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. Globe and Mail article on dual U.S./Canada citizenship.

   https://www.theglobeandmail.com/opinion/article-leaving-america-why-i-gave-up-my-citizenship/

2. Very little about expatriation. It”s costs, benefits and pitfalls.

3. Cheryl – thanks for posting the link. An excellent, thoughtful article.

4. Re the G & M article. This guy reeks of smugness. So I guess those who want to retain dual status are inferior to citizens who have the superior moral judgement he has? And of course it can’t be about taxes because he doesn’t have any money. BS.

5. Yes it does make one wonder if he would have renounced if FATCA was not in existence. But renunciations of US citizenship did occur for many years before 2009-10 (I’d bet many were still related to US citizenship taxation).

   I wish that he had acknowledged how US citizenship taxation and the financial barriers to US renunciation are unjust laws, instead of accepting them without question as legitimate , as so many do.

   However, I do agree with his main conclusion that one cannot owe primary loyalty to more than one state.

6. Maybe primary loyalty is too much to ask when rejecting the lesser citizenship involves the destruction of your life within the country where you are committing your loyalty.

   Primary loyalty has nothing to do with money or renouncing the lesser Citizenship. Perhaps a demonstration of loyalty should merely be where you choose to live and accept the obligations that entails.

   I am no less Canadian because I haven’t renounced US Citizenship. I chose to be Canadian, unlike most Canadians. I also identify as an American. Whether I renounce or not will not affect that (does that make me un-Canadian?). Last I heard, the Canadian government allows dual-citizenship. Do I have to commit financial suicide to prove to other Canadians than I’m as Canadian as they are? Isn’t it enough that the Canadian government doesn’t fully respect me as a Canadian by giving my banking information to the US government just because they view me as a citizen of another country?

   No one from any country other than the US would ever need to write an article like that. To me it smells like a very ripe red herring.

7. New blog post over at Fix The Tax Treaty looking at the rationale behind GILTI.
   http://fixthetaxtreaty.org/2018/11/27/explaining-gilti-rationale/

8. Mr. A:

   “I wish that he had acknowledged how US citizenship taxation and the financial barriers to US renunciation are unjust laws, instead of accepting them without question as legitimate , as so many do.”

   Welch seemed to me to be thinking more about the difficulties for duals that can be caused by conflicting obligations from the two countries – military service being an obvious though not currently likely example.

   The problems caused by FATCA and CBT are due to one country being all too co-operative with the other country.

9. Anyone have any more information about this? I can’t seem to find the full text or even a more thorough list of the issues. But I’ll bet my bottom double-taxed dollar that nothing pertaining to us is in there.

   “A Republican who will soon step down as chairman of the U.S. House of Representatives tax committee (Kevin Brady) late on Monday released a sweeping, nearly 300-page tax bill that he said would affect Americans’ retirement savings, numerous business tax breaks and redesign the Internal Revenue Service.The 297-page text of the bill covers tax breaks for fuel cell cars, energy efficient homes, race horses, mine safety equipment, auto race tracks and many other items, as well as retirement savings plans such as 401(k)s and individual retirement accounts (IRAs).”

   https://www.cnbc.com/2018/11/27/top-us-house-tax-writer-floats-a-tax-bill-on-retirement-plans-and-the-irs.html

10. More detail, but no mention of TTFI. I’m afraid if this tax bill even makes it to the House floor, there is no chance of yet another tax measure (TTFI) being introduced anytime soon.

    https://thehill.com/policy/finance/418361-gop-chairman-releases-year-end-tax-package

11. Here’s Brady’s bill:

    https://docs.house.gov/billsthisweek/20181126/BILLS-115SAHR88-RCP115-85.pdf

    Nothing I can see about TTFI, but TTFI is suppose to be in a stand alone bill anyway.

12. @BB: But I worry that the existence of Brady’s bill kills TTFI in the cradle. If you look at the few serious comments about Brady’s new bill, they can be summarized as: “Another tax reform? Haven’t the Republicans done enough damage already? Now they sneak this in at the last minute?” Brady keeps chanting bipartisan-bipartisan-bipartisan about this one, but the perception remains the same.

    So imagine, a TTFI bill comes up, and influencers say, “Aw, c’mon! More tax breaks? Enough is enough!”

