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. Woo Hoo! Let the fun begin.

   Said earlier, perhaps on a different thread, better not ignore big data, FinTech etc. This is just the tippy tip tip of the iceberg.

   All data wiill be matched and shared on everybody. Period. Just a matter of time now.

2. But only with the bank, and only with the individual’s consent. Which is how social media and ISPs already do it. It’s new for banks to get in on the act. As the man says –

   “To you it’s a headache – to is it’s an opportunity!!

3. Same concerns apply. It’ll be shared. By hook or by crook, it’ll be shared.

   As far as consent goes, I had to consent to the State Dept. sharing all the data they have on me or riske losing my passport.

   I had to consent to my Japanese bank sharing all me account data including transactions, balances, changes in balances etc. with the IRS or not open the account.

   “Consent” has lost its meaning. Much like “But your honor, I did not rape her, she gave me her consent.” being accepted to acquit despite the fact the rapist held a gun to his victim’s head.

4. “I had to consent to my Japanese bank sharing all me account data including transactions, balances, changes in balances etc. with the IRS or not open the account.”

   Yes, you live in a IGA2 jurisdiction. USCs in IGA 1 jurisdictions, which includes all EU Member States, don’t get the opportunity to refuse consent for their data to be given to the local tax agency (which forwards it to the IRS). But they do have very wide protection under the GDPR which means banks and other organisations must have consent to use data. EY appears to be proposing making the customers an offer they can’t refuse, provided the customer gives consent for the bank to use their data for marketing etc.

5. “match data being reported through FATCA and/or CRS with data being reported in the taxpayer’s tax return.”

   Where is that data coming from? So the account holder has to provide the bank with a copy of their tax return or lose the account?

   What could posdibly go wrong?

6. “Where is that data coming from? So the account holder has to provide the bank with a copy of their tax return or lose the account?”

   No, but there’s nothing stopping the bank from offering certain services which need sight of the tax return – such as making sure there’s not going to be any nasty little conflicts between what the bank is reporting and what the customer is reporting. Just like free email providers like gmail get consent to use their customers’ data in return for the free service.

   I don’t of course know that that’s the kind of thing EY has in mind. I might be misinterpreting.

7. I have recently received news that unfortunately Marco Sewald has resigned from his position as the Taxpayers Advocacy Panel international representative due to serious illness. We wish Marco well and appreciate the efforts he made to the panel in the brief time he represented American Taxpayers abroad.

8. “US planning international tax guidance on BEAT, GILTI, transition tax, Harter says”
   https://mnetax.com/us-planning-international-tax-guidance-on-beat-gilti-transition-tax-harter-says-27934

   The US intends to issue proposed regulations addressing the section 965 transition tax next month followed by comprehensive guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury, during the 2018 OECD International Tax Conference, held June 4–5 in Washington.

   “We’ve got a pretty decent draft of the [section] 965 transition regulations drafted and it’s begun its way through the review and editing process so I think we are on schedule to get those out by the end of July,” Harter said.

   Concerning the other components of the 2017 US tax international tax reform, Treasury’s goal is to release a “fairly comprehensive” set of proposed regulations by year-end so that corporations can rely on the guidance when preparing their year-end financial statements, he said. The plan is to then finalize the proposed regulations by June 2019 so they fall within the section 7805(b) retroactivity window and thus can apply seamlessly back to January 1, 2018, Harter told the conference, an annual event co-sponsored by the OECD, USCIB, and BIAC.

   [..]

   Pam Olson, US Deputy Tax Leader and Washington National Tax Services Leader at PwC, said that despite all the work done on BEPS, global discontent remains with the cross-border tax rules.

   “BEPS tackled the politically and publicly easy part — closing loopholes — but proposals like the digital service tax, actions like State aid, the diverted profits tax, etc., make clear to me at least that the system is wholly unstable. And that is because the hard part is yet undone and the hard part is determining who gets to tax what no long longer falls through the cracks.”

   Olson said the old rules for jurisdiction to tax are becoming a thing of the past. Countries need to have a multilateral conversation on what the future should look like, she said.

9. “Macron: Countries must work together to fix flawed tax system”
   http://www.publicfinanceinternational.org/news/2018/05/macron-countries-must-work-together-fix-flawed-tax-system

   Emmanuel Macron told delegates in a keynote speech at the OECD’s Forum 2018 – for which Public Finance International was a media partner – it was crucial to build a “strong multilateral system”.

   This was needed to tackle the global issues like equality, trade tensions and climate change, the French president said at the event in Paris.

   Currently the international tax system is creating uncertainty and inequality, and it must be modernised to cope with economies becoming increasingly digital, he said.

