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

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

1. @Bubblebustin
   Why dont my links ever work?
   Go to youtube and put in: muslims win prayer case against webber academy
   This world is just more and more crazy….

2. Anyone feel like bursting an aneurysm? (Spoiler, there is NO mention or outrage of the treatment of US expats).

   “The new restrictions have alarmed civil rights groups in the United States, including the American Civil Liberties Union, which in a letter to the House of Representatives earlier this month called the changes arbitrary, discriminatory, and “un-American,” since they would punish individuals solely based on their nationality or ethnic origin.

   https://theintercept.com/2015/12/18/congress-just-put-iranian-americans-and-others-at-risk-for-becoming-second-class-citizens/?comments=1#comments

   Comments open

3. Is the part about the chinese bank refusing to divulge information true?

   http://www.financialsurvivalnetwork.com/2015/12/et-tu-brute-how-empires-die/

4. Aha- it is about a different kind of customer….will China pay?
   http://www.bbc.com/news/business-34981059

5. A little light relief amidst the gloom:

   http://www.clickhole.com/article/embarrassing-us-ranked-182nd-world-alphabetically-1855

6. IRS Commissioner threatens to end Streamlined. This is the same kind of ridiculous threat we heard from Douglas Schulman who claimed OVDI was your last best chance to come forward.

   https://www.taxconnections.com/taxblog/streamlined-program-will-expire-larry-stolberg/

7. That article I posted above from the Intercept needs some comments. One of the editors is Glenn Greenwald and it would be fabulous to get his attention.

8. That hilarious, Barbara. At the same time, the US should also work harder at eliminating the lowest 20% income bracket because they earn the least amount of money. They should give both these efforts 110%!

9. Is this saying the US is going with CRS or something else?

   http://www.heritage.org/research/reports/2015/12/two-little-known-tax-treaties-will-lead-to-substantially-more-identity-theft-crime-industrial-espionage-and-suppression-of-political-dissidents

10. @Polly

    That article about Webber Academy. It seems secularism is under threat when two students can be awarded damages from a non-denominational school for having been denied the right to practice their religion at school.

11. @bubblebustin, re the author of a blog post reporting that; “………. On December 17th at the George Washington University Law conference on international taxation, the Commissioner of the IRS John Koskinen said, “At some point, we will have assumed that people have had enough notice that they should have become voluntarily compliant,” “At that point—after some period of time and you’re not compliant—it will be assumed that logically you are purposely not compliant”…….
    https://www.taxconnections.com/taxblog/streamlined-program-will-expire-larry-stolberg/

    Koskinen’s ‘assumption’ reminds me of what my high school teacher said about ASSumptions …..

    If indeed Koskinen said and meant that, it is more in the same asinine and deliberately punitive flavour as Shulman and Turbotax Timmy Geithner ( http://www.wsj.com/articles/SB123198429552584175 http://gawker.com/5139875/our-tax-cheat-treasury-secretary ) particularly in light of the closure of even the few locations that offered even some IRS services ‘abroad’, the fact that the IRS is not even answering its telephones ( http://www.bloomberg.com/politics/articles/2015-07-15/irs-didn-t-answer-your-phone-call-this-year-join-the-club-
    https://www.washingtonpost.com/news/federal-eye/wp/2015/07/16/the-irs-hung-up-on-taxpayers-8-8-million-times-this-year-and-theres-more-bad-news-about-customer-service/ ) much less living up to any part of the taxpayer code of rights to be informed, etc. http://www.accountingweb.com/tax/irs/irs-adopts-a-new-taxpayer-bill-of-rights that the Taxpayer Advocate has tried to get the IRS to live up to.

    I fully expect that in early 2016 we’ll see yet another Annual report to Congress from the NTA flagging serious abuses of those living ‘abroad’ as some of the ‘most serious problems’ she flags.

    And, apparently; ” The floggings will continue until morale improves.” (as per phrase used by Phil Hodgen http://hodgen.com/why-people-expatriate/ ).

12. @Bubblebustin
    Talk about different strokes for different folks….which citizens are being treated equally nowadays?

13. @Polly

    for windows 10 users, the copy and paste method to get around a pay wall works for Firefox and Internet Explorer, but not for the Bing browser

14. @Badger

    Nice history lesson with links for newcomers or those who’d like a refresher course on why many of us are where we are today. Congress and the IRS’s lack of transparency and accountability has created the nightmarish circus that is the IRS led by ringmasters the likes of Shulman and Koskinen. And now they’re going to weaponize them with the State Department?

15. @Neill

    That Heritage article is amazing – not a single mention of FATCA, though his conclusions are exactly the same as any standard FATCA critique (bracketed comments mine):

    The [FATCA] Protocol will put Americans’ private financial information at risk. American businesses that have operations abroad or sell abroad are at particular risk [as are individuals – so-called U.S. persons]. The [FATCA] Protocol will impose substantial additional compliance burdens on financial institutions that will have a disproportionate adverse impact on smaller businesses, such as community banks and small broker-dealers. The [FATCA] Protocol will create a rich source of sensitive financial information, scattered in databases around the world, held by corrupt governments or governments with inadequate safeguards, ready to be hacked by or sold to criminals or hostile governments. The [FATCA] Protocol will also aid governments [particularly the United States] that want to confiscate their citizens’ wealth for “merely” economic reasons.

