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. Senate supports “accidental Americans”
   16/05/2018 09:21
   https://www.breizh-info.com/2018/05/16/95864/le-senat-francais-veut-regler-la-situation-des-americains-accidentels
   I like how AAA reference the Republican Party Platform.

2. “Accidental” Americans: the Secretary of state announces to the Senate a mission between the MAE and Bercy who will visit Washington at the end of the month to begin negotiations with the US #FDE #France-USA authorities #binationaux

   https://twitter.com/jp_bansard/status/996447084411785216

   “Sénateur des Français établis hors de France” interesting representation in play, yet it is for French persons within France getting attention of the Senator for French persons living outside of France. Perhaps this person will latch onto the issue.

3. “Sénateur des Français établis hors de France” interesting representation in play, yet it is for French persons within France getting attention of the Senator for French persons living outside of France. Perhaps this person will latch onto the issue.”

   If only US person within the US would get the attention of US Senators for US persons living outside of the US.

4. I’m meaning the individual members of the commission will be protected.

5. @JC, glad that Easter looks like he will be working against the “impact of Trump tax in Canada”
   http://www.cbc.ca/news/politics/trump-tax-reform-canada-1.4661065

   but, it is very very dismaying that this same Liberal MP (who is now a co-chair of the Canada-United States Interparliamentary Group, ….meeting with US counterparts/lawmakers re the North American Free Trade Agreement (NAFTA) and international security issues. http://www.cbc.ca/news/politics/trump-tax-reform-canada-1.4661065 ) appears to be disturbingly ill informed about the already punitive existing US extraterritorial tax system and its serious incursions on Canadian residents, judging by a comment in a proposal he made in summer 2017 that shows he does not understand at all how US extraterritorial CBT works, and is openly admiring of FATCA – (though he shows he falsely equates the two and is apparently ignorant of the gaping unremedied double taxation traps and gaps already existing in our Canada/US tax treaty);
   “……..Those who live permanently, or almost permanently, outside Canada, do not pay taxes or have access to health care and certain other things, but do have the benefit of a Canadian passport
   that offers protections that can be costly to provide. The U.S. has an interesting approach to taxes, unique or almost unique in the world, which is taxation on world-wide income (called FATCA or the Foreign Account Tax Compliance Act, as many Finance Committee members will know). In theory, there is not to be double taxation, or there are measures to prevent, minimize, or allow recovery of double taxes……”…..
   from
   July 27, 2017
   Mr. Wayne Easter, Chair
   Standing Committee on Finance
   Sixth Floor, 131 Queen Street
   House of Commons
   Ottawa ON K1A 0A6
   Canada
   E-mail:
   fina@parl.gc.ca
   c/o: Suzie Cadieux, Clerk of the Committee
   613-992-9753
   Re: Pre-Budget Recommendation
   http://www.ourcommons.ca/Content/Committee/421/FINA/Brief/BR9073189/br-external/AmsdenBarb-e.pdf

6. The US National Bureau of Economic Research published this non-academic article “Efforts to Curb Tax Avoidance Offshore Paid Off, to a Degree”;

   http://www.nber.org/digest/may18/w24366.shtml

   It is based on a lengthy academic article available for US$5 at this website:

   http://www.nber.org/papers/w24366

   An earlier draft version is at this link at no-charge:

   https://www.gsb.stanford.edu/sites/gsb/files/acct_05_17_slemrod.pdf

   Excerpt from the non-academic article:
   “The enforcement initiatives raised tax revenues: Annual reported capital income rose by $2.5 to $4 billion annually, corresponding to between $700 million and $1 billion in annual tax revenue. The researchers characterize these sums as “sizable, but…small relative to independent estimates of the amount of concealed offshore wealth and capital income overall.” A recent study by Annette Alstadsæter, Niels Johannesen, and Gabriel Zucman (NBER Working Paper No. 23805) estimated the amount held offshore by U.S. households at $1 trillion. ”

   Two different conclusions could possibly be drawn from this excerpt. Either offshore assets have moved on to other tax haven destinations or into other undetectable asset classes, or the size of offshore assets have been exaggerated by politicians, NGOs and the media.

7. @Innocente, I don’t think the numbers were and are verifiable. And they get repeated and cited until they become self fulfilling. The figures cited for the US ‘tax gap’ attributed to ‘offshore’ bank accounts that was used to justify FATCA was a back of the cocktail napkin type figure that somebody once said, was then quoted and which even in the footnotes later it has been admitted that when contacted, either the originator of the number or the person they corresponded with said that the number had no verifiable basis, there was no explanation, no calculations, no sourcing, etc.

