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. And just what can the US do extraterritorially against a Canadian-only executor of an estate whose assets are all located in Canada, i.e. has nothing located in the US for the IRS to try to grab? And what can the IRS really do extraterritorially against the Canadian sited estate and assets of someone who was also a Canadian citizen and resident at the time of their death – regardless of whether they were also considered a UStaxableperson?

   What is this ‘new’ law referred to re estate returns?

   US tax prospectors imported to Canada continue to mine the ‘gold in them thar hills’.

2. Decent article, open for comments:

   America’s Punishing Worldwide Tax Scheme

3. I commented in America’s Punishing Worldwide Tax Scheme.

   I try to always mention Brock and related websites to try and grow our community.

4. badger – as I understand it, the risk is that a USC’s executor could find themselves required by local probate law to bring the estate of a USC or former USC into compliance with the insane US tax laws. There’s ways to prevent this happening – people just need to be aware of the risk so they can plan accordingly.

5. VERY IMPORTANT! You want a change, sign the petitions. You do not want a change, do nothing.

   TTFI PETITION.

   https://mailchi.mp/12c8c8f8d63b/sign-the-2018-ttfi-petition

6. JC,

   I presume if I/we am not/are not an Overseas American(s) to whom this is addressed, with information to fill out unwise for me/us, I/we should not sign these petitions — though I/we do want change for others affected.

7. Interesting that they are petitioning against the excise tax but not the transition tax.

   I suppose the donors don’t mind about the transition tax.

8. Couple of blog posts over at Tax Connections that might be worth a pile-on. I’ve commented. Note that it can take up to 24 hours for comments to be posted.

   I’m not sure what the ROI is on these comments but whatever, it’s easy and fun.

9. RO errored in referring to the Transition Tax as an excise tax. They are consulting with experts on the issue now. Too late to correct before petition went out.

   @Calgary411

   Solomon Yue of RO responded to my query as to whether non-US persons can sign the petition:

   “Yes they can & they should sign. We will inform Congress why we have 3 groups: expats/former expats/tax reformers, including their US & non-US spouses/family members/business partners affected by both #FATCA & #FBAR, especially after the 15.5% repatriation tax passed in 2017.”

   It appears RO’s combining efforts with Grover Norquist’s Americans for Tax Reform in this petition.

   “They can sign. This time we ask 3 groups: expats/former expats/ATR tax reformers 2 sign our petitions 2 Treasury & Congress. ATR/RO joinly cash in Holding’s/Brady’s raincheck 4 #TTFI. In return we help their members 2 understand why TTFI needs 2 connect w/ TTFC & 15.5% tax hurts.”

10. “RO errored in referring to the Transition Tax as an excise tax. They are consulting with experts on the issue now. Too late to correct before petition went out.”

    Ah. Thanks for the explanation.

11. RO PETITION:

    Solomon encourages noncitizens, spouses and accidentals to sign the petition.

    The survey asks about voting. If you are not a U.S. citizen then put N/A.

    https://twitter.com/SolomonYue/status/963632531064139776

    Perhaps this should be a feature here.

12. Husband and I just signed. I hope this petition gets good support.

13. JC: I created a post for your information about the TTFI Petition. Thanks for drawing it to our attention!

14. I’m vaguely aware that for some reason Expat Forum has a bad rap around here. Nevertheless, good work can still be done:

    http://www.expatforum.com/expats/expat-tax/1398474-canadian-tuition-credit-us-tax-return.html

    Saving Canadians, one individual at a time.

    No need to comment, it’s under control, I just wanted to point out that this is another forum where we can help keep innocents out of the clutches of the IRS.

15. @Nononymous

    Many of the early Brockers came together on Expat Forum. At the time, our interest in finding out for ourselves, instead of blindly believing the tax compliance community et al, was offensive to the moderators because of the “R” word (renunciation). I am surprised you don’t remember this because you were around then, I remember. I don’t think the archive pages go back that far anymore but the some of the early posts of Brock, or some of the individual stories on the bottom of the front page, discuss what happened. Too late for me to go through now……Some of it is
    here

16. The resident condor fell from grace and the prevailing stance nowadays seems to be admirably pragmatic: file the minimum and don’t worry.