    The Senate should not ratify the Protocol. [Too late.]

    Does the IRS have a penalty yet for non-willfull hypocrisy?

16. Can anyone make any sense of this? So far, it seems that most Indians, especially NRI’s (non-resident Indians) have very little idea of the true impact of FATCA:

    http://www.firstpost.com/world/us-based-nris-dont-sell-your-indian-immovable-properties-fearing-fatca-2554630.html

17. For a major laugh read this:

    http://www.wsj.com/articles/treasurys-latest-inversion-failure-1450744017

    In their rush to try and stop inversions it seams treasury just forced companies to move more stuff offshore.

18. @Deckard1138,

    There have been a few news articles on this recently. Didn’t make much sense to me either. Maybe it’s all about getting rid of foreign stuff. Or hiding the money. You can claim you spent cash so it’s not generating income and not counting against you in assets tests.
    For example in OVDP if you have a house that generated income you didn’t report they want 27.5% of the house value even thought he income from the house might be quite modest. After tax credits you might not have caused any financial loss to the USG but they want 27.5% of the value anyway.
    It’s only a matter of time before the US wants to know about hard assets you have overseas as well. The whole world is moving to a model where the government knows exactly what you have so you can;t run away from them. It’s easier to work out what taxes to implement if you know what people have.
    Me, I am in a multi-year process of shrinking my foreign stuff down. I can hold foreign assets as ETFs treated reasonably by the USG. Foreign companies are treated better by foreign governments than the USG treats it’s own. So I vote with my money.

19. @Deckard1138 @Neill

    Old habits die hard:

    “The culture of cash has deep roots in India and tax avoidance became a habit among its wealthiest and its well-off chiefly because of the steeply progressive tax rates in the earlier decades, such as the 1980s. Income tax rates have since become moderate but old habits seemingly don’t die easily. About half of India’s black money deals are said to be in real estate transactions, where “How much in white? And how much in black?” are routine questions encountered by anyone who tries to transact. But even consumer durables, cars, and jewellery are routinely bought with black money.”

    http://www.hindustantimes.com/columns/cash-is-what-keeps-india-s-parallel-economy-afloat/story-3k86qnw4BHFlwkkvIw8lfO.html

    Maybe the fear is of the Indian government somehow finding out about these dealings through a greater exchange of financial information with the US.

20. @Neill
    Ouch. If OVDP takes 27.5% of a property’s value for non-reported income generate from it, I can see why the NRIs are transferring it to relatives. There are a lot of NRIs in the U.S. and as a group they are fairly affluent.

21. @Publius,

    There is no ‘if’ check the OVDP FAQ #35:

    The penalty applies to all assets directly owned by the taxpayer, including financial accounts holding cash, securities or other custodial assets; tangible assets such as real estate or art; and intangible assets such as patents or stock or other interests in a U.S. or foreign business.

    OVDP is a good deal for the USG. The lever of FBAR is so great as to force people to take these deals. Eventually they will push it too far and maybe lose in court.

22. @Neill
    Thanks for that. It is quite a laundry list, but basically any asset “related in any way to tax non-compliance” is fair game if I am reading it right. So, the OVDP fine is 27.55% of the value of the property for NRIs renting out property in India and not declaring the income to the IRS. But if the NRIs owned property in India but did not earn income from it, would it be included in OVDP?

    Of course, the irony is that FATCA is the brainchild of Charlie Rangel, who famously failed to declare rental income for seventeen years from property in the Dominican Republic while serving on the key U.S. tax committee. In the end, he paid $10,000 in back taxes on a property worth $250,000.

23. @Neill

    So basically…. US persons should be piss poor…. maybe they should invite all US persons who have nothing… go to the US so they can get their fair share of free handouts from the gov’t…

24. @Publius,
    >But if the NRIs owned property in India but did not earn income from it, would it be included in OVDP?

    If there was no income then there was no unreported income. Then you can remove the asset from the non-compliant pool the 27.5% penalty is calculated from. Much of my fighting with the IRS was over a single account with no income that happened to have the same account number as another account. We got it excluded in the end. I had to do PFIC calcs to avoid the fake income generated by the modified mark to market. The two different accounts were set up by two different financial advisers that chose Fidelity as the place to but the ISA’s. The sent out separate statement sheets for the two accounts but had the same account number.
    Now note it’s no unreported *income*. It’s not enough to have no tax liability. So say you earned $100 in an account and payed $35 in tax on it to a foreign government. When you include the income in your tax return it doesn’t change the tax owed. The IRS though wants the balance penalty on that account.

25. @Publius,
    Note that streamlined takes the 5% penalty from all foreign accounts even if compliant. Hard to justify that beyond revenue raising in my view.
    My agent saw ‘National Financial Services LLC’ in my tax return with big numbers. She was jumping up and down to get that included in the balance penalty because she was clueless that this is the name Fidelity uses in the US on it’s tax forms.
    She started asking for loads and loads of statements so she could check all the numbers. She succeeded in finding an error I had made and she dropped the balance penalty by a large amount as a result. At that point I think she figured she should give up and they gave in to a bunch of stuff we wanted.

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