Media and Blog Articles Open for Comments – Part 5 of 11 (Year 2018)

1,714 thoughts on “Media and Blog Articles Open for Comments – Part 5 of 11 (Year 2018)”

1. @ BB
   I had a hunch that “jump off a bridge” comment might be yours. Turns out I was right. Obviously your anger WILL keep you from jumping … #NotPayingThis. I certainly don’t understand all the complexities of TT (kudos to Karen and John for their deep understanding of it) and it doesn’t affect me directly but I listen anyway because it affects people I care about. Stay strong!

2. Thank you for your caring, kind words EmBee. What a ride this has been. I’m grateful to you and others who’ve played such an important role along the way.

   I believe my seething sarcasm has carried me through many a crisis relating to this “gift” of US citizenship.

   I yearn for the good old days when we all we had to do is spend a few thousand dollars a year to meet the IRS’ expectations. We’ve now entered the twilight zone.

3. Very informative webinar. Thanks both John and Karen! May the many who need this information find a path to it. Thanks so much to the Brock site for the awareness, expertise and continued commitment of so many provided here.

   This US transition tax / confiscation, the US Supreme Court refusal to review the *standing of litigation* (and what that might mean for other country litigations), the link from badger about pensions (http://isaacbrocksociety.ca/media-and-blog-articles-open-for-comment-part-5-of-5/comment-page-21/#comment-8189050) and what I am personally doing to get my family’s issues in better stead for when I am gone give me, as likely others, plenty more to contemplate in the quiet of wee nighttime hours.

4. Anti-FATCA lawsuit plaintiff vows fight against FATCA ‘will go on’
   By: Helen Burggraf | 04 Apr 2018

   http://www.internationalinvestment.net/products/tax/anti-fatca-lawsuit-plaintiff-vows-fight-fatca-will-go/

   Please RT/Like:
   https://twitter.com/JCDoubleTaxed/status/981788847695577090

5. JC: Great to see Helen is keeping our issue in the press. Nice interview with her, Stephen. It’s not over til it’s over, and it ain’t over!

6. Hear hear. 🙂

7. Heitor David Pinto renews his appeal for plaintiffs willing to challenge CBT in US courts.

   https://m.facebook.com/groups/334650186701060?view=permalink&id=969358889896850&_ft_=qid.6542431792148904227%3Amf_story_key.969358889896850%3Atop_level_post_id.969358889896850%3Atl_objid.969358889896850%3Asrc.22&refid=18&__tn__=%2C%3B

8. Stephen, John et al: Is ADCT working with Heitor David Pinto on the anti-CBT lawsuit that plaxy just posted about? Are the two efforts separate or joint? Just curious.

9. The Taxpayer Advocacy Panel is seeking additional members to represent international taxpayers.

   From the website:

   TAP offers its members a unique opportunity to participate in the improvement of both the American tax administration system and the organization of the IRS. TAP members make progress on local, pressing tax issues by working directly with the IRS. Members serve as listening posts to their community and provide local input on tax-related issues. TAP members have the unique opportunity to work directly with taxpayers and the IRS to help change the IRS.

   TAP is also seeking to include at least one (1) additional member to represent international taxpayers. For these purposes, “international taxpayers” are broadly defined to include U.S. citizens working, living, or doing business abroad or in a U.S. territory.

   They want at least one international taxpayer representative. Wouldn’t it be great to stack the panel? I’m considering applying, though unsure I can commit the 200 hours per year of unpaid work they’re asking. Any other potential applicants among us? Applications open until 27 April.

   https://improveirs.org/signupalert.aspx

10. Looks like The Federalist is on board.

    http://thefederalist.com/2014/01/27/toxic-citizen-the-misery-of-being-an-american-abroad/

11. Nail on head:

    given the fact that entities in such European Union jurisdictions as Ireland, the Netherlands and Luxembourg have, evidence suggests, been making use of the OECD’s existing – and I would argue, entirely flawed – double tax treaty structures to engage in a form of tax avoidance, to the tune of hundreds of millions of dollars annually, it is hard to see how anyone in these jurisdictions could then possibly point, with a straight face, at the Panama and Paradise papers exposés as evidence of problematic tax avoidance.

    http://www.internationalinvestment.net/products/comment-the-eu-and-the-new-21st-century-colonialism

12. The FATCA IGA Model 1 IGAs are a dirty deal that lets America off the hook for its tax haven industry.

    CRS is the corresponding dirty deal that lets Europe off the hook for its tax haven industries.

    The OECD double tax treaties enable FATCA and CRS.

    And the small countries whose economies are almost entirely dependent on access to US and European financial systems, are being systematically stripped of capital under the label “transparency.”

13. I thought Marco Sewald already filled that single position with TAP.

14. @BB et al

    It sounds like they are asking for one additional international representative.