    What’s more, if Brady–someone allegedly sympathetic to RBT/TTFI–was unable or unwilling to introduce TTFI before his chairmanship ends, what hope do we have that a Democrat chairperson of Ways & Means will put it through?

    I seriously think this is the end of the road. We’re all f***ed.

13. @Babara

    Yep.

14. It’s been said many times before, giving rich ingrates that have abandoned the country and refuse to pay their fair share complete freedom from paying any taxes at all is political suicide.

    The US government is apparently incapable of putting this abomination this right.

    Local governments will continue to fail to protect their own residents and citizens by facing up to the US government and will continue to tell them they need to seek redress with the US themselves. They know that the problem is self rectifying, one way or another.

15. Or perhaps they’ll find out they can’t legally do what they’re doing.

16. Barbara: I fear you are right. But I hope the results of our upcoming date in Canadian court will begin some sort of tangible, legal push-back against the US from outside that country, at least as far as FATCA is concerned.

17. Concern as Brady tax bill fix legislation lacks called-for fixes for US expats
    November 29, 2018
    Written by Helen Burggraf

    https://www.americanexpatfinance.com/tax/item/65-concern-as-brady-tax-bill-fix-legislation-lacks-fixes?fbclid=IwAR08bzTO_yV5RPaZ0iqARHLZT0Y9Y53SY9xv8pLy6-TzD2IEK7Mvuvuh69U

18. I’ve posted the next installment of my series explaining GILTI – http://fixthetaxtreaty.org/2018/11/30/explaining-gilti-measurement/

19. An interesting tussle over the seldom-applied $50,000 threshold for FATCA reporting.

    “Could Israel face international sanctions over OECD agreement?”

    http://www.israelnationalnews.com/News/News.aspx/255118

    Knesset Finance Committee Chairman MK Moshe Gafni (United Torah Judaism) has refused to allow the advancement of the CRS agreement until regulations protecting certain haredi charities from FATCA are passed, even though the issues are separate.

    Haredi and Orthodox free-loan associations, known as “gemachs”, can be affected by FATCA regulations. Gemachs allow members of the community to freely donate items such as clothing or furniture and for less well-off members of the community to receive those items for free.

    Israel’s anti-money laundering authority has warned that such institutions can be used for money-laundering and tax evasion schemes, though such occurrences have decreased in the past decade.

    US authorities agreed to exclude gemachs that hold less than $50,000 from FATCA regulations. However, the Justice Ministry gave the Knesset two years to pass regulations grounding the exemption for small gemachs in law. The deadline to pass the regulations ended in August.

    MK Gafni refuses to allow the CRS regulations to advance for a vote in the Knesset until the FATCA issue is resolved and the gemachs are protected.

20. What a mess!

21. How GILTI rules differ for individual US Shareholders of CFCs
    http://fixthetaxtreaty.org/2018/12/05/explaining-gilti-individual-impact/

22. Update from PurpleExpat

    https://mailchi.mp/92405e962dd1/newsletter-dec-2018?e=bb47b3b156

23. Monte Silver is at $39,718 of $50,000 goal for legal action.

    Monte Silver: I thought it might be interesting to see what a behind the scenes email with very senior Treasury officials looks like (Secretary Mnuchin cc). This email displays what the issues are, how legal arguments are laid out, and …the amount of work involved. .

    The email was included in my memo to the Transition tax comment period so it is public record. Using the words “bad faith” in the subject line does set a tone.

    https://drive.google.com/…/17yky-6_xUElzZPgOcoZXoPdeg…/view…

    Let me know your thoughts.

    https://www.facebook.com/groups/americansmallbusinesses/permalink/575140062950812/

24. December 2018 Update on Tax Reform for US Persons Overseas.

    Anthony Parent, Keith Redmond, John Richardson

    Keith says TTFI bill will be introduced in before Christmas.

    Also that there is a French FATCA Lawsuit ~19.40. I have no other reference to that.

25. Interesting article on how a cash strapped IRS is finding it difficult to pursue taxpayers: https://www.propublica.org/article/how-the-irs-was-gutted?fbclid=IwAR3TYUoVdwce1RLezgiIxCFU4fQcF6w-bHigUZHR64uDPmeIfaoYTmnDo7s

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