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.
Yeah, yeah, yeah. I’ll believe it when I see it.
I breathed a huge sigh of relief when the Repubs. won both houses thinking that at least for the time being my passport would be safe. But, then Hatch (R Utah (?) finally snuck in the passport revocation provision after failing two or three times.
We’ll probably be offered complete obsolution for the small price of 5,827 pages of ‘disclosure’ returns each year thereafter.
“Yeah, yeah, yeah. I’ll believe it when I see it.”
Indeed. They might lose control, or come close to losing control. The voters who found themselves paying for the TCJA tax cuts might be quite disgruntled at the prospect of further tax increases; and of course 2020 is already on the horizon.
https://www.angloinfo.com/blogs/global/us-tax/the-problem-with-pfics-a-fairytale-definition-pfics-live-happily-ever-after/
Not news, but an interesting rundown on the history of the PFIC regime, and the reasons (or justifications) for creating it.
““Yeah, yeah, yeah. I’ll believe it when I see it.”
Indeed. They might lose control, or come close to losing control. The voters who found themselves paying for the TCJA tax cuts might be quite disgruntled at the prospect of further tax increases; and of course 2020 is already on the horizon.”
All true, but even if they win in a landslide and have historic level of control I doubt that whatever they dream up will not be much of a help except those wealthy enough to pay others to prep. their taxes and donate huge sums to a canidate.
The repubs. winning the Senate shoukd have been either salvation at its best or at least no worse for us. Now we have the passport stuff AND a new tax law that needs to be fixed right out of the box. Not a good track record.
Depending on who wins, we are likely to get worse than we now have or a hell of a lot worse than we now have.
Hope I’m wrong, but….
I said:
“Does this somewhat enigmatic statement imply that redefining what is a PFIC might achieve a revenue-neutral score?”
Maybe not. It looks like the TCJA has caused some interactions between the current definition of a PFIC and the subpart F rules, with, as they say, “unintended” consequences. (https://www.taxnotes.com/tax-reform/news-analysis-tcja-when-pfic-becomes-controlled-foreign-corporation)
It may be that a new PFIC definition is needed in order to sort out that confusion, and as a side-effect, the Holding bill can’t be scored until the PFIC definition is known.
By the time they finally get it sorted out, they’ll be no more USCs living abroad, all having had their families and lives torn apart long before then.
Except of course for the (1) all the duals who renounce without having anything torn apart except a chunk of their wallet, and (2) the millions of duals and accidentals continuing to safely live happy non-compliant lives.
Your situation may (or may not) be bad, but don’t assume that everyone else is as vulnerable.
If one doesn’t need the US passport, one cannot have US tax problems. One may have FATCA problems, depending on the situation, but that’s an easy fix (for $2350).
“Except of course for the (1) all the duals who renounce without having anything torn apart except a chunk of their wallet, and (2) the millions of duals and accidentals continuing to safely live happy non-compliant lives.”
I specifically said “USCs”. Duals are not only “USCs”.
The current cost to renounce is not easy fix for those of us who are not rich.
No reason a genuinely bi-partisan solution should be out of the question.
A bi-partisan solution ought in theory to be less susceptible to being reversed and re-reversed at the whim of the US electorate.
The whole US international tax regime -covering taxation of foreign investments of US citizens regardless of residence – seems to be in such a mess that some simplification would be in the interest of both parties. The Holding bill is alleged to have bipartisan support, and the DA statement does not call that into question. If indeed bipartisan, some version of the bill may eventually get enacted.
“USC-only” may be clearer to some readers, to distinguish from USC duals. And yes the fee is a significant barrier for many.
Transition Tax hearing tomorrow:
https://www.federalregister.gov/documents/2018/10/15/2018-22345/guidance-regarding-the-transition-tax-under-section-965-and-related-provisions-hearing
“No reason a genuinely bi-partisan solution should be out of the question.
A bi-partisan solution ought in theory to be less susceptible to being reversed and re-reversed at the whim of the US electorate.
The whole US international tax regime -covering taxation of foreign investments of US citizens regardless of residence – seems to be in such a mess that some simplification would be in the interest of both parties. The Holding bill is alleged to have bipartisan support, and the DA statement does not call that into question. If indeed bipartisan, some version of the bill may eventually get enacted.”