15. @Trish

    Not according to this article from the IRS posted in Tax Connections yesterday,

    “To the extent possible, the TAP includes members from all 50 states, the District of Columbia, and Puerto Rico and one member abroad who represents international taxpayers. Each member is appointed to represent the interests of taxpayers in his or her geographic location as well as taxpayers overall.”…

    …”The TAP is seeking members in the following locations: Alaska, California, Hawaii, Kentucky, Massachusetts, Michigan, New Hampshire, New Mexico, North Dakota, New York, Oregon, Pennsylvania, Rhode Island, Texas, Vermont and Wyoming.

    The panel is seeking alternates in the following locations: All states mentioned above, but particularly Colorado, Washington, DC, Delaware, Kansas, Ohio, South Dakota, Virginia and Washington.”…

    I can confirm with Marco.

16. Here’s the link to the above article:

    https://www.taxconnections.com/taxblog/join-the-taxpayer-advocacy-panel-and-help-improve-the-irs/

17. Current TAP members;
    https://improveirs.org/tap-members/
    includes 1 ‘international’ rep.
    Sewald Marco Nidderau International Special Projects

18. RE the international rep on the TAP panel. Nidderau is in Germany.

19. I believe Shelby Lyon of ACA immediately preceded Marco as international rep. Perhaps that’s where the NTA got the harebrained Same Country Exemption idea for FATCA.

20. Re current international TAP rep. I think this may be the author below. If so, understands the situation from an EU perspective.
    See;
    Accidental U.S. Taxpayers Residing Abroad: Choosing between U.S. Citizenship or Keeping Their Local Investment Accounts
    Conference Paper (PDF Available) · April 2017 
    DOI: 10.13140/RG.2.2.10049.15204
    Conference: Conference: 19th International Conference on Banking, Accounting and Finance on April, 24-25, 2017 at London, United Kingdom, At London, Volume: 4

    and,

    Surge in U. S. Citizens Expatriation: Testing StructualEquation Modeling to Explain the Underlying Policy Rational
    Conference Paper (PDF Available) · May 2017 
    DOI: 10.13140/RG.2.2.36814.05441
    Conference: Conference: 19th International Conference on Law, Regulations and Public Policy on May, 21-22, 2017 at Berlin, Germany, At Berlin, Volume: 4

21. Yes, that’s him. Bright guy and very approachable. He’s on FB.

22. @BB, there is apparently an ‘International subcommittee’, but how did that work with only one international rep? I think there has only been an ‘international’ rep for about 2 or maybe 3 years? How is it that the TAP can make decisions on taxpayer priorities with only 1 international rep? And don’t get me started about how they only do outreach and events within the US while the IRS demands compliance from the rest of the globe. I did once (or twice?) submit a SAMS to the TAS on those issues, but didn’t get any response.

    Maybe that is a good one for those interested to flood the TAS SAMS https://www.irs.gov/advocate/systemic-advocacy-management-system-sams with. Definitely qualifies as a SYSTEMIC issue that affects large numbers of taxpayers eh? Only everyone living around the globe outside the US that the US defines extraterritorially as a UStaxableperson.

    Anyone interested can see some of the ‘Special projects’ minutes, https://improveirs.org/special-projects-committee/ some of which mention ‘international’ items. Ex. most recent posted is https://improveirs.org/special-projects-committee/ . I didn’t investigate the minutes of the other committees.

    Why doesn’t the TAS and TAP hold a meeting in Canada? After all, we’re just a short drive over the border from the US. Closer than Puerto Rico – where the TAS International phone line is. And as they very well know, HOME to the second largest population of those deemed UStaxablecitizens outside the US other than Mexico.

23. Please help me to bring highlight that the AU-US Tax Treaty is flawed, has been neglected, and needs fixing.

    Please retweet and like on Twitter.

    This tweet and meme focuses on the question – is Australia he 51st State – as that is the only way an Australian resident may simultaneously be an actual resident of the U.S.

    I am responding to a 46 address twitter string. The addresses cover the spectrum of Australian politics, think tanks, press, and US person and Australian related entities. There are also two Congressmen who are on the Australia caucus in Congress.

    https://twitter.com/JCDoubleTaxed/status/983843354961108992

24. Yes, there is currently one international rep on the TAP. But the IRS site clearly says they are seeking more than one international representative. Doesn’t that convince you? Anyone thinking of applying?

25. “Perhaps that’s where the NTA got the harebrained Same Country Exemption idea for FATCA.”

    It’s kind of unavoidable, isn’t it?

    Whatever changes the US makes to its tax laws (if any), US citizens will have to choose whether they want to be treated by the US as US tax-residents.

    Presumably, the residence-country accounts of those opting for US tax residency would continue to be treated as foreign accounts, unless there was a provision to exempt same-country accounts.

    Unless the US drops FATCA due diligence altogether in Model 1 countries, which would be ideal from the point of view of US-born individuals but which the US Congress probably can’t do.

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