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. I prefer Matthew 22:21

   “Render unto Caesar the things that are Caesar’s; and to God the things that are God’s.”

   Fortunately, neither Caesar nor God nor the IRS owns a share of my non-US-source income.

2. I’m pleased that the tax authority of my country has always taken the same view. All my income is reported to the tax authority, and they assess my liability. Throughout the years I’ve lived here, the tax authority has invariably decided that my income should be taxed by them, not by any other country’s tax authority. Nor by Caesar. Nor by God.

3. Monte Silver of Americans for Tax Fairness has contacted me about the E-mail/Phone campaign to Congress: Exempt Americans Abroad from the Repatriation & GILTI Taxes.

   “ . . . Fact: Congress will be passing a law that fixes various problems created by the reform. Fact: It will do so in the Lame Duck session – between the elections on November 6, 2018, and January 3, 2019 when the new Congress convenes. Very soon.

   Will we be part of the fix? Yes, if… if we maintain the same high level of effective activism and if we play our cards right.

   This email petition is the platform for our effective activism. When you sign it, every single key senator and House representative, and their key staff, will hear your voice, very loud and very clear.

   Lets win this. We can do it.

   What to do? Simply follow the steps below. We have made it easy for you.”

   The steps he refers to, and other information, are at this link – http://www.americansabroadfortaxfairness.org — it has sample e-mail text and contact info (email and phone) for the House and Senate Leaders, Committee Chairpersons and Committee Members.

4. More reasons why Canadian banksters urged our government to bend over for FATCA;
   http://business.financialpost.com/news/fp-street/cibc-reaches-for-more-as-its-u-s-banking-push-starts-paying-off
   https://www.bloomberg.com/news/articles/2018-06-15/cibc-reaches-for-more-as-its-u-s-banking-push-starts-paying-off

   Hence, Banksters and profit know no country and have no allegiance or social conscience when it comes to their fellow citizens, Canadian taxpayers or accountholders vs. profit.

5. pacifica 777

   I no longer vote in the US and as I am still hopeful of finding a window towards a second citizenship and ditching USCship and know that my ID has bedn stolenin the US, I’d rather not lie and say that I do vote in the US. Is it permissible to leave that blank empty on the form letter?

6. @ JapanT,

   AFAIK, that’s just a sample letter. So, you could write your own text or just leave that line out of the sample form letter. I’m not actively involved with this project, just helping to get the word out, but that’s my take on it.

7. Got it. Thanks.

8. “The Missing Profits of Nations”,
   Thomas Tørsløv (University of Copenhagen), Ludvig Wier (University of Copenhagen), Gabriel Zucman (UC Berkeley and NBER), June 5, 2018
   http://gabriel-zucman.eu/files/TWZ2018.pdf

   By combining new macroeconomic statistics on the activities of multinational companies with the national accounts of tax havens and the world’s other countries, we estimate that close to 40% of multinational profits are shifted to low-tax countries each year. Profit shifting is highest among U.S. multinationals; the tax revenue losses are largest for the European Union and developing countries. We show theoretically and empirically that in the current international tax system, tax authorities of high-tax countries do not have incentives to combat profit shifting to tax havens. They instead focus their enforcement effort on relocating profits booked in other high-tax places—in effect stealing revenue from each other. This policy failure can explain the persistence of profit shifting to low-tax countries despite the sizable costs involved for high-tax countries. We provide a new cross-country database of GDP, corporate profits, trade balances, and factor shares corrected for profit shifting, showing that the global rise of the corporate capital share is significantly under-estimated.

   “Tax Havens Blunt Impact of Corporate Tax Cut, Economists Say”,NYT, 10 June 2018
   https://www.nytimes.com/2018/06/10/business/corporate-tax-cut.html

   The new corporate tax cuts are unlikely to stimulate the level of job creation and wage growth that the Trump administration has promised, a trio of prominent economists has concluded, because high tax rates were not pushing much investment out of the United States in the first place.

