Liberty and justice for all United States persons abroad

The Isaac Brock Society

Media and Blog Articles – part 2 of 11 (Year 2015)

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

If clicking on a comment link brings you to the wrong comment, click here  to get on the most recent page of comments.(alternatively, to reach the most recent comment page, go to  the url in the bar at the top of your browser and delete everything after http://isaacbrocksociety.ca/media-and-blog-articles-open-for-comments-part-2-of-2  )

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.  You could mention such articles in the comment stream for this page, or if I see one on another thread, I can copy the link to here. I’ll keep adding to the list, but not deleting, so we’ll end up having sort of a “bibliography” too.  [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.

Note also: JC suggests 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.

Be sure to read the comment stream for this thread — there are usually very recent articles mentioned there that are not yet on this list.

2015.01.01
Raising revenue off Caribbean backs, Bruce Zagaris, NationNews, Barbados.
On or about 2016.01.01
16 issues to make 2016 candy for the market, Westfield Times.
2015.12.31
Tax reporting norms: FinMin updates guidance note on compliance, K.R. Srivats, Hindu Business Line, India.
2015.12.30
Top Tax Blogs from 2015, Tax Connections. (Congratulations to John Richardson and Lynne Swanson who placed 2nd and 4th!)
Global dragnet puts pressure on tax evaders as year-end deadlines loom, Jeff Gray, Globe and Mail, Canada.
IRS Employee Whose Job Was Assisting Victims Of Identity Theft Charged in $1 Million Identity Theft Tax Fraud, Paul Caron, TaxProfBlog, US.
How America’s Wealthiest Are Saving Billions Through a Private Tax System, TruthDig.
RA Returns Home, TaxProTalk forum.
2015.12.29
For the Wealthiest, a Private Tax System That Saves Them Billions, Noam Scheiber and Patricia Cohen, New York Times, US.
IRS Stirs Up New Crisis With Non-Profits Over Social Security Numbers, Eric Pianin, The Fiscal Times.
DNC Must Heed Warning Bells From 2000, Bennet Kelley, Huffington Post, US.
2015.12.28
IRS Creates “International Practice Units” for their IRS Revenue Agents in International Tax Matters, Patrick Martin, Tax-Expatriation, US.
MF investors: Les than a4th comply with US tax law, Jayshree P. Upadhyay & Ashley Coutinho, Business Standard, India.
IRS service should improve after some saw their ‘worst tax season,” advocate says, Robert Schroeder, MarketWatch, US.

Articles from earlier in 2015 are at this link

 Articles from 2014 are at this link

Media and Blog Articles Open for Comment thread, Part 1 of 2, is at this link

Media and Blog Articles Open for Comment thread, Part 3 of 3, is at this link

1,837 thoughts on “Media and Blog Articles – part 2 of 11 (Year 2015)”

  2. @JC,
    Given that the US can’t impose tax on foreign profits of foreign corporations and given that the US can’t impose tax on foreign profits of non-US persons why should they impose taxes on US corporations or US persons.
    That treats two essentially the same entities differently. This drives inversions, foreign purchases of American companies, renunciations and relinquishment’s.
    The tax on foreign earned profits should be zero except possibly for residents of the US.

  4. Does or should, as it applied to US citizens RESIDENT in the US

    “Helping Americans conceal assets from the IRS was a big business for many sizes and types of firms in Switzerland, and now we’re seeing how extensive it was”

    equate with US citizenship-based taxation, and

    …our local Canadian (or other country) *foreign financial institutions* helping *US citizens who happen to abide in Canada and other countries with residence-based taxation* conceal assets from the IRS? Our assets (or account balances) are reported on FBAR to Treasury and, for some, FATCA form 8938 to the IRS. Not until we are forced to relinquish US citizenship is our net worth (*assets*) reported on Form 8854 as people find no alternative to the insanity but to give up US citizenship and its consequences for those who have chosen other countries?

    Homelanders (inside or outside the USA) may say *Just Renounce* but that is a huge financial barrier for some at the ever-increasing Department of State fee to do so, presently at US$2,350.

