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. JC:

   “Sounds like RO legal challenge not stopped, but in next chapter:

   ‘Now we look 4 new plaintiffs who received IRS fine letter.’ ”

   It’s over for expats, I believe. RO said at the time the certiorari attempt failed, that they would continue but would be looking for US-resident plaintiffs.

2. Yes. RO have posted their requirements on their Facebook page.

   https://m.facebook.com/republicansoverseas/posts/825918967591900

3. Being an us tax subject/”person” was akin to having congenital defect–whereever you go there you are.

   Unfortunately, whilst there has been some minor push back from us expat/dual citizen associations, clubs, and advocates–politically and pragmatically–FATCA and CBT (exceptionalism as work!) is here to stay.
   The bankers forced the “sovereign” countries to all bend over and take the red, white, and blue up the boot.

   So the anger may not be directed at the us empire; b/c that’s the us doing what it does best!— 400yrs+ a bully, hollow, broken, soulless, war mongering, hu$lting empire that stood for nothing except get money, get more money. Everything in the us was coated with a thin layer of massive fraud. Be furious with your so-called new home as they f-d you. They released YOUR info to a foreign entity-the us, and now you cannot open a bank accnt, mortgage, participate in savings plans, mutual funds, etc…

   What’s next ? irish need not apply? no germans allowed–call this number, no jews allowed b/c the us empire said so, so bend over and take it? YUP–that’s what those “sovereign” countries did. So with the exception of Madame in’t Veld, the rest of the yammer, is just some yammer, some jammer, and false hopes of someday to keep folks on the payroll, and lawyers selling hope.

   What is required is someone to say: It’s. Over. No more false hopes, do nothing “hearings”, and pollys selling smiles and BS.

   Reality—Our “new” adopted country f-d us, and they worship the us empire. They signed their country away to manifest destiny. They NEED the us empire for making $. The expats/dual citizens don’t mean anything. They’re pesky little foreigners. F u. That’s the reality.

   All roads lead to: RENOUNCE ,and be ‘pure’ _____country. OR go back to the us empire and “enjoy” the ontologically empty wasteland.

4. Joe Light at Bloomberg writes about Section 962, calling it a “tax loophole” for the “wealthy”. Quotes one of Phil Hodgen’s webinars:
   https://www.bloomberg.com/news/articles/2018-07-11/tax-loophole-from-1960s-could-let-wealthy-tap-21-corporate-rate

   Via TaxProf Blog, of course:
   http://taxprof.typepad.com/taxprof_blog/2018/07/long-ignored-962-could-let-wealthy-tap-21-corporate-rate-under-new-tax-law.html

5. Pls RT/Like on Twitter.

   This was a reply on the Britain twitter string or as some call it tree, with 46 addresses.

   @BorisJohnson former @USAccidental & rumored he paid six figure U.S. tax bill on sale of his first home in Britain! Called it OUTRAGEOUS!

   Will you call it OUTRAGEOUS to Trump?
   Or, will you salute #AmericaFirst ?

   @BBCNews @guardiannews @TelegraphNews #FATCA #TTFI #taxreform

   https://twitter.com/JCDoubleTaxed/status/1017609634280960000

6. But who cares about the tax bill of an unprincipled politician who clung to his US citizenship while periodically threatening renunciation, and when he finally did renounce after being disastrously appointed to high office, was personally assisted by the US Ambassador over drinkies at Grosvenor Square?

   People who were genuinely devastated to learn that they were subject to US tax law and were wrongly told that they couldn’t renounce unless they could pay for five years compliance plus accountants’ fees, rightly attract sympathy. Those who (along with their siblings!) are themselves privileged MPs who said not a dickie-bird when FATCA-implementing legislation whizzed through Parliament, do not, and why should they?

7. JC:

   “It would be wrong to give up on Solomon Yue, as there are no other legislative initiatives that may get anywhere.”

   The trouble is, the legislative initiative being twitted about by Solomon Yue, besides being unlikely to get anywhere, doesn’t offer anything at all for those who don’t want to be treated as tax criminals for having been born in America.

   It’s a sort of plea deal for the 9 million: sign this W-9 and we’ll let you come into compliance and then we’ll (conditionally) let you not file for a while until the law gets changed again.

