Media and Blog Articles Open for Comments – Part 3 of 11 (Year 2016)

2,818 thoughts on “Media and Blog Articles Open for Comments – Part 3 of 11 (Year 2016)”

1. @Neill

   Maybe you can make more of this than I can:

   https://tax-expatriation.com/2016/11/03/like-canadas-deemed-acquisition-rules-irc-section-877ah2/

2. @Bubblebustin,

   This is just about the unfair capital gains tax of the US. You can purchase say a house or a stock while not an American. As soon as you become a US person thought he US thinks it has a right to tax the gains in said property if you sell. It wants the gains in the property that occurred before you because a US person.
   The exception it talks about I already knew about. For the exit tax you can use the value of the asset when you enter the country. I thought you had to file when you enter to kind of register those values but I have never studied it closely since I have nothing from that time that would be taxed as a capital gain.
   Same old story. Money you earned outside the US can get taxed. Stuff you earned before you because an US person the US wants to tax. Stuff they haven’t taxed before you want to leave they want to tax.
   Any reasonable person would suggest America should be asking for all this stuff because it’s to the detriment of some other taxing entity. We all know it’s par for the course for them though.

3. http://www.theglobeandmail.com/news/national/in-scathing-ruling-federal-court-says-csis-bulk-data-collection-illegal/article32669448/

   In one telling passage, Justice Noël points out that controversial legislation passed in the Conservative government’s dying days has vastly increased CSIS’s access to data held by other federal departments. “CSIS no longer needs a warrant to obtain information from the Canada Revenue Agency,” the ruling reads at one point.

   Emilia Bolin
   ‏
   @nobledreamer16 Canada Fed Court say ok to collection of tax data without warrant

   Patricia Moon ‏@nobledreamer16

   Yes we know-Passed by last govt. Privacy Commish of time raised concerns about it. Nobody liked it but it is “the LAW.” CSIS out of control?

   Patricia Moon ‏@nobledreamer16

   @EmiliaBolin thank you for making me aware of this article……..

4. …and thanks to other legislation passed by the Harper government, the CRA no longer needs a warrant to obtain information on certain Canadian bank account holders.

5. @ Patricia Moon
   I used that Globe & Mail CSIS article to slip in a FATCA reference. Thanks for posting it here.

6. So 50% of one year:

   http://www.wsj.com/articles/u-s-professor-to-pay-100-million-tax-penalty-over-swiss-accounts-1478294923

7. Thanks, Neill for your reply. The IRS always gets their pound-and-half of flesh it seems.

8. Pure idiocy making the rounds on Facebook:

   https://www.crowdpac.com/surveys/if-trump-is-elected-where-should-you-move

9. @Barbara,

   If they never really want to option to be able to leave the US the next time they don’t like the candidate they should vote for Hillary. Only one party wants to make it harder to leave.

10. More on the professor and the Swiss bank accounts as posted by Neill above – this bit is especially interesting:

    Horsky directed the activities in his Horsky Holdings and other accounts maintained at the Zurich-based bank, despite the fact that it was readily apparent, in communications with employees of the bank, that Horsky was a resident of the United States. Bank representatives routinely sent emails to Horsky recognizing that he was residing in the United States. Beginning in at least 2011, Horsky caused another individual to have signature authority over his Zurich-based bank accounts, and this individual assumed the responsibility of providing instructions as to the management of the accounts at Horsky’s direction. This arrangement was intended to conceal Horsky’s interest in and control over these accounts from the IRS.

    In 2013, the individual who had nominal control over Horsky’s accounts at the Zurich-based bank conspired with Horsky to relinquish the individual’s U.S. citizenship, in part to ensure that Horsky’s control of the offshore accounts would not be reported to the IRS. In 2014, this individual filed with the IRS a false Form 8854 (Initial Annual Expatriation Statement) that failed to disclose his net worth on the date of expatriation, failed to disclose his ownership of foreign assets, and falsely certified under penalties of perjury that he was in compliance with his tax obligations for the five preceding tax years.

    https://www.justice.gov/opa/pr/emeritus-professor-pleads-guilty-conspiring-defraud-united-states-and-submitting-false

11. He thinks they will give him a visa? Maybe he thinks other countries just take anyone?
    http://observer.com/2016/11/im-out-of-here-if-donald-trump-wins-charles-rangel-says/

    I hope more go. Forgive them Obama. They know not what they do.

    http://www.forbes.com/sites/robertwood/2016/11/05/leaving-u-s-over-election-hiding-assets-on-exit-is-criminal-draws-100-million-fine/#3960882f3a32

12. @Neill, as you know too well most homelanders (I do not attribute that name to you), think getting a Visa is easy peasy because everyone “loves Americans.”

    I just love watching UK Border Patrol on the television and cheer when they deport an American at the airport.

13. Could an “Offer in Compromise” be valuable to some non-resident US taxpayers, when the IRS can’t collect or even assure mail delivery?

    https://www.taxconnections.com/taxblog/irs-needs-to-improve-its-offer-in-compromise-process/

14. This pretty much tells you everything about where USdeemedtaxablecitizens living outside the US stand and what they can expect going forward;

    ‘Expat vote seen key in US election, but candidates avoid committing firmly to its causes’

    “……… In August, as reported, the non-profit, Washington, DC-based American Citizens Abroad advocacy group wrote to the two main party candidates as well as to the two leading independent candidates, asking for their positions on eight key issues “affecting Americans living and working overseas”, as it explained in a press statement.

