voluntary participation in local pension plans is ill-advised. The U.S. will not recognize the pension as qualified, and participation often triggers complex U.S. reporting requirements and punitive tax rates.

    Will the local tax benefits of participation simply result in a bigger U.S. tax bill?

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    In some cases (Spain and Switzerland, for example), local income tax rates can be lower than U.S. tax rates. In these cases, contributing to a locally qualified pension reduces local taxable income and lowers the local tax bill. However, reducing the local tax bill will likely reduce the available foreign tax credit and conversely raise the corresponding U.S. tax liability, thereby negating the purpose of participating in a pension plan. This happens when plan contributions cannot be deducted from U.S. taxable income, because there is no treaty clause providing a U.S. tax deduction for local pension contributions. This is one of many ways that a local tax benefit is cancelled out by America’s insistence on citizenship-based taxation.

    Will my pension plan be treated as a foreign grantor trust for U.S. tax purposes?

    Although this question may sound very technical, it is critical if you choose to roll foreign employer pension assets into a self-directed pension plan (as is common in the U.K. with self-invested pension plans—SIPPs—and in Australia with self-managed superannuation funds) or set up a self-directed pension plan in a country where there is no treaty provision that “qualifies” such plans. Generally, once the employee begins to self-manage pension assets, the plan becomes a “grantor trust” and can trigger nasty U.S. reporting requirements, including filing an annual Foreign Trust Report (IRS Form 3520) and reporting the underlying investments as Passive Foreign Investment Companies (PFICs) on IRS Form 8621. These annual requirements are complex and result in punitive taxation and should be avoided at all costs.

    Do Malta pension schemes provide a superior alternative pension platform for Americans abroad?

    Malta-based pension plans are widely marketed to Americans as a solution to their foreign pension problems. Plan sponsors claim that the U.S.-Malta Double Taxation Treaty provides unique tax benefits for Americans participating in Malta pension plans. Unfortunately, these claims are untested and are unlikely to survive IRS scrutiny. Most importantly, the treaty only covers Americans residing in Malta making their distribution to Americans globally especially dubious.

    Do my U.S. retirement accounts create a local tax reporting problem?

    Just as the U.S. may not provide preferred treatment for your country of residence pension plan, your U.S. retirement accounts may be treated punitively in your country of residence. A few countries tax only locally sourced income (Hong Kong, for example), so U.S. retirement accounts are generally not a problem in these countries. Many countries will tax residents on their worldwide income but still recognize the principle of tax deferral within a U.S. qualified plan. A few countries (such as the U.K. or Canada) may treat U.S. plan assets and contributions as qualified, thereby recognizing both the deductibility of contributions and tax deferral on income within the plan.

    Are IRA and 401k contributions permitted while I am living abroad?

    Generally, IRA (and 401k) contributions by American taxpayers living abroad are allowed by U.S. rules. The catch is, however, that contributions must be made from non-excluded earned income. Therefore, if your foreign wages are below the U.S. Foreign Earned Income Exclusion threshold of $101,300 and you are claiming the exclusion, contributions are not allowed because all income has been excluded. Be careful, however. Contributing to a U.S. pension plan while resident in a high tax country may inadvertently result in double taxation. This happens when no tax benefit accrues from the contribution but distributions during retirement will still be taxed.

    David Kuenzi is the founder of U.S.-based Thun Financial Advisors, which specializes in cross-border investing and financial planning for U.S. and non-U.S. investors.

    Share this:
    DAVID KUENZI DOUBLE TAX TREATY FOREIGN PENSIONS IRS IRS FORM 8621 MALTA PENSIONS PENSION PLANNING PENSIONS PERSONAL FINANCE PFICS THUN
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    There are 9 comments.
    Newest
    OldestReader RecommendedJOHN M PETERSON
    JOHN M PETERSON Jun 8, 2016
    Responding to John Mueller, unfortunately no, ROTH IRAs are subject to the same rule as Traditional IRAs (can’t contribute except to the extent your income exceeds the foreign earned income exclusion). Best solution is to get your employer to offer a US 401k plan.

    John Mueller
    John Mueller Jun 8, 2016
    I read Mr Petersons comments with interest. He refers to using a Roth 401K but those generally are employer sponsored. Are Roth IRA’s an option if your income has been excluded by the standard deduction?

    Michael Hickey
    Michael Hickey Jun 5, 2016
    Given the ever more draconian tax reporting requirements imposed on Americans living abroad these days, especially FATCA, more of them are now taking the drastic step of renouncing their US citizenships, just to live normal lives.

