Liberty and justice for all United States persons abroad

The Isaac Brock Society

Media and Blog Articles Open for Comments – Part 5 of 11 (Year 2018)

You can access all years at this link: Media and Blog Articles – Links for All Years

If clicking on a link brings you to the wrong page in the comment stream, click here to get to the most recent comments.

Media and Blog Articles

EmBee suggested that it would be good if there was a thread for new articles, so that people would be aware of where to comment.   So, I created this permanent page.   I’ll make a permanent list of links posted here and keep adding to it,  but not deleting, so we’ll end up having sort of a  “bibliography” of FATCA/CBT articles.  [Note:  Some articles are not open for comments]

For more articles on FATCA, enter FATCA into Google then click on the link “more news for fatca” just below the most recent featured article.

Notes:

From JC:   To see #FATCA on Twitter for latest breaking news.  JC finds that is quite a good source and there even are some international articles that one may read using Google Translate.   Others may help certain tweets and articles remain in elevated position by retweeting them.

From Badger:   On an important archival note, please use the Internet Archive Wayback machine https://archive.org/web/ (see bottom right ‘Save Page Now’ box to enter URLs of webpages you want saved for posterity, and try to save backup copies of articles and other items of interest in some other form – such as a datastick or external drive. Some important and very significant webpages and the fulltexts of articles are no longer available (although some can be retrieved if someone using the Wayback machine saved them).

Be sure to read the comment stream for this thread — there are usually very recent articles mentioned

2018.12.23
New bill could lessen tax woes for Canadian residents with US citizenship: but the outlook is bleak for thousands grappling with Trump’s repatriation tax, Elizabeth Thompson, CBC News, Canada.
2018.12.21
Tax Fairness for Americans Abroad Act of 2018!  Let’s Get This Passed! Anthony Parent, John Richardson, Keith Redmond, IRS Medic. US.
TTFI bill introduced today, great news for Americans living in Canada, Reddit Forum.
FATCA: Significant Relief in New Proposed Regulations, Jeremy Naylor, Amanda H. Nussbaum and Martin T. Hamilton, Mondaq.
2018.12.20
Tax Fairness for Americans Abroad Act, Democrats Abroad.
2018.12.19
TCJA and US Expats, Karen Alpert, Fix the Tax Treaty, Australia.
2018.12.18
Why Banks Have Become Judge, Jury & Prosecutor and will Shut you Down Judged Guilty for Nothing That is Actually Illegal, Patriot Rising.
20`18.12.17
IRS Issues Proposed FATCA Regulations, Adrienne M. Baker, Joseph A. Riley and Jeff J. Kang, Lexology.
2018.12.13
IRS Issues Proposed Regulations on FATCA, Other Reporting Conditions, ABA Banking Journal, US.
2018.12.11
How the IRS as Gutted, Paul Kiel and Jesse Eisenger, ProPublica, US.
2018.12.08
December 2018 International Tax Reform Updates- FATCA -GILTI – TTFI, Anthony Parent interviews Keith Redmond and John Richardson, IRS Medic. (video)
2018.12.05
Explaining GILTI – Individual Impact, Karen Alpert, Fix the Tax Treaty, Australia.
2018.12.03
Luxembourg: Exchange Of Information Vs Data Protection: A Brave New World Of Transparency, Antoine Dupuis and Guilles Sturbois, Mondaq.
2018.12.00 (December 2018 edition)
EU parliament versus FATCA, Financier Worldwide.
Newsletter, Purple Expat.

 Articles from earlier in 2018 are in the Media and Blog Articles 2018 Archive.  Links to previous years’ archives are also at that link.

1,714 thoughts on “Media and Blog Articles Open for Comments – Part 5 of 11 (Year 2018)”

  1. Just like the USG/IRS wants US persons resident overseas to include ALL their global income – top line number – from which tax credits/FEIE etc. may be applied, likewise I ask for a top line number of $75-113 billion – each year – for resident services for USP overseas. No doubt if something would be figured out that there might be some deductions etc from that top line number. A point is to highlight the U.S. government tax cheating on the “compact” of tax jurisdiction between the government and the people which – by accepted norms – involves, in exchange for taxation, the provision of resident services and protection of local property and individual rights: which the USG basically provides ZERO of for USP overseas.