    However, as ACA executive director Marylouise Serrato told International Investment last week, unlike in previous election years, the organisation didn’t receive responses from any of the candidates to its letters.

    “It is not clear why there was no response,” she added. “You would need to ask the individuals we sent the requests to. We did try to follow up with phone calls, but nothing came of that either.

    “The first hurdle was to identify the person within each of the candidates’ retinues who was responsible for handling these kinds of requests.”

    Summing up, Seratto said, “We haven’t seen any official statement by either party or candidate that says ‘this is concretely what we’re going to do for the American community abroad if we get elected’………..”

    http://www.internationalinvestment.net/other/expat-vote-seen-key-us-election-candidates-avoid-committing-firmly-causes/

15. Related:

    ACA and others who represent Homelanders Abroad (link previously on this thread): http://www.americanthinker.com/articles/2016/11/the_sleeper_issue_for_9_million_americans_that_the_media_will_not_cover.html

    FATCA was initially conceived to combat offshore tax evasion and recoup tax revenues, requiring U.S. citizens, including those living abroad, to report all financial accounts held outside the country—an arguably reasonable purpose and measure. But the Democrats took that simple, targeted goal and addressed it by trapping every American abroad in an insanely expensive regulatory dragnet of questionable legality.

    FATCA doesn’t simply target a few suspected tax cheats; instead, it requires each and every foreign financial institution (“FFI”), including banks, brokerages, pension funds and insurance companies, to annually identify and report to the IRS all clients who are “U.S. persons” (a broad category, including businesses where even one American has signature authority on a financial account), and to turn over to the IRS detailed information on each client’s total assets, account balances, transactions, account numbers and other personal identifying information. Any noncomplying institution faces draconian penalties, including the withholding of 30% of U.S.-sourced income.

    In essence, FATCA coerces FFIs to become IRS lackeys, making them conduct wholesale warrantless seizures of Americans’ private financial information on behalf of the IRS, without any reasonable suspicion or probable cause. The extent of the information collected and disclosed to the IRS is far more intrusive than would be tolerated by law-abiding Americans at home. By having the FFIs do their dirty work, the IRS sidesteps issues of constitutional violations and privacy rights of American accountholders.
    …
    This is inexcusable. Americans currently living abroad, like their compatriots at home, are overwhelmingly honest, productive, hard-working citizens. They are not 9 million money-laundering criminals. Yet, FATCA assigns these Americans a presumption of guilt.
    …
    The Democrats, meanwhile, have been AWOL from the fight to repeal FATCA, and voters abroad know it.

    Of all the laws enacted by the Obama Administration and Congressional Democrats, FATCA stands out for its mindless inefficiency, counterproductivity, and bureaucratic abuse. Nine million Americans abroad are feeling its effects, and they are not happy. Expect them to vote accordingly.

16. Amazing. Your a tax haven if you have a near zero corporate tax rate. Clearly it’s all about having a negotiated across the board tax rate so nobody can get away from your theft.

    https://www.theguardian.com/world/2016/nov/07/treasury-tries-to-thwart-eu-plans-for-tax-haven-blacklist

17. Those in Canada donating to the US presidential campaigns include a press secretary to a Liberal Minister, and a Conservative MP :

    “…….. FEC records show that Bob Dechert, former Conservative MP for Mississauga-Erindale, who recently announced plans to seek an Ontario PC nomination, donated $250 on July 26 to the Oklahoma Leadership Council, which contributes money to Republican candidates. Dechert’s contribution was refunded on Aug. 10.

    Several attempts by CBC News to reach Dechert to find out more about his contribution and why it was refunded have been unsuccessful.

    Jordan Owens, who now works as press secretary to Defence Minister Harjit Sajjan, made two contributions totaling $205 in June 2015 to Clinton’s Hillary for America campaign. At the time, she worked for the Gandalf Group.

    “I have always supported the Democratic Party,” said Owens, who has American citizenship.”………..

    http://www.cbc.ca/news/politics/canada-trump-clinton-u-s-election-1.3837993

    So where do Jordan Owens, Liberal Defence Minister Harjit Sajjan, and Conservative MP Dechert stand on FATCA extortion in Canada? And on Canadian local legal ordinary bank accounts being FBAR’d. Are the ones that are UStaxablepersons US extraterritorial citizenshipbased tax compliant? How do they like the US claiming the right to tax the Canadian disability and education savings and benefits of Canadians?

18. Canadian Redditor with American mother wants to go get his US citizenship documented, but apparently his mother (who has since moved back to the US) is opposed. He says she’s unwilling to give him any proof of her periods of residence in the US because she’s afraid of him getting dragged into a tax mess:
    https://www.reddit.com/r/legaladvice/comments/5bnnfg/can_i_applydo_i_have_american_citizenship/

19. Anybody crying that Schumer gets in. I swore at the TV if that helps.

20. No doubt the renunciation numbers were held back from being released before the election.

21. “Schumer” pronounced like “Neumann” as in Seinfeld. This is jaw-dropping.

22. Oops, that should be “”Schumer” pronounced like “Neuman” as in Seinfeld. The wine is flowing freely this election night.

23. I am having a lot of fun on Facebook with the moving abroad comments.

24. It’s called panic. I suspect Valium sales will skyrocket.

25. I’m having a bittersweet moment watching Clinton (who to me represents nothing more and nothing less than the living embodiment of FATCA and CBT) get trounced. Time to start writing to all the newly elected/re-elected Republican members of the House, Senate, and, yes, White House to rub in their faces the official party platform calling for RBT and repeal of FATCA.

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