   Instead, the researchers conclude, multinational corporations based in the United States and other advanced economies have sheltered nearly 40 percent of their profits in tax havens like Bermuda, depriving their domestic governments of tax revenues and enriching wealthy shareholders. That number suggests a jarringly large amount of what appears, to policymakers, to be investment pushed abroad by high tax rates is instead an accounting trick — so-called paper profits — which tax cuts will not reverse.
   [..]
   Throughout the debate over the tax bill, Republicans cast the country’s corporate tax rate as uncompetitive when compared with nations such as Ireland and Canada, and said the rate was pushing American multinationals to park their profits in other countries where their tax bills would be lower.

   The new research concludes that assumption is wrong. “Machines don’t move to low-tax places,” the economists write, “paper profits do.”
   [..]
   Mr. Zucman said the results should cause policymakers to rethink their efforts on several fronts. They suggest, he said, that advanced countries are underestimating economic growth and undercollecting corporate tax revenues, because they are missing the profits that have been shifted on paper by multinational corporations.

   Kimberly Clausing, an economist at Reed College who has written and researched extensively about the scope of shifting profits to tax havens, said the research demonstrated that “the decline in the corporate tax is a result of policy, not an inevitable feature of the global economy. This implies that policymakers have the ability to address this problem without losing out in a tax competition game against other countries. But they must have the will to tackle tax havens themselves, instead of directing their fire at other non-haven countries.”

9. No idea where to put this because we don’t have a permanent “evil condors” thread. Moodys is doing a bunch of seminars again. This time I will be in town for one so have signed up with a psuedonym. I plan to record it on my phone, and if possible ask some awkward questions about the virtues of non-compliance and IRS inability to enforce etc. If anyone has a question they’d like asked, please post it here.

   Added bonus, they scheduled the event between World Cup matches, so I can go straight to a bar for the Germany-Sweden kick-off.

10. Details here for additional Canadian dates in July, if anyone else feels like being disruptive, plus a webinar.

    https://moodysgartner.com/learning-tax/

11. I can’t be there, Nononymous, but I wish I could be!

    Give them hell!

12. @Nononymous: Here’s hoping you get the chance to ask your questions at the Moodys event. If at all possible, you might consider a question to the effect of: “Considering that the vast majority of non-compliant US persons overseas are either invisible to the IRS, or face no actual threat of action against them, has there been any discussion within your offices as to whether advising expats to enter the system–and therefore face huge fees and enormous potential fines–is either moral or ethical? Setting legality aside, would it have been moral or ethical for a Berlin-based legal firm in 1942 to advise Jews hiding in a cellar to ‘come into compliance’ with German legislation?”

13. A review of US-Canada antagonisms of the past. Would’ve benefitted from a mention of FATCA and ADCS. Tools that allow for a non-military invasion of Canada.

    https://www.politico.com/magazine/story/2018/06/21/that-time-the-us-almost-went-to-war-with-canada-218881

14. Perhaps more information on the issue of potential or actual passport revocations might be forthcoming from the IRS Taxpayer Advocate Nina Olson, who says ; “…In my next blog on passport issues, to be posted in June after we publish the Objectives Report to Congress, I’ll share some data regarding passport cases, including TAS cases, and provide an update on TAS’s ongoing advocacy for these taxpayers….”…
    https://taxpayeradvocate.irs.gov/news/nta-blog-refusal-to-exclude-open-TAS-cases-from-the-passport-certification-program-violates-taxpayer-rights?category=Tax%20News

    Stay tuned for;
    Ms. Olson’s “… forthcoming FY 2019 Objectives Report to Congress that will be published at the end of June.” and which will appear on this page https://taxpayeradvocate.irs.gov/reports

15. https://www.thelocal.se/20180621/uma-thurman-applies-for-swedish-citizenship-ahead-of-planned-move-to-sweden

    The Pulp Fiction actress has often talked about visiting Skåne and Sweden over the years, as well as her desire to get Swedish citizenship and relocate to the country. Now Thurman is taking the steps to try and make that dream a reality.

    “She gave me the task of requesting Swedish citizenship. A large part of her relatives are Swedish, her mum is Swedish. She explained to me in the past she thinks it’s wrong that she’s not a Swede, she feels like a Swede,” Thurman’s lawyer Thomas Bodström told radio station Mix Megapol.

