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 managed to screen shot the first few paragraphs of the G & M article. Mr Marino from Moody Gardner is quoted.

   The funny thing is, it’s too late for Canadian business owners to avoid this tax by renouncing as it is retroactive. Let’s not let any tragedy go unexploited though!

2. Moodys Gartner has a blog piece commenting on the transition tax:

   If nothing is done, the transition tax would occur on the U.S side of the equation without any corresponding Canadian tax. The transition tax would not be recognized as a foreign tax credit for Canadian tax purposes because the tax does not relate to a foreign source of income (from the Canadian perspective).

   This essentially leads to double tax for these U.S. citizens residing in Canada.

   https://moodysgartner.com/top-ten-us-tax-reform-changes-will-impact-everyday-canadians/

   You would think that a taxpayer in this situation (if they didn’t want to renounce) should be able to raise a complaint under the treaty Mutual Agreement Procedures.

   Surely the Canadian Competent Authority would not agree to forego its primary right to tax these Canadian-source earnings of a Canadian citizen and resident.

3. BB – “The funny thing is, it’s too late for Canadian business owners to avoid this tax by renouncing as it is retroactive. ”

   The US can’t retroactively tax non-US-citizens on non-US-earnings.

   A dual Canadian business owner might prefer to keep the citizenship and pay the tax, or dump the citizenship yet pay the tax, but both of those would be a voluntary choice. A third option would be to renounce and file nothing.

4. The Globe and Mail posted the article in its entirely on it FB page. Try this link:

   https://www.facebook.com/theglobeandmail/posts/10156018943448904:0

   Mentions it’s too late to renounce to avoid this tax. Just about to wade into the comments.

5. It’s too late under US tax law, but a Canadian-only citizen residing in Canada is not subject to US tax law except in regard to US-source assets/income.

6. Basically an infomercial for Moodys in Calgary. Not much new. Claims its too late for the repatriation tax- best to not mention your company.

7. “best to not mention your company.”

   Best to renounce and tell the US to get knotted, IMO, but only the person being threatened by this tax can know what is the best option for them.

8. Save your brain and avoid the comments section. Turns out there are just as many halfwits north of the border as south of it. Depressing.

9. It’s in the print edition. ” Professional advice……. is always recommended……..to not be barred” said Mr. Marino of Moods Gartner.

10. @Nononymous

    I was poised to comment and then decided not to bother. The “halfwits” are living in an alternate reality and can’t be reached. Any expat who pays that tax can only blame themselves.

11. “Professional advice……. is always recommended……..to not be barred”

    This is nonsense. It’s perfectly easy to renounce US citizenship without getting banned from the US.

12. @Plaxy & Nononymous

    Thanks. I deleted the app. Only used it once to deposit cheques.

    Will deleting it be enough?

13. I don’t know. I avoid using mobile banking. I think you would need to contact the bank, and cancel the mobile banking service. But it may be different in Canada.

14. It looks like the full text of the Globe and Mail article, “Tax reform leads US entrepreneurs in Canada to consider giving up citizenship,” has turned up at PressReader (no paywall).
    https://www.pressreader.com/canada/the-globe-and-mail-bc-edition/20180129/281947428284371

15. Switzerland suggests it’s time to move on:

    Switzerland asks US to swiftly conclude proceedings against Swiss banks (The Economic Times 1/26/18), here. Excerpts:

    Switzerland today asked the US to swiftly conclude proceedings against some Swiss banks for better banking activities, as its President Alain Berset met his American counterpart Donald Trump.
    * * * *
    With regard to the banking dispute, the Swiss delegation explained that it would be beneficial for bilateral business activities if the proceedings against Swiss ‘Group 1 banks’ were to be concluded swiftly.
    [..]
    Some Swiss banks are facing regulatory action from the US authorities for allegedly helping American citizens evade tax.

    http://federaltaxcrimes.blogspot.co.uk/2018/01/tax-crimes-related-news-from-davos-12618.html

    with one comment referencing the Bank Frey / Stefan Buck case (see http://isaacbrocksociety.ca/media-and-blog-articles-open-for-comment-part-5-of-5/comment-page-1/#comment-8098640).

16. @plaxy
    and time for America to look at DELAWARE

17. Polly – indeed. If only.

18. The faintly comical fact is, Switzerland is standing there, telling the US it’s time to move on, and the US is standing there, carefully not looking at Delaware, and meanwhile the two of them have just appeared at the top of the list of the most secretive financial centers in the world.

    “Global study names Switzerland as capital of bank secrecy”
    https://uk.reuters.com/article/us-finance-secrecy-index/global-study-names-switzerland-as-capital-of-bank-secrecy-idUKKBN1FJ2I0

    “Report Says U.S. Is World’s Second-Biggest Tax Haven”
    https://www.bloomberg.com/news/articles/2018-01-30/u-s-seen-as-world-s-second-biggest-tax-haven-after-switzerland

    The U.S. now accounts for about 22 percent of the global market in offshore services, up from 14 percent, according to the report.

    “While the United States has pioneered powerful ways to defend itself against foreign tax havens, it has not seriously addressed its own role in attracting illicit financial flows and supporting tax evasion,” the report said. The authors criticized the U.S. for its “independent-minded approach” to cracking down on tax evasion, money laundering and financial crime.

    Delaware, Nevada and Wyoming were highlighted as hot spots for secretive “shell” companies, with nominee officers and directors who serve as a front for the actual, hidden owners.

    I would not call it independent-minded. I would call it lying.

19. Really, the US must have a far far higher proportion of offshore business than 22%. Nine million of its citizens hold offshore accounts that for some reason don’t seem to have been counted.

20. I expect the Money Launderer-in-Chief will be looking to substantially increase that measly 22%. After all, its an integral part of his “Make America Great Again” strategy.

21. Indeed. They could sell DC shell companies to non-resident USCs who can’t find a local bank that will deal with them. 🙂

22. I forgot – the State Dept already does that.

    https://app.loanspq.com/xa/xpressApp.aspx?enc=Kw21Wblm1yxpjJabdoZaD8omBxwNp1pHsZC27kLht2id_7aKjcwUX3azXWcuU9cf1iJRvzQNWteR7uog7HRk6D5a9eHIjAxc4sya0F6zrEM

23. @plaxy
    independent minded? WHAT TOTAL HOGWASH. It is such a slap in the face to use such a contrite and harmless word for people hiding their ill-gotten money in America. Why dont they NAME it when it comes to America? Switzerland is oh so evil- but America is just angelic. Makes me turn green in the face.

24. America is a superpower, I think is the reason. But that appears to be changing.

    “Makes me turn green in the face.”

    That sounds bad. Don’t let them stress you out. What goes around, comes around. I hope. 🙂

25. @ plaxy
    “I would not call it independent-minded. I would call it lying.”

    I would call it self-serving. USA#1 can do it but other nations must not dare to do it. Rather obvious way to divert the flow of capital into the USA, I’d say.

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