  6. Banks are standing on the wrong side of history — with Trump
    By Paulina Gonzalez, opinion contributor — 08/09/18 09:30 AM EDT
    http://thehill.com/opinion/immigration/401032-banks-are-standing-on-the-wrong-side-of-history-with-trump?

    My comment: Trying to attract attention to our issues commenting on an article with related issues:

    http://thehill.com/opinion/immigration/401032-banks-are-standing-on-the-wrong-side-of-history-with-trump?mode=comments#comment-4031778702

  7. Someone has a sense of humour re the lack of IRS services for resident US taxpayers.

    “And again, because people need back tax help, they need to get copies of their transcripts. In looking at the different ways that the IRS is considering how to get transcripts, I think if you’re there on a Tuesday online, the moon is waxing and, you know, there’s like a gerbil in the room, you qualify. I think it’s like a very narrow set of people that are going to be able to use that. And again, for the folks that we have, the more hoops that you put through, it makes it more complicated. And if you already have a busy life and you’re trying to figure out something stressful, putting more hoops in front of folks, they’re just not going to do it. They’re not going to move forward. And then they’re actually going to end up in even more of a tax compliance situation.”

    Try fiery hoops for non-residents.

    https://www.taxconnections.com/taxblog/irs-continues-to-close-taxpayer-assistance-centers-despite-taxpayer-advocate-service-and-congressional-concerns/

  9. Posted by Monte Silver on Facebook:
    https://www.facebook.com/groups/102486093177364/permalink/1839588302800459/

    Americans Abroad with small businesses subject to Repatriation/GILTI taxes:

    To get an exemption for American small businesses abroad from the Repatriation tax, last month we focused on Senator Cassidy of Louisiana who volunteered to assist. It worked and we have a draft bill in hand.

    Now we focus on Ohio Senator Portman for a bill exempting us from GILTI. Portman responded and wants to speak to Americans abroad impacted by GILTI. If you or someone you know owns a small business abroad and is impacted by GILTI – or the Repatriation tax, IT IS URGENT THAT YOU CONTACT ME BY PRIVATE MESSAGE OR AT MS@SILVERCOLAW.COM

  11. https://www.nationalreview.com/2018/08/american-expatriates-deserve-territorial-income-tax-system/

    Alas, another article which tries to support our side but ends up having the opposite effect. By trying to squeeze everything into a single 750-word piece, there is no room for explanation. Hence, the reader is delivered the “fact” that expats enjoy a $102,100 tax exemption, and are somehow affected by some vague banking thing called “FATCA”. The author tries to point out that US expats are good cultural ambassadors and start businesses, but fails to explain why this makes us deserving of yet another tax concession (which is how readers will interpret the article’s premise).

    The argument is vaguely made, and the readers fixate only on that $102,100 FEIE, as can be seen in the comments.

    Another opportunity squandered by a journalist with the best of intentions, but who is very bad at constructing a rhetorical argument. What a shame.

  13. @BB
    I think the idea of the USA getting first dibs while Canada gets the dregs kinda stinks. These are Canadian companies earning their profits in Canada. However, being double taxed stinks too. (Preemptive strikes are as abhorrent in taxation as they are in warfare.) Sounds like M-G is thinking inside a box decorated with the stars and stripes. But they probably have more sway with our gov’t than all the Canadian residents affected by TT/GILTI so more Canadian acquiescence could happen. I wouldn’t call it “an elegant legislative solution” though.

  14. @EmBee

    The idea of paying “America First” is repugnant to me. It’s as though the corporation is no longer Canadian even though it may earn all its income solely in Canada, pay Canadian corporate taxes, employ only Canadians and be owned by Canadian citizens. I asked RB if he think the Canadian government would actually agree to this or is this suggestion a reductio ad absurdum argument against the Transition Tax.