   “We can only move forward if we are fully accountable. And I cannot give a fair account to our citizens of the current tax architecture because it is fundamentally flawed,” he said.

   Macron added the only acceptable international tax system was one that was “fair and subject to regulation”, and that could be explained to citizens, those who pay their “share of tax”.

10. Just sharing an exchange on that FT article comment section:

    “Hilarious. Rich liberal neoliberals who want to be Americans but don’t want to pay tax to support social programs that their fellow citizens need. All talk and no walk.”

    PurpleExpat 2 days ago
    @Jerryjb so you are saying, 1) all US citizens overseas are rich neoliberals, 2) do not want to pay tax, 3) do not want to support social programs. Well, #1 is about 99% wrong. #2 they pay taxes where they live, so that is 100% wrong. #3 they support social programs where they live = 100% wrong. How is it that someone can be so wrong in one sentence. It is just another sign of the dumbing down of America.

11. @ plaxy
    Macron is a globalist through and through. He has their odious patter down pat. Their goal is to have everyone everywhere controlled by a distant unapproachable, unaccountable governing body and to blur the boundaries of nations to the point where the concept of sovereignty will fade to black. It warmed my heart when the Alliance for the Defence of Canadian Sovereignty was formed, not the least of reasons being that its name alone shows it recognizes that sovereignty needs to be defended and ever more so as the years pass. Personal liberty and privacy are in dire need of defenders too.

    “In searching for a new enemy to unite us, we came up with the idea that pollution, the threat of global warming, water shortages, famine and the like would fit the bill.” – “The First Global Revolution”, A Report by the Council of the Club of Rome by Alexander King and Bertrand Schneider 1991.

    Of course the global agenda is really not about uniting humanity; it’s about controlling humanity.

12. Embee – I’m not a French voter and don’t have an opinion on Macron beyond noticing that the French, including Macron, have gone further than any other EU country to acknowledge that the US is interfering with EU citizens’ banking. I hope that when Europe and Australia and the rest of the world get around to redesigning international taxation it will be recognised that the asymmetrical nature of US CBT lying and the US determination to turn everyone in the world into a US Person is one of the factors contributing to the instability mentioned by several speakers at the OECD conference.

13. Perhaps this has already been posted. If so, apologies for the redundancy. Comments are open.
    Usual distortion by failure of author and headline that can be read as if expats “don’t want to pay taxes” period – but doesn’t mention that they are fully taxed in the country where they actually live – outside the US (sometimes more taxes in total than they’d pay IF they were US residents).
    https://www.accountingtoday.com/news/expatriates-object-to-filing-us-taxes

    Also doesn’t mention the complexity of reporting from outside the US, the pitfalls inherent in the layers of Form Crime reporting regimes and penalty structures imposed on those banking and living normal law abiding lives outside the US….. etc.

14. Some help and accurate information needed below – preferably from someone with UK experience;
    https://www.mumsnet.com/Talk/am_i_being_unreasonable/3272251-To-not-want-to-pay-tax-as-an-Accidental-American

15. Badger, I signed up but that site wouldn’t let mepost a message. Can’t figure out why. I would have tried to set her straight

16. Regarding ignorant homelander comments, I do find it rich that people might think I don’t pay my fair share of taxes. I pay much more than I’d pay if I lived in the US (but I also live in a country with a much better social safety net). This “fair share” thing sounds so true until you realize that they are coming after people who have no business being taxed where they don’t live. It’s really not fair at all.

17. @Fred (B)

    In the homelander dictionary, “fair share” is defined as “I want, you pay”.

18. E-mail from RO/ Solomon Yue 4 hours ago:

    Dear JC,
    On June 4, 2018, the US Internal Revenue Service issued a bulletin which delayed by one year (until April 15, 2019) the first payment of the US transition tax for those overseas American business owners whose total transition tax liability was $1 million or less.

    It is estimated that this exemption will cover expats with approximately $6.5 million in cash assets or $12.5 million non-cash assets.

    You can read the relevant section of the IRS bulletin (Question and Answer 16) in the text box below this message.

    For an analysis of this bulletin and how it relates to American expats, we recommend tax lawyer John Richardson’s blog post.

    The delay in the first transition tax payment is great news for overseas American business owners, but this is only the first step in the process to remove the Transition Tax for small businesses, altogether.

    Lawmakers now need to define what constitutes a ‘small overseas American business’ for a future Transition Tax legislative fix. John Richardson (tax lawyer) thinks that the IRS range for a small business (depending on the cash/fixed asset ratio) is probably between $5.7 million and $11 million. In our last discussion with the Treasury Department regarding the financial definition for overseas small businesses for the Transition Tax fix legislation, Treasury indicated a value of $10 million.