17. Sad condors:

    http://www.mondaq.com/canada/x/673244/Corporate+Tax/The+US+Transition+Tax+For+2017+More+Sad+News+For+Many+US+Citizens+Residing+Abroad

    The condors of course have no option other than to pay up. 🙂

18. @Nononymous

    Good on ya!

    @Plaxy

    Re: The Expat Forum…..I don’t spend much time over there nowadays, but I did notice that the BBC dude seems to have dropped off the edge of the earth.

    Re: the condors….Yep, there must have been more than a few long faces around the water cooler at condor central! The best part is that they’ll probably be the only ones to pay; everyone else will ignore it.

19. BBCW got himself banned I believe. I don’t know the specifics, but yes, once he was sent to sleep with the fishes the atmosphere improved dramatically, from what I saw.

    “they’ll probably be the only ones to pay; everyone else will ignore it.”

    Exactly. 🙂

20. “For US individual shareholders, there really is no new regime, only the same old one. Yet those same US individual shareholders will be called on to pay a tax for a transition to a new regime from which they are excluded.”

    Sad to see such pure capitulation.

    #NotPayingThis

21. Condors, unlike normal USC foreign corporation-owners, have no choice: the IRS has them where it hurts. heh heh heh

    Naturally they’ll be hoping to raise the necessary money by scaring normal USC foreign corporation-owners into believing they too must pay, and must also pay condors to help them do so.

22. Someone on FB made and interesting suggestion:

    “Is taxation of deemed income even constitutional? Getting that struck down would solve not only this issue, but the exit tax, the Subpart F expropriations, and derail a long-abused practice that Congress use for reasons that don’t bear inspection.

    Further, I’m not finding ANYTHING about the transition tax in the 2017 5471 instructions, even the on-line ones that are supposedly kept up to date. Today is 15 February, so one could conceivably file ASAP, and should one get taken to task, observe that one was compliant with the filing instructions in effect at the time. So the IRS would have you in court for not adhering to as yet unpublished instructions for a law with 30 year retroactivity. If I were the prosecutor on that particular case, I would resign from my job in advance, because I would certainly be asked to do so after losing the case.”

    https://www.facebook.com/groups/832130876876662?view=permalink&id=1659010577522017

    File as you always have NOW!

23. I’m sort of loving the idea of long faces at Moody’s when a few dual-citizen lawyers realize that they’ll be the first (and possibly only) ones to place their heads on the chopping block for the transition tax. I still intend to catch one of their roadshows one day and publicly ask them to assess the risks of non-compliance.

    I read the history of engagement with ExpatForum. Now it makes sense to me. I was around at that time (summer 2011) but apparently missed all the action because I never went over to the US forum. I started posting to Canada, then very quickly they created the Expat Tax board. The one thing they are still sticky about is links to other forums. Brock is fine, I can drop in a subtle link to IBS any time, but explicit mention of the far more active Germany competitor is immediately pulled. (They will at least allow a list of keywords to find their competitor via the Google.)

    Certainly now the tax forum is quite moderate. One can discuss and recommend renunciation. Bev (the moderator) takes a very practical view of these things, seems quite keen on filing “nominal” returns with fudged/subset data to just keep life simple.

    I confess to missing old BBCWatcher sometimes. I spent hours arguing and providing alternative advice, but it was always a civil debate and he (I’m saying “he” because I’ve never been more certain of the gender behind a non-gendered screen name) provided good insights into the technicalities. I never looked hard enough to figure out what he did for a living, if he was a professional condor or just a keen hobbyist. No idea what he was banned for, it happened while my attention was elsewhere, but obviously something snapped.

24. “Today is 15 February, so one could conceivably file ASAP, and should one get taken to task, observe that one was compliant with the filing instructions in effect at the time.”

    Good idea. One could thus sign the forms without risk.

    “So the IRS would have you in court for not adhering to as yet unpublished instructions for a law with 30 year retroactivity.”

    Is that even possible? Wouldn’t the first step have to be writing to you to explain what numbers they think your return should have shown? It would be a brave and stupid IRS agent that volunteered for that task.

25. Maybe we should call it “un-Compliance” in this case, or continued compliance if we continue with the status quo.

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