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. @Bubblebustin

   Here’s the plain English version of Hillary’s statement:

   Foreign banks and tax agencies are now America’s financial extraordinary rendition sites, and our instructions to them are clear: do whatever you have to do to extract the information we’re looking for from US persons – just don’t leave any visible scars or bruises.

2. Tax Havens – USA: The New Switzerland?
   http://www.valuewalk.com/2016/02/tax-havens-america/

   disqus

3. @JC

   Sounds good to me: US force banks of world to be nice to US persons. They have the power to do dso. US citizenship should be less of a lighting rod of discrimination. It would be a bit more tricky to force all the companies of the world not to discriminate against US persons because they are US persons

   I think this misses the whole point. Foreign banks shouldn’t have to follow US law at all. The extra-territorial enforcement of CBT via FATCA violates the sovereignty of every other country on earth. A US law forcing banks to be nice to US customers violates that sovereignty just the same. The more the US forces its laws on banks or companies outside of the US, the greater will be their resentment of the US and US persons, and rightly so.

4. It serve the banks right for pressuring their government’s to sign their IGA’s. It’s called mission creep, and the US is good at it.

5. I agree, bubblebustin. Perhaps it would be pay-back for the banks’ initial self interests above all else in allowing themselves to become arms of the US IRS. Banks’ and countries’ interests over what should be the rights for people of the countries involved.

6. I’m sure everyone can appreciate the irony, Calgary411. The banks could hardly complain could they?

7. Yet another Republican debate coming up.

   “The Washington Times, who is co-moderating the debate with CNN, has agreed that Republicans Overseas can submit questions to the moderators.”

   Our issues are finally gaining a wee little bit of traction. Rubio now advocates switching to Territorial-Based Taxation on his campaign website. So maybe, just maybe, a question about CBT or FATCA or renunciations can make it into a nationally televised debate. Shall we yet again bombard them until they give in?

   Link to send questions is in the article:
   http://republicansoverseas-hongkong.com/front-page1/come-watch-the-next-republican-debate-with-us/

8. America’s Overseas Voters Are Not Impressed
   MAR 1, 2016 3:14 AM EST Therese Raphael
   http://www.bloombergview.com/articles/2016-03-01/america-s-overseas-voters-are-not-impressed

9. Just as breaking into an Egyptian tomb often comes with a curse so does not filling or getting stuff wrong on forms in the form of penalties.

   http://www.seacoastonline.com/news/20160229/granlund-cartoon-irs-tax-forms

10. Does anyone here get Phil Hodgen’s expatriation emails? He sent one today that sent chills down my spine (more chills ). He says that if you have renounced the irs can audit you and if they find a (big) mistake it could make you a covered expatriate even though you did all the paperwork to renounce correctly. I just can’t believe it anymore! I was planning on renouncing next year but maybe I should wait till 5 years go by since that streamlined filing clears. sigh….trapped forever….

11. @2terrified2sleep,

    Yes I get it. After you have been through the system with the IRS you expect to learn something that turns stuff upside down on you every year or so.
    I make sure I have filed all the forms that I need to to keep the statute clocks ticking (8621 etc). The only good think about OVDP is that it closes the years.

12. US turns on tax credits for Cuba:

    https://www.irs.gov/pub/irs-drop/rr-16-08.pdf

    I mistakenly thought that the tax treaties turned on credits but 26 USC 901 says any foreign country. The treaties then I guess say that section better stay there.
    Since Cuba is a pet project of Obama it might be instructive to see how things play out there as opposed to those scumbag, lying, cheating and tax dodging Canadians.

13. I seriously feel like the boogeyman is after me! Like I’m in a dream (nightmare) and I keep running but I can’t get away. Seriously, if they can audit you even after you renounce and if you have stuff that they question , you’re back to where you started…except worse since now you have fines and could get switched to being a covered expatriate. What is going on???

14. TFSA update. Last week I told you that a couple of my kids and I were going to a Canadian FI to open some TFSAs. Sure enough, during the KYC portion of the meeting, the US tax question came up. The form it took was, “You’re not US are you? You don’t like go to the US, do you?” My kids and I answered no, and they affixed their signature to that statement. The truth is that we do not want to tell them AND they do not want to know. I have three financial gurus in my life. All of them have known of my US taint, two of them choose to pretend that I have taken care of the problem (a form of don’t ask don’t tell), and the third usually wants an update on how things are going. In any event, my kids have now successfully opened their own TFSAs and sworn to a lie. I couldn’t be prouder!