    *Accidental Americans* ACQUIRED a US citizenship without their consent (at age of majority) and some (those without requisite mental capacity) cannot renounce nor are their parents, their guardians or their trustees able to act on their behalf, even with a court order. If there is such a thing as citizenship-based taxation, there should never be US citizenship without a person’s consent.

  6. Didn’t know a better place to put this — The Smithsonian Channel has a documentary, “The End of Bank Secrecy”, originally shown in November 2014. I just caught the last 7 minutes while scrolling through channel listings. It looked to be about how the U.S. went after Swiss banks, but that close to the end of the show they were talking about Delaware and the U.S. as a major tax haven. This documentary repeats twice later tonight.

  7. Just talked to Geoff Martz nice guy

    http://isaacbrocksociety.ca/2015/10/19/interview-opportunity-abc-news-nightline-would-like-to-interview-an-american-living-abroad-who-is-in-the-process-of-renouncing-his-or-her-us-citizenship/comment-page-2/

    He is going to send me some questions regarding why people renounce

    He is on a steep learning curve he was not aware of many of the issues at hand / exit tax / calculations/ Boris / etc.etc

    Hopefully on a separate forum I will copy and paste his questions

    Please keep to bullet point short and concise

    I will cut and paste them to him

    Perhaps indications of relevant points brought out may help (like)

  8. Wed Oct 7:
    This week at the University of Michigan Law School, Reuven Avi-Yonah and I are co-hosting an academic workshop on the topic of citizenship and taxation.
    https://twitter.com/taxpolblog/status/651793040470728704

    I asked for an update on this. Here is the response from Allison Christians:
    Slow progress on building understanding of how Fatca affects real people who are not tax evaders. Papers to be published next year. Like politics, academics is slow. But i hope advancing the dialogue will improve the policy discourse and make meaningful reform more possible.

  9. WSJ’s provocatively titled “Inside Swiss Banks’ Tax-Cheating Machinery” mentions large cash withdrawals by USCs but doesn’t discuss a reason behind those for USCs living in Switzerland. In 2012 the approx. 100 retail banks began kicking out their USC customers. A panic began to build that there would be no banks in Switzerland which would deal with USCs residing in the country. Contingency plans were put in place by many families (and companies) on how to deal with this situation. Many families removed USC family members from bank accounts to prevent bank account closures. Another contingency plan was simply to remove cash and place it in a safety deposit box so that the USC family or individual could survive for a year or two.
    By the time the dust began to settle in 2013, there were three retail banks in Switzerland that would deal with USCs living in Switzerland. The terror was not over yet, however, as one of these remaining retail banks froze USC bank accounts in late 2013/ early 2014 until USCs produced FBARs (and possibly other US tax documentation).
    USCs in Switzerland remain deeply suspicious of the US administration and I expect that there are still large amounts of cash in safety deposit boxes. It is difficult to know if there will be an after-shock.

  10. The first example is citizenship-based taxation, which dates back to the Civil
    War income tax in the US. No other major country has adopted this rule, and
    for good reason: It is far from clear that even the US can enforce it effectively,
    especially since US citizenship can be acquired by merely being born there.
    Most of the problems with FATCA stem from taxing US citizens living
    permanently overseas

    •Reuven Avi-Yonah (Michigan) Constructive Unilateralism : US Leadership and International Taxation

    http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2622868

  12. http://www.bbc.co.uk/programmes/b05442ft

    Debt has an important role to play in the story of coinage. While coins were invented to pay soldiers, it was through taxation that they became embedded in the lives of entire populations. Ancient rulers indebted their subjects by demanding taxes which had to be paid in coinage. David reveals that this system of taxation was in fact an ingenious ploy to make subjects feed and provide for the army by creating a universal need for coinage.

  16. From good old David / Met with Finance committee previously
    https://www.facebook.com/heitordavid.pinto
    I contacted the staff of the Senate Finance and Ways and Means committees again but they didn’t respond, so I decided to contact individual congressmen. I got three meetings scheduled so far, all with Republican staff. Two are next week, one the following week. Two are high level staff, one I already met before. I’ll post something on Facebook soon.