    Republicans Overseas continues to work on the implementation of Territorial Taxation for Individuals, which would effectively allow overseas Americans (both as individuals and as small business owners) to stop paying US taxes and to only pay taxes to their host country. As soon as the draft TTFI bill is available to share with the public, we will do so.

    Sincerely,
    Solomon

    Solomon Yue
    CEO Republicans Overseas

19. @JC

    I’m a bit confused.
    The draft is ok do show and discuss with AmCham, but is not available to share with the public? I have a funny feeling that this draft isn’t going to be what we “individuals” are hoping it will be. But, if I am proved wrong I won’t cry. 🙂

20. from Democrats Abroad …
    I wonder if the thing in the House Ways & Means Committee is the same one mentioned by Republicans Overseas. At least, at last, some bipartisanship here! (Although that happy fact is the result of being screwed in a bipartisan manner).

    https://www.democratsabroad.org/carmelan/on_15_june_intl_tax_filing_day_tell_congress_we_re_double_taxed_we_vote_and_we_re_not_happy_call?utm_campaign=glb61118taxemea1&utm_medium=email&utm_source=democratsabroad

    Dear …,

    Democrats Abroad is marking June 15th – International Tax Filing Day – by storming Congress with calls from Americans abroad asking for tax reform. On Friday June 15 join our campaign and tell your elected representatives we’re double-taxed, we vote and we need tax reform. Click here to learn more.

    Twelve months ago it became clear that, following the disastrous attempt to repeal Obamacare, the GOP Congress was going to get serious about tax reform. Knowing their love for tax cuts for the wealthy and powerful, we knew it would be very hard to squeeze past the army of corporate lobbyists determined to have the Congressional Republicans meet their particular needs. Although a switch from Citizenship Based Taxation to Residency Based Taxation did not make it into the bill, we and other organisations representing Americans abroad generated enough attention to persuade some in the House to explore the issue, and we now have a Residency Based Taxation bill in development in the House Ways and Means Committee. The provisions of the bill are not fully established, but we are close to the process and providing meaningful input.

    International Tax Filing Day is the perfect time to let Congress know how many of us want badly to see Residency Based Taxation become law. Please help by picking up the phone on June 15th and calling your Senators and Representative. All you need is in this Tax Reform CallStorm Campaign Guide.

    Please help other Americans abroad to call as well. Forward this email and/or send your friends the CallStorm Campaign Guide today.

    We know grassroots outreach works!

    As you may know, though the 2017 Tax Act did nothing to relieve Americans abroad from double-taxation, it actually added two new taxes to the burden born by Americans abroad who own their own companies. ( See here for more information.) Happily, hard work by committed activists has resulted in a reprieve for most American business owners abroad from making those tax payments. This is a genuine grassroots campaign success!

    We now have 12 months to persuade Congress to enact an exemption for Americans abroad from the “transition taxes” in the 2017 Tax Act. Whether or not you own a business abroad you can help push for this important reform. Click here for more information and to participate in this important campaign.

    Please send questions or comments to the DA Taxation Task Force at taxationtf@democratsabroad.org.

    DA TAXATION TASK FORCE

21. “There will come a time, and it may be upon us sooner than anyone expects, when the allies will stop beating their heads against the wall. They are going to work around the U.S., maybe even against the U.S., at which point the partnership that won two world wars and the Cold War could be permanently shattered. And again, that may be exactly what Trump is gunning for. As Le Monde observes in today’s edition, ‘Donald Trump is the same age as the world order put in place by the United States at the end of the Second World War, but one would swear he decided that the latter will not survive him.’ ”

    from http://www.electoral-vote.com/evp2018/Senate/Maps/Jun11.html#item-1

    While Trump is a catastrophe, no question, I continue to hope this opens the eyes of other countries and motivates them to better protect their residents and citizens from FATCA.

22. @Fred(B)

    RO calls it Territorial Tax For Individuals, while DA refers to it as Residency-Based Taxation, but yes it is the same bill.

    In the spirit of bipartisanship, both should at least refer to it as the RBT/TTFI bill. Without seeing it, who’s to say which it more closely resembles?

23. JC and Fred (B): Good to know that the efforts continue. Thanks for posting!

24. @Portland, thanks for trying to help the person with the panicked OMG moment in the UK http://isaacbrocksociety.ca/media-and-blog-articles-open-for-comment-part-5-of-5/comment-page-37/#comment-8262254

25. According to Jeff Sessions, pay tax is our biblical duty:

    https://sisyphusblog.wordpress.com/2018/06/16/what-the-hell-is-romans-13-and-what-does-it-have-to-do-with-taking-children-from-their-parents/

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