    I’m given to understand that there is a lengthy backlog for those wanting to relinquish, just in Toronto alone, despite the $2,350 price tag. (by far the highest cost in the world for exercising your right to expatriate)

    “Staying home” really isn’t an option for many of these people. Meanwhile, these byzantine rules are literally screaming for comprehensive tax reform, including Residence Based Taxation, which I advocate, and which pretty much the rest of the world adheres to, with the exceptions of the USA, and Eritrea.

    William Braun
    William Braun Jun 8, 2016
    @Michael Hickey What I meant by ‘staying home’ is basically advice not to work in any foreign country as an American. The tax rules for expats are even more convoluted than for those who never work abroad, and are filled with expensive potholes. Relinquishing or renouncing is its own unique minefield and what appears as straightforward is not nearly as painless as many are led to believe. As for citizen-based taxation, opposition to this is tilting at windmills. The US sees this as a easy source of tax revenue collected from people without representation in government. It will never go away.

    Michael Hickey
    Michael Hickey Jun 8, 2016
    @William Braun @Michael Hickey

    Unfortunately, this doesn’t help those that may have only been born in the US, and never actually lived there. Ultimately, they’re the ones most ‘stuck’ in this scenario, as they might not even see themselves as American, and yet the US government has a claim on them, anyway.

    On the issue of renunciation, well, that all depends on whether or not the person in question has any interest in visiting the US for any reason, as renunciation by itself doesn’t resolve past tax problems. But, if that person is not coming back anyway, then it will be very difficult for the IRS to figure out where to send the tax bill. Meanwhile, most renunciants I know are happy with their decision.

    As for citizenship based taxation, it may very well be tilting at windmills. But, I lose nothing by trying. Still, the repeal of it will probably not happen in my lifetime. Therefore, sooner or later, it becomes a choice as to whether the person will return home, or stay gone for good.

    William Braun
    William Braun Jun 11, 2016
    @Michael Hickey Oh, I wholeheartedly agree and applaud your efforts (and those of the ACA) to call attention to the CBT problem that plagues all Americans and particularly those of the ‘accidentals’. It is frustrating to watch: I recently saw a list of pending congressional legislation and one bill aimed at severely increasing FATCA had many, many supporters whereas Rand Paul’s initiative to ban FATCA had …none. I continue to find it ironic that a revolution was fought partly because ”taxation without representation is tyranny’ and yet all expats are relentlessly pursued. I realize that some part of the tax is offset by the earned income exclusion, but the key phrase here is ‘earned income’. ‘Unearned income’ such as unemployment, disability and even pension benefits are taxed fully. As much as I love my birthplace, this degree of greed is almost a violation of human rights.

18. https://vimeo.com/173234584

    Hillary Clinton Wishes Americans Abroad a Happy 4th of July

    From here
    https://twitter.com/asalexanderdesk/status/750485675854573568

19. Why Americans Renounce Their Citizenship
    By Serena Solomon July 18, 2016

    http://www.vice.com/read/why-americans-renounce-their-citizenship

    Good to see Australians represented

20. Trying in US https://www.youtube.com/watch?v=UseaD5P5Z9U

    A Proposal for Fair US Tax Treatment of Foreign Pensions” from @JackieBugnion and Paula Singer https://www.americansabroad.org/taxation/us-taxation-of-foreign-pensions/

    Petition ADDRESS CITIZENSHIP-BASED TAXATION
    https://www.change.org/p/bernie-sanders-bernie-sanders-citizenship-based-taxation-and-fatca

21. Republican 2016 platform for FATCA repeal and against extra-territorial personal taxation (CBT):
    by Mark Twain
    // // Sweden Republicans Overseas //

    “The Foreign Account Tax Compliance Act (FATCA) and the Foreign Bank and Asset Reporting Requirements result in government’s warrantless seizure of personal financial information without reasonable suspicion or probable cause. Americans overseas should enjoy the same rights as Americans residing in the United States, whose private financial information is not subject to disclosure to the government except as to interest earned.The requirement for all banks around the world to provide detailed information to the IRS about American account holders outside the United States has resulted in banks refusing service to them. Thus, FATCA not only allows “unreasonable search and seizures” but also threatens the ability of overseas Americans to lead normal lives. We call for its repeal and for a change to residency-based taxation for U.S. citizens overseas.”https://prod-static-ngop-pbl.s3.amazonaws.com/media/documents/DRAFT_12_FINAL%5b1%5d-ben_1468872234.pdf

22. Watch 2006 movie Idiocracy movie see the next president

23. Haha! I haven’t seen the movie, but just read the Wikipedia entry on it. Sounds Hillaryious!

25. JakDac, That’s one of my favourite TV scenes ever.

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