All true. I just do not see any reason for large scale support. What political gain is there if they do? What political pain is there if they don’t? If they did things ust because it is the right thing to do, there wouldn’t be a need for IBS or any of the lawsuits, letter writting campaigns, etc..
Only time will tell, but whatever we do get, some kind of compliance with a far away master is most likely a major component. This compliance will seem just and easy to the homelander but outrageous and impossible to the USC abroad.
“And yes the fee is a significant barrier for many.”
Though not for those with US tax problems: it’s always going to be better value to renounce than to pay top-up taxation.
“If they did things ust because it is the right thing to do, there wouldn’t be a need for IBS or any of the lawsuits, letter writting campaigns, etc..”
Very true. However, there are policy goals which do attract bipartisan support. Not out of concern for expat USCs (I honestly doubt if any politicians in either party lose any sleep over that, given that average expat USCs have little influence either electorally or as donors); but to defend the US financial system from foreign exploitation of the zillions of twisted tax loopholes created by corruption and lazy tax-writing.
“whatever we do get, some kind of compliance with a far away master is most likely a major component. This compliance will seem just and easy to the homelander but outrageous and impossible to the USC abroad.”
There’s compliance, and there’s sort-of-compliance. Lurk on the tax boards of some expat forums if you want tips on the latter.
Thanks, but I do not get enough sleep to entertain even sort of compliance.
I don’t live there, receive nothing from there and have enough difficulties to not need any more from afar.
And with that, I am off to bed, it being past midnight here.
“I don’t live there, receive nothing from there and have enough difficulties to not need any more from afar.”
If the passport is one of the requirements for continued residence and eventual citizenship, you’re receiving an inestimable US benefit; one worth the trouble of filing FBARs (if you have accounts over $10K). No
need to file 1040s; the IRS won’t waste time fretting about whether you were or were not making enough money to pay US tax.
That’s how I would deal with it, if I were in that situation; however, you also do of course have the option of doing nothing and waiting to see ehat (if anything) transpires.
FBAR fines don’t count towards passport revocation, if I’m not mistaken. Only taxes owed and associated penalties.
“FBAR fines don’t count towards passport revocation, if I’m not mistaken. Only taxes owed and associated penalties.”
The point of filing FBARs (if required) would be to establish compliance, in case the Japanese naturalisation procedures include questions on the matter, when it comes time to apply for Japanese citizenship and renounce US citizenship.
@ BB
Ah, a hearing for the Transition Tax. May the verdict be guilty (of crimes against expat entrepreneurs) and the sentence be the death penalty. 😉
More twisted logic.
“If the passport is one of the requirements for continued residence and eventual citizenship, you’re receiving an inestimable US benefit; one worth the trouble of filing FBARs”
No. One does not receive a passport from the US. Mine cost $150.. Considerably more than than those from some other countries. And it is not worth spying on my family and employers. While a passport is a requirement to continued residence, a US passport is not.
“I were in that situation; however, you also do of course have the option of doing nothing and waiting to see ehat (if anything) transpires.”
Something already has transpired. All my financial data is being sent to agencies in the US with poor track records of protecting the personal data they receive.
“…it is not worth spying on my family and employers.”
Indeed.
I said:
“The point of filing FBARs (if required) would be to establish compliance, in case the Japanese naturalisation procedures include questions on the matter, when it comes time to apply for Japanese citizenship and renounce US citizenship.”
Alternatively, continue living in Japan without applying for citizenship.
What does your wife want you to do?
“Alternatively, continue living in Japan without applying for citizenship.”
Sadly no alternatives exist for those with the resources of time and money.
My wife refuses to believe that any Japanese FI would supply any information to the US or any other government outside Japan.
She and her family are dissapointed that I am NOT going to register our children at the US Embassy as births abroad and get US passports for them. They do have Japanese passports.
How do you mean?
Do you mean that you can’t remain indefinitely in Japan without taking Japanese citizenship and renouncing US citizenship?
With a view to moving to the US? Or remaining in Japan?