   I can’t find it now, but I’ll look for it. We’ve remarked on it at IBS earlier, just buried now.

8. William Byrnes has touched on the problem with some of the numbers. Ex.
   https://profwilliambyrnes.com/2014/03/15/so-where-does-the-oft-cited-150-billion-figure-of-offshore-evasion-come-from/
   http://repealfatca.com/2017/04/18/fatca-much-ado-nothing-fatcas-tax-revenue-going-offset-irs-industry-costs/

   Still want to re-find some of the quotes and sources for the numbers the IRS, Treasury, TIGTA, GAO, Geithner, and FATCAfounders etc. tossed around so freely.

9. I too remember that the number is completely fictitious. No matter. They will continue searching, extorting and stealing until they fnd it.

10. http://www.lemonde.fr/idees/article/2018/04/14/pascal-lamy-donald-trump-croit-en-economie-comme-ailleurs-a-la-loi-du-plus-fort_5285486_3232.html

    “If America wants to destroy multilateral trade, the Europeans and the Chinese will have to work together to avoid this threat…”

    Pascal Lamy was director general of the World Trade Organisation (also former EU commissioner). Following his op-ed in Le Monde he was on French radio this morning warning about America’s propensity to impose its law on the world. The subject was of course the Iran nuclear deal, where the US would re-impose sanctions on European companies doing business with Iran (in US dollars). He talked of setting up Euro-based exchanges to escape that, and of refusing US sanctions, if necessary with retaliation against US interests, since the EU, while a political dwarf, carries quite some economic heft. Hopefully Lamy is relaying the mood among the EU movers and shakers. He explicitly said that the EU should protect its flagship companies from the US attempt to impose its laws abroad. He was not mentioning banks, but that’s what came to my mind, re-FATCA threats.

    I post this because it is a favorable context in the EU, in France notably, for moving against US extraterritorial reach concerning FATCA and citizenship based taxation. Trump’s actions are opening eyes, and people are beginning to understand how pernicious US actions can be. It helps because Trump lacks sublety. Obama and Clinton were infinitely more dangerous, in this sense (and arguably no less at risk of starting a war). Hopefully when French parliament works on helping accidentals (and others, like me, not accidentals, but CBT targets nonetheless), people of all political sides can agree (thanks to Trump) it’s time to keep the US in check.

11. @Fred (B)

    We can hope.

12. I placed this comment in a post that I thought was most relevant, but perhaps no one is checking that post now that it is not at the top of the Brock home page. So, I am also placing this on the Media post as a deadline is approaching and more need to determine what they need to do for their individual situation. Thanks to John Richardson and the others in this discussion.

    http://isaacbrocksociety.ca/2018/05/05/brock-project-advice-on-how-to-explain-the-effects-of-the-ustransitiontax-through-a-question-in-the-house-of-commons/comment-page-2/#comment-8238289

13. https://www.bna.com/us-course-land-n73014475976/

    Bloomberg: U.S. on Course to Land on European Tax Blacklist: EU Official

    This quote is infuriating: “The EU should adopt measures similar to the GILTI because now profits coming from low-tax or zero-tax countries will be taxed,”

    SO wrong on so many different levels.

    GILTI is so poorly drafted that I have no words to describe how bad it is.

    Start with the basic premise:
    All intangible income is essentially US source (I guess that’s because Congress thinks all IP is developed in the US).

    REALLY????? No other countries generate IP? If Google hires software engineers in Sydney, the income from their intangible product will be taxed as US source income under GILTI (Google Maps came out of the Sydney office, so this isn’t a hypothetical situation).

    Of course, that’s just the theory – the problem is, how do you measure income from intangibles? The GILTI solution – only depreciable assets are tangible! Tell that to your average retailer who generates profit from (non-depreciable) investment in inventory and probably leases their premises (store fittings would be the bulk of depreciable assets). Where is the intangible income? However the average retail operation will have significant GILTI.

14. @Solomon
    I’m waiting 4 a final #TTFI outlines 2 present at an AmCham Hong Kong event on May 25. https://amchamhk.eventbank.com/event/8210/# All my ?s have further delayed the legislative text release. Agree w/ better late/good than earlier/insufficient. I’m also mindful abt missing this yr legislative window

    https://twitter.com/SolomonYue/status/997139764309458944

15. @Karen

    The basic premise is that the US Congress needs money to pay for all the benefits that homelanders feel entitled to and know that raising it from homelanders will be as bad as cutting benefits.