   I don’t know why anybody would want to bother when those who want to hang on to US citizenship already have the option of no filing or minimal filing (zero tax due).

8. Wildly inaccurate item about the EU Parliament vote (e.g. the claim that to be “approved” for renunciation a USC must prove five years tax compliance)

   https://www.cambridge-news.co.uk/news/cambridge-news/grandmother-toddler-dollars-usa-14873554

9. Now that Bopp’s hand-picked conservative (https://www.law.com/nationallawjournal/2018/07/03/conservative-lawyer-bopp-urges-trump-to-pass-on-kavanaugh-for-scotus/) is well on the way to the Supreme Court bench, all the anti-RoeFATCA case needs is plaintiffs.

10. Preserving FATCA for weapon against Roe. No change to FATCA until US-resident plaintiffs have been dredged up and the case has wound its way through the lower courts again.

11. I said:

    “Bopp’s hand-picked conservative ”

    Correction – I misread. Apparently Bopp wrote to Trump but did not argue in favor of Kavanaugh. Apologies.

12. Solomon Yue confirms that the proposed legislation he refers to would not do anything to alleviate the FATCA-generated bank access problems of citizens of other countries who have a US place of birth:

    “We hope your bank will be satisfied with the Territorial Taxation For Individuals qualified non-resident certification to allow you to open bank accounts & renew mortgages. If not, we still need another bill to waver [I’m guessing he means waive] your #FATCA/#FBAR reporting.”

    (Like it’s the bank that’s to blame. Just exactly like that US Ambassador to Switzerland who lambasted the frozen-with-fear Swiss banks for closing USC accounts!)

    So that’s two bills that can’t be got through Congress. Oh, plus the one that’s going to fix the transition tax.

13. Eric – thanks for the link to the Bloomberg article on section 962. Comments are open on the TaxProf Blog. Here is my comment there (currently under moderation):

    Before you jump to plug this “loophole” consider how section 962 plays out for US expat entrepreneurs who have been inadvertently burdened with both section 965 (repatriation) and section 951A (GILTI). Section 962 allows these taxpayers to offset US tax with the tax they have already paid in their home countries on the same income. In the year that the US tax code treats undistributed income of the CFC as taxable to the shareholder, section 962 allows a deemed paid credit for the home country tax paid inside the corporation. While US tax on the subsequent distribution is higher due to the interaction between section 962 and section 959 – there will be home country tax on any dividend distribution which will offset much (if not all) of the US tax due. And, given that GILTI is its own separate FTC basket with no carryovers or carrybacks, the deemed paid FTC from section 962 may be the only way for individual US shareholders to offset US tax on GILTI with tax already paid at home.

    Of course, the real solution to this problem is for the US to join the rest of the world and tax based on residence (and source) rather than citizenship. The current system of taxing the residents (and often citizens) of other countries is a 19th century idea that has no place in a globally mobile 21st century economy. Until this is fixed there will continue to be instances where laws which make perfect sense for US resident taxpayers have devastating unintended consequences for tax residents of other countries who happen to be US citizens as well.

14. @plaxy

    TTFI is a complete waste of time for most Accidentals. It might help single-citizenship US expats who fear the loss of their passport, or those already compliant, but for anyone else the US tax system isn’t a problem because, obviously, they are not in it and will not ever be in it. The one significant problem for Accidentals is loss of banking access with a US birthplace thanks to FATCA, and that will not be improved by TTFI.

15. Nononymous:

    “TTFI is a complete waste of time for most Accidentals.”

    No worries, it’s never going to happen.

    The risk is that USCs might delay renouncing on the basis of yet more lying promises from US politicians.

    As for “accidentals” – aren’t we all? Except those who took US citizenship or PR status of their own free will.

    “The one significant problem for [the US-born] is loss of banking access with a US birthplace thanks to FATCA, and that will not be improved by TTFI.”

    Yep. Or as I mentioned above:

    “the legislative initiative being twitted about by Solomon Yue, besides being unlikely to get anywhere, doesn’t offer anything at all for those who don’t want to be treated as tax criminals for having been born in America.”

16. usa greatness and exceptionalism:

    Case Study Example: HELLO BANK!