    I think MG is thinking outside the brain box on this one.

  15. Barbara–the author was a 34 yo millenial american. What can we really expect? Doesn’t know what he doesn’t know. Many cannot or will not thk clearly, or can construct a critical argument with well-researched evidence. There’s a huge difference b/w opinion and creating a well-researched argument. Unfortunately, that article was mediocre at best–perhaps, intentional. america was “famous” at simpleton “articles” masquerading as investigative journalism, or critical thinking.

    Seriously–can ANYONE say “USA” with a straight face. 400yrs+ of hustling, huckstering, and war mongering imperialism. All roads lead to renounciation-amen!

  16. Typical Berg.

    It’s a non starter. Why should Canada give a tax credit for illegitimate taxes paid to a foreign country?

  17. @ Sara T,

    Thank you for taking part in the discussions here. However, we have a “one name only” rule for commenting. Please stick to using only one name in your future comments; otherwise, we may remove them to avoid confusion.

    Site Rules are accessible through the Sidebar in the first item in the Important Information box.

    “Site Rules: For information on site rules, please see the paragraphs numbered 1) Use only one alias and 2) No personal attacks, in this post, – Our Isaac Brock Society: Taking Stock of Where We’re At.”

  18. This footnote is interesting, or rather it’s interesting that the tax firm chose to add this apparently unnecessary footnote.

    [1] Some media are also reporting that the recent proposed Regulations continue to pile on damage to affected persons. However, our firm’s view is that the proposed Regulations are consistent with previously issued guidance and simply provide further clarity on some issues (for example, US citizens who renounce their citizenship will no longer be able to pay the Transition Tax over an 8-year period and any remaining liability would be due and payable at that time).

    In reality, of course, renunciation would be a reasonable way for a Canadian citizen to give the transition tax a miss, provided the individual (a) has no US assets or ongoing need to interact with the US, and (b) is content to renounce cleanly (i.e., without filing any US tax forms).

    Renunciation is perhaps not a viable option for dual US tax advisers hit by the transition tax; but it might be a good solution for some of their erstwhile clients.

    Poetic justice.

  19. @poetic justice.
    My sentiments exactly!!
    I had a Swiss resident, American IRS enrolled agent tax accountant (who was married to a Swiss citizen) do my final returns . When I remarked that hopefully the US would eventually join the rest of the world and adopt RBT which would prevent all these renunciations, she remarked ” Oh I hope not, my business is booming”

  20. This should be a feature in its own right.

    This is the meeting on day 2 with Solomon Yue, John Richardson & others. Any video of the Amcham meeting?

  23. Why Is Bank of America Asking Clients About Their Citizenship?
    https://www.thenation.com/article/why-is-bank-of-america-asking-clients-about-their-citizenship/ (archived https://archive.is/cXTMY)

    First article about Bank of America I’ve seen that explicitly mentions CRS (and implicitly mentions FATCA), though the author blurs the distinction between tax residence and citizenship:

    The reports started trickling in to online forums and local news, starting in 2017. From Reddit to The Kansas City Star, Washington to New York, the stories all followed roughly the same pattern: Bank of America sent a customer a notice demanding details about their citizenship—and if they refused to answer, their accounts were promptly frozen.

    Outside the United States, this is a normal practice. Dozens of countries have agreed to the Common Reporting Standard aimed at combating tax evasion, and began collecting citizenship information as part of that effort in 2017. …

    Under a separate law, foreign banks must collect citizenship information from Americans, ostensibly in order to track down potential tax-dodgers.

  25. Ok, let’s say it is due to the Patriot Act. Why now? Patriot Act is how many years in existsnce snd they are just now getting around to following it? Why?

    Not saying that it is not due to the Patiot Act but if it is, we shoukd explore why it is only now being followed.

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