    Any legislative action to raise funds abroad is nothing more than attempt to put a veneer of legality to their theft.

    You are a USC living abroad, you owe the US taxes, fines, penalties, information and time to the US.

    You were born in the US to non USC parents and repatriated home younger than 1 year old, you owe the same.

    You were born abroad to one USC and one nonUSC parent, you owe the same.

    You have spent some time in the US, you owe the same long after you return.

    You do business with a USC, you owe the same.

    You are married to a USC, you owe the same.

    You are emplyed by a US owned domestic company, you owe the same.

    You do a short term contract job for a US owned domestic company, you owe the same.

    You earn any amount of income from, with or through the use of anything patented in the US, say an iPhone, you owe the same.

    You sell “US sourced” goods, you owe the same.

    You sell second hand “US sourced” goods, you owe the same.

    Now before anyone goes bat crazy over the fact that much of this is not law, yes I know. But these sentiments match comments I receive from homelanders and the trajectory of US legislation. Even my own mother is livid that my wife, a Japanese National, is not paying income tax to the US because she works for a “US company” in Japan.

16. JC quoting Solomon Yue:

    “I’m waiting 4 a final #TTFI outlines 2 present at an AmCham Hong Kong event on May 25.”

    Is it known who is producing the final TTFI outline that Solomon Yue is waiting for?

17. Matt Stross from Congressman Holding’s office.

18. Thanks.

19. https://www.forbes.com/sites/robertwood/2018/05/14/fewer-americans-renounce-citizenship-but-taxes-still-drive-them/#63969de119f1
    ‘May 14, 2018
    Fewer Americans Renounce Citizenship, But Taxes Still Drive Them’

    This article has an embedded link to a Brock page http://isaacbrocksociety.ca/2014/08/22/comparison-of-fees-and-procedures-for-renouncing-citizenship-in-various-countries/comment-page-1/ as its source for citing that there is incomplete reporting of the actual total numbers renouncing.

20. Slight correction to my comment above. The article mentions incomplete reporting of the actual total numbers renouncing. The IBS link they use as a cited source is one that leads to a post by Eric that shows the US renunciation fee is the highest of the 28 countries investigated, and likely highest in the world.

21. More product placement, another instance of the Reed Amendment being raised as a spectre to scare expats;
    ” …….She also needs to avoid being affected by the Reed Amendment, which bars former US citizens who renounced for tax purposes from reentering the United States,”
    https://www.thelocal.ch/20180515/meghan-markle-and-the-long-reach-of-the-irs-what-us-citizens-living-abroad-need-to-know-moodysgartner-tlccu

22. It seems to me quite interesting that the TTFI proposal is to make its first appearance at AmCham Hong Kong.

    Their web page credits DeSombre and the RO PAC with convincing Brady (remember that CS Monitor breakfast?) and now, having got the specifics finalised, bringing the draft back to AmCham HK to show the donors. Which makes a lot of sense, when you think about it.

    The AmChamHK “Priorities” page lists Territorial Taxation at the top of the 2018 “US” list:

    2018 Focuses

    UNITED STATES

    * Territorial tax system for U.S. nationals overseas

    * U.S. visa waiver for Hong Kong

    * Hong Kong’s unique role in U.S.-China trade relations and for stronger U.S. engagement in Asia

    * More U.S.-HK institutional collaborations in tech & innovation

    * Investment into the USA

    While “American thought leadership in innovation and technology” is at the top of the “Hong Kong” priorities list.

    Oh that tech and innovation. A.K.A. IP. That stuff that can be done without none of those awkwardly located foreign premises, and taxed without none of that hideous CBT-dependent SubPart F gobbledygook.

    Not as dumb as they’re cabbage-looking.

    Maybe. I am of course just speculating. Perhaps the HK launch is a reason for TTFI optimism (for USC minnows globally), in any case. If TTFI suits the (Republican) donors’ China agenda, (Republican) Congressional seatholders might be more likely to vote for it.

23. We can hope.

24. Behind a paywall, but for those who can access it;
    ‘Canada’s answer to U.S. tax plan won’t come till fall, Morneau says …’
    https://www.theglobeandmail.com/politics/article-canadas-answer-to-us-tax-plan-wont-come-till-fall-morneau-says/

25. Not a word about transition tax or GILTI. It’s all about pressure from Canadian business to cut corporate tax rates in Canada.

Comments are closed.