  17. @JC and Calgary. I’ve never seen that Ralph Goodale piece. That could be huge since he may well be in JT’s cabinet soon. Where was Ralph when the NDPers were doing the heavy lifting in question period when this bill was rammed through?
    Tricia,sorry about the Blue Jays! A real punch in the gut….but when you strand 12 men on base in one game, you can’t win against KC! 🙂

  18. MP Goodale made the comment below about FATCA, but that is all I could find;
    https://openparliament.ca/debates/2011/9/30/ralph-goodale-1/

    Oral Questions

    September 30th, 2011 / 11:55 a.m.

    Liberal
    Ralph Goodale Wascana, SK

    “Mr. Speaker, there is concern across the country among many law-abiding Canadian citizens and taxpayers about the long arm of the U.S. tax collection department. Even the Canadian Bankers Association is upset. The Americans are trying to enforce their laws beyond their borders and are threatening Canadians to that effect.

    So far, the government has offered Canadians tea and sympathy. Will the government do something a little more tangible? Will it set up an advocacy centre to actively inform and assist Canadians who are unfairly being put upon by the extraterritorial excursions of the U.S. IRS?”

    Note the response below, of the Con MP Menzies who answered him;

    https://openparliament.ca/debates/2011/9/30/ted-menzies-5/
    Taxation
    Oral Questions

    11:55 a.m.

    Macleod
    Alberta

    Conservative
    Ted Menzies Minister of State (Finance)

    “Mr. Speaker, certainly we are concerned with what is happening to many honest taxpaying Canadians who were not expecting this to be imposed upon them. The finance minister has spoken to his U.S. counterpart, saying in no uncertain terms that we do not want this unfair treatment to Canadian taxpayers who are honest law-abiding citizens. We are encouraging the U.S. to be very fair with our citizens.”

  19. @Calgray, that Goodale post sharpened me some more…..

    You know how I am a stickler on words as words have important psychological meanings and set the stage.

    A reminder to all that “clinging nationality” is an important word for those that left the USA and have the proverbial gum stuck on their shoe.

    But Calgary, here is another that I think is important. You know how I hate the term “dual national” because its a figmint term that has NO meaning in Law!!!!

    We need to start using the term “deemed national” when we talk about the USA extraterritorailly imposing their citizenship on other citizens.

    @All…..when we write our MPs we must stop using dual national but instead weave into the lexicon deemed nationals and clinging nationality.

    Clinging nationality is now an absolutely correct term because of the blatant fee requiring more than one month of average after tax earnings.

  20. @Jacdac. Make sure to post here too; some of us don’t do Facebook but we will all be interested in what happened at these meetings . I am wishing you strength and. a bit of patience but give them h*ll (respectfully). ………..

  23. @Charl

    That CBC article is a good read. It refers to the lawsuit one former lawyer with the Justice Department has against the federal government. I’d actually heard Mr Schmidt interviewed on CBC radio awhile ago. The lawsuit really should have made headlines during the run-up to the election as it explains where the Harper government got its justification for walking all over the Charter, that is when a law’s less than 5% chance of passing Charter muster was thought to make it consistent with the Charter.

    Harper really hates Pierre Trudeau.

  24. JUST put in your DOT points on Nightline forum

    Just talked to Geoff Martz nice guy

    http://isaacbrocksociety.ca/2015/10/19/interview-opportunity-abc-news-nightline-would-like-to-interview-an-american-living-abroad-who-is-in-the-process-of-renouncing-his-or-her-us-citizenship/comment-page-2/

    He is going to send me some questions regarding why people renounce

    He is on a steep learning curve he was not aware of many of the issues at hand / Exit tax / calculations/ Boris / etc.etc

    Please keep to bullet point short and concise

    Perhaps indications of relevant points brought out may help (like)

  25. Been having a Twitter conversation with Jason Ling the author of
    http://www.cbc.ca/news/politics/harper-government-s-legal-setbacks-suggest-strategy-of-confrontation-1.2729421
    after I notified him that he neglected to include C-31 in the list of battles the Harper government’s chosen to have with the Canadian people. He made me aware of another article he’d had published in the Canadian Bar Association’s National magazine, in the wake of Justice Martineau’s decision called “Ruling on FATCA’s Overreach”. He apparently interviewed Joe
    Arvay.

    http://www.nationalmagazine.ca/Articles/September-2015-Web/Ruling-on-FATCA-s-overreach.aspx

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