15. US Expats Voices WILL Be HEARD in MARCH10th Debate https://www.facebook.com/Republicansoverseasdebatequestions/

16. Good comment I spotted
    Only 2 out of 244 existing tax jurisdictions in the world use citizenship-based taxation (the US and extortionist, UN-condemned dictatorship Eritrea). All the others use residence-based taxation. It is about time for the US to face reality and fall in line with the fiscal practice that is quite literally the world standard.

    http://www.bloombergview.com/articles/2016-03-01/america-s-overseas-voters-are-not-impressed

17. @2terrified2sleep

    I read that post by Phil Hodgen too. We are also preparing to renounce. My thoughts on the possibility of an IRS audit screwing things up are:

    a) If a person is not covered due to net worth and is a long-time expat, they probably don’t have much in the way of US tax due anyway — they’re a minnow and not worth the IRS’s attention. There’s no profit in an audit.

    b) If a person has renounced already, getting money out of them will be much more difficult (unless they have assets in the US), so again, there’s no profit in an audit.

    c) If the IRS goes ahead and audits, even though there’s no profit in it, the strategy I would follow would be to go to the press. By then, I’d have nothing to lose. And the last thing the IRS/US would want is to be seen as picking on middle class foreign citizens and leaving their government to pick up the pieces with the local social safety net.

    My (perhaps optimistic) feeling is that the odds of this happening are quite remote. So, while other aspects of this situation may be keeping me up at night, this is one thing I refuse to worry about unless/until it actually happens.

18. @2terrified2sleep – I read Phil Hodgen’s email, I read all his emails and usually I find them really helpful, but I think this one is meant for a particular kind of problem that probably most of us minnows will never encounter.

    He is talking about a tax accountant’s client who is already being audited, so this is a case where the IRS already thinks they’ve got reason to suspect there’s something wrong – and they can put pressure on the tax accountant to squeeze the client for further information.

    I suspect they just don’t have the staff and/or budget to take that approach on most of us small fry, just over an unintentional error. I’m not losing any sleep over it. In our own countries, after all, we have rights, we’re not so horribly vulnerable as taxpayers in America are.

19. @no name – “The truth is that we do not want to tell them AND they do not want to know.”

    Yep, I agree that sometimes seems to be the case. Don’t ask, don’t tell. None of my (UK) banks have asked me any questions.

    There was an article a few months ago, “FATCA ‘versus’ IGAs”, about the Canadian and UK IGAs differing with the IRS about whether an account should be closed, or just made reportable, if a bank asks for self-certification and doesn’t get it. The IRS wants such an account to be closed, but Canada and the UK both say it should just be made reportable. (Which is bad enough of course but at least it doesn’t leave the person without banking facilities.)

    http://www.bna.com/fatca-versus-igas-n17179934450/

20. 2terrified. I agree with iota. Get some sleep. This will not affect you. They have their hands full with real tax avoiders.

21. Well they want to update the rules for Fincen 114. More reporting from those with 25 or more accounts. Drop the need for financial pros to report. Nothing to help most people burdened by this crap like no reporting if you have accounts already reported by the country:

    https://www.fincen.gov/whatsnew/html/20160301.html

22. Swiss and US to include in their #FATCA agreement an exception clause for accounts held by lawyers or notaries.

    New FATCA exception clause for accounts held by lawyers or notaries

    FBAR still applies?

    https://www.efd.admin.ch/efd/en/home/dokumentation/nsb-news_list.msg-id-60824.html

23. http://www.cbc.ca/news/business/taxes/tax-time-2016-us-citizens-tax-shelters-1.3446226

    ‘IRS wants its share of Canadian tax shelters owned by U.S. citizens
    For Americans living in Canada, a TFSA or RESP may be a no-no because of U.S. tax laws’

    By Susan Noakes, CBC News Posted: Mar 01, 2016 5:00 AM ET

24. http://blogs.angloinfo.com/us-tax/2016/03/01/accidental-americans-you-have-not-been-forgotten/
    “The Budget for fiscal year 2017 mentions providing relief to “accidental” dual citizens, a provision apparently aimed at providing tax relief to individuals living overseas who discovered that they held US citizenship in addition to their other “foreign” citizenship and that this meant being taxable by the US on worldwide income as well as having responsibility for filing very confusing and onerous information reports with respect to foreign assets, many of which can be punitively taxed “……..

    ………….
    ……………………”Many individuals will not qualify for the benefits of this proposal because the tests are very stringent. For example, the individual must have attained his dual nationality at birth – he must have been born both a US citizen and citizen of another country. Obtaining another country’s citizenship by naturalization will not count. In addition, the individual must never have held a US passport, or, if he did, it must have been for “the sole purpose of departing from the United States in compliance with 22 CFR §53.1”…”…………..

25. A RenfrewBound person (also a ‘US person’ accountant), comments at the CBC article Badger references above:

    “Although I have always been compliant with US taxation and file every year I am beginning to hear from US tax colleagues that the IRS will shortly be looking for medium to high profile cases to prosecute and Canada is likely the first area of enforcement before Europe, South America or Asia. While the IRS cannot enforce collections in Canada as they do in the US it will won’t be a pleasant experience for dual US Canadian citizens. We can expect to see registered letters and possible phone contact. It is also possible that suspected US Persons who attempt to enter the US at land border crossings may face interrogation and arrest or be denied entry by US Immigration at pre-clearance areas of airports in Canada. “

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