    Can I open a basic banking account if I am not a citizen of Belgium?
    “Yes, certainly, but you must live in Belgium. However, there is an exception to this rule. A US citizen cannot become a customer.
    To comply with US tax (FATCA) and other legislation relating to accounts held by US citizens or residents of the United States, the bank cannot authorize US citizens to subscribe to a free Hello bank! offer.”

    The realistic chances of repealing FATCA, CBT, is akin to turning around an aircraft carrier in a bathtub.
    RENOUNCE.

17. And yes, many of those happy talk, keep the false hope alive, delusional optimism polly cheerleaders are simply using usa empire propaganda psych ops to boost whatever political party holds ‘power.’

    Much of what Mr. Yue is proclamating will not get much traction, wait till next yr, and yes, may delay folks renouncing due to false hope. If one cannot open a bank account, have access to mortgages, credit lines, assurance, funds, etc…then all the we musts, we shoulds, we need tos, we oughts to, anecdotes, etc are a waste.
    The us empire has CONTEMPT for its “foreign” tax base /tax subjects, Remember–we’re fungible (easily replaceable per the us FATCA architects).

    RENOUNCE.

18. “Can I open a basic banking account if I am not a citizen of Belgium?
    “Yes, certainly, but you must live in Belgium. However, there is an exception to this rule. A US citizen cannot become a customer.”

    That would be against EU law. A USC has the right to a basic bank account. Money in, money out. It’s not enough.

19. Thank you Plaxy, agree thought a basic bank accnt was ok—also tried 3 other online banks–if one puts in their birth country–usa–it’s all over. Cannot grant banking to us citizens/residents due to FATCA.

    Apparently, us citizens/us residents/usa-ish folks are REJECTED and DENIED given FATCA–the first questions are –have you ever paid US taxes, are you a US citizen/resident.

    Then it’s light out. usa usa!

20. And the huge unforgivable insult is that all persons born in America must forever prove innocence or be reported to the IRS.

    No other section of EU society is treated this way purely on the basis of national origin.

21. What’s next?

    Irish need not apply? No African countries allowed.. No Jew/Jewish ancestry permitted. Anyone of Italian-origin, Italian-ness cannot open a basic bank account due to XYZ “law”–Italian hotline to review Italian-ness.

    And 99% of the us empire populace is asleep. What say you Mr. Yue regarding this overt discrimination?

22. And to kick a dying horse–the us empire CREATED and ENFORCED FATCA so usa-ers/us subjects were subjects to overt discrimination based on nationality.

    Yet the us empire states how welcoming, smiley, happy, immigrant friendly, come on down, PC BS, etc etc..

    All paths lead to: Renounce Ave

23. Jon – yes, it’s easy for them to use automated software to block you. If you go in to a branch you have a chance to argue.

    The way the basic bank account law works is that the Member State (e.g. Belgium) must make sure that basic bank accounts are available. There’s no requirement for every bank to offer one. If you look on the Belgian government website, you may be able to find which banks offer basic bank accounts. Absurd, isn’t it?!

    You could also email your MP and your MEPs and complain loudly at them about FATCA blocking you from access to banking services.

24. Thank you kindly Plaxy–crazy that we have to do all this and simply cannot have easy access to simple banking; and then the us empire states how they do not ‘discriminate’ based on national origin complete w/ PC yammer -psych ops.

    Realistically, I cannot see a real out to any of this us-feces show. My opinion is that although there’s a lot of well-meaning advocates, committees, assocations, clubs–the rate -limiting step is the us empire. They own the ‘gold’ and the rest of the “sovereign” nations are simply marrionnette puppets with the IRS- the deranged puppet master.

25. @ plaxy
    “As for “accidentals” – aren’t we all? Except those who took US citizenship or PR status of their own free will.”
    Excuse me but do you actually think that long ago PR’s now living in their home country with the citizenship of only their home country accept the designation of US person for taxation purposes forever simply because they did not know such a thing called CBT existed? I don’t and I never will. Even the CRA has suggested that such non-accidentals, as you would deem them to be, should not tell banks of their past nebulous US connection. The EQ (Empathy Quotient) of some Brockers worries me sometimes.

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