    “She wants to buy a house in Sweden and live here in the future. She has a lot of relatives in Skåne so there are a lot of things that make her want to become a Swede; she has felt Swedish her entire life. We hope it will go well but it’s also a long process.”

16. I ran this very one-sided article about the tax joys of living abroad by a co-founder of Greenback Tax Services, who really should be more cautious. I doubt that many Americans will decide to up sticks on the basis of this advice, but it does create the illusion that moving abroad generally makes your tax life easier (maybe if you move to a country with very limited financial and tax regulation, otherwise no). No room for comments, but there is a twitter address.
    https://www.inc.com/carrie-mckeegan/work-remotely-this-little-known-tax-provision-could-save-you-thousands.html

17. Publius – indeed. Remarkable how

    “the US has to give credit for foreign taxes paid, but prefers to pretend they’re giving you a tax break”

    gets transmuted into

    “ a little-known provision in the tax code that can help fund your overseas lifestyle!”

    I see the writer doesn’t mention that FEIE disappears along with the earned-income FTCs if the expat tries to retire while still filing US taxes.

18. Correction, the writer does mention the limitations of the FEIE. I spoke too soon out of my annoyance at seeing undoubletaxed income described by the writer as tax-free money.

19. @Publius, @plaxy

    According to my Enrolled Agent (EA) the writer missed a new tax incentive for some people to live abroad. Next year, due to the tax reform, I will be recieving a refundable Child Tax Credit of roughly 800 USD from the IRS. Never paid a cent in US taxes, never paid a cent into US social security and now I will be getting free cash. Well not really free, my EA’s bill is 1000 CHF a year. 🙁

20. Uncle Tell – Ironic, isn’t it? I too get free money from the US: a monthly SS pension payment, not large, but wholly disproportionate for the few years I worked there before I escaped. And taxed not by the US but by my home country, I’m pleased to say. 🙂

21. @UncleTell

    It’s free money at the expense of revealing your child’s identity to the IRS. That may or may not be an acceptable bargain. I chose not to give up my daughter’s anonymity for the sake of a few thousand dollars, but others may not have that luxury.

22. Is the free money only available for a USC child?

    Or can it be claimed by a USC parent for a child born outside the US for whom US citizenship has never been claimed?

23. @plaxy

    To claim, child must be a USC with SSN.

24. So here are the four questions I’ve written down for the Moodys seminar tomorrow. Hopefully I will have the chance to speak. No idea. I will attempt to record the exchange on my phone.

    Canadian banks generally rely on self-certification to identify US-person customers. They do not demand ID showing place of birth, as in other countries. What in your view are the potential consequences of denying US citizenship or tax residency when asked the FATCA question by a Canadian financial institution?

    What, in your view, are the possible consequences for a Canadian estate or executor if a dual citizen with no US assets dies without ever having been compliant with US taxes?

    Please confirm that renunciation of US citizenship does not require US tax compliance, before or after. It is a separate legal process. The only consequence of renouncing without tax or FBAR filings is to be deemed a “covered expatriate” – but this is only a concern if you plan to give or bequeath money to a US taxpayer.

    Are you personally aware of any cases where US-born Canadian citizen entering the US (on either a Canadian or US passport, regardless of what US law requires) have been asked questions about their tax compliance status?

    As you are no doubt aware, the IRS has no power to collect penalties or taxes owing imposed against Canadian citizens resident in Canada. When asked, the federal government has confirmed this to be the case. Consequently, under current law a dual citizen with no financial ties to the US – no assets, income, expected inheritance or business interests – should have no reason to fear the IRS, and no reason to come into compliance. Would you not agree that for the typical “Accidental American” living in Canada the costs and risks of compliance – the expense of hiring professionals, the possibility of penalties or taxes owing due to incompatibilities between the two tax systems – outweigh the risks of non-compliance? Has there been any discussion within your office of whether advising dual citizens to enter the US tax system is, in some circumstances, morally or ethically wrong?

    Thanks @Barbara for the suggestion about morality and ethics (though I will not invoke a Holocaust analogy, I do not think it is ever appropriate or effective).

    I don’t want to waste the rest of the day nerding out on this stuff, but if anyone has any suggestions, please post them here, bearing in mind that it’s already too long.

25. Five questions! No one expects the Spanish Inquisition!

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