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. @BC Doc

   If something’s not done about it, they’ll be seeing Mexicans using the northern border as an entry point after the Mexi-murka wall is built! Increase federal funding NOW!

2. How US persons can avoid paying US tax on your principal residence – oh, but there’s a catch: increased estate tax.

   “No matter the US citizen’s financial situation, it will almost always make sense to gift an interest in a principal residence prior to its sale in order to avoid the US tax that might otherwise arise upon its sale. When a sale is not imminent, however, an immediate gifting strategy may not be the best solution.”

   The solution? Read here:

   http://www.mondaq.com/article.asp?articleid=490084&email_access=on

3. @JC – The only disadvantages about dual US/UK citizenship in Britain are the US tax aggression, plus for a politician like Johnson the possible questions about loyalties.

   The tax problems seem to have been sorted out, but the political disadvantage remains, and can only become more acute if Johnson really does get within spitting distance of Number 10.

4. @Neill
   Of course, they are really thinking about sneaky people when they make the laws, but that is part of the problem: the laws they create hit a lot of unintended parties. Occasionally they will say something like of course, by trusts we don’t mean RRSPs and of course we don’t mean those trusts that people use merely to buy property in Mexico, but people in countries who have things that are RRSP-like are still left not knowing how the IRS sees things.

   @iota
   “funds accumulated offshore are often passed to future generations free of transfer taxes.“

   Well, if truth be told, funds accumulated onshore generally pass to future generations free of transfer taxes nowadays. The estate tax limit is now so high that only either very wealthy estates (or those going to non-resident aliens) pay it. When actor James Gandolfini died unexpectedly, people were shocked that his estate paid a large amount of tax and he was criticised for not having planned better. As for state estate taxes, well, North Dakota does a nice business in trusts.

5. @Publius – Yes, I was just struck by the way they seem to cast an evil interpretation on the most innocent and loving actions, when committed by a person with US citizenship – as if the purpose of leaving money to a grandchild is not a desire to show affection but a desire to evade US tax.

6. @Publius, when you mentioned that ”The estate tax limit is now so high that only either very wealthy estates (or those going to non-resident aliens) pay it…”, do you mean that former citizens US-cited estates would subsequently be hit with heavy estate taxes? Or did you mean that former citizens as NRAs would face heavy estate taxes if they subsequently inherited from a U.S. Estate?

   My understanding is that when my American parent die, that I would not pay any inheritance taxes to IRS because their estates would have already been subject to estate taxes. It gets more complicated though in that I believe that some states such as Maryland also impose a tax on the recipients of inheritances, even though those estates had already been subjected to both federal and state death taxes.

   I further was of the impression that it would only be my US-cited estate that would be hit with US death duties if it were worth more than $60,000. This means that if I eventually inherited a share of my father’s beach house, that I would sell my share to my siblings and get all my remaining assets OUT of the United States after my parents have both deceased.

   At the moment, I still have a small four figure sum in a US-based brokerage account so that I can deposit birthday and Christmas checks from my parents and siblings. Otherwise, I would have no need…the problem with opening up a dollar account in the UK, for instance, is that minimal balances plus annual charges would be far higher…

   However, if I send the brokerage a W8-Ben, they will almost certainly close the account. What a nuisance.

7. @ Monalisa
   ”The estate tax limit is now so high that only either very wealthy estates (or those going to non-resident aliens) pay it
   I guess they don’t want any US estates leaving the good ole US homeland.
   I didn’t realise this, until I read Publius’ post, also see below.

   http://www.sgrlaw.com/resources/newsletters/trusts_estates_trends/trustsnestatestrends_winter11/1622/

8. @ Mona
   Second thoughts
   Re reading the article, it refers to the US situated estates of NRA’s being taxable above 60,000, not the inheritors of those estates. That is why I originally thought that Publius’ statement was wrong. It was the whole reason why I was forced into become a US citizen in the first place while living there with a US spouse.
   So beware all those Canadian snowbirds with Florida homes.

9. @ Publius
   I think your statement should read
   ”The estate tax limit is now so high that only either very wealthy estates (or those OF non-resident aliens) pay it.
   Those also paying high estate taxes (40%) are the estates of COVERED expats, wherever those estates are situated IF the inheritors are US persons.

10. @Mona Lisa – I would think that under the US-UK treaty it would be up to the UK to tax or not tax a foreign legacy received by a UK-resident taxpayer. Whoever handles the estate would surely have to confirm your nationality, and check the relevant laws and treaties, before doing any withholding on you.

    It might be a good idea to check the US account t&c’s to see if there’s a requirement to tell them of any changes in nationality. If so, if I were in your place I would notify them a.s.a.p. Or you could just quietly close the account yourself, once you’ve settled on an alternative way of handling dollar remittances.

    The t&c’s on two of my UK accounts grew a requirement for notifying nationality changes, around the time FATCA was implemented. I wouldn’t be surprised if it was a widespread requirement, these days, even in the US.

11. Another brilliant article by Alex Newman:

    http://www.thenewamerican.com/usnews/constitution/item/23176-obama-attacks-sen-rand-paul-for-protecting-fourth-amendment

12. Quirky — veiled McCarthyism (tactic also used in Canada – shaming)?

    http://isaacbrocksociety.ca/2016/04/26/reply-from-the-finance-minister-the-honourable-bill-morneau/comment-page-2/#comment-7508347

    My comment above should have been directed to bubblebustin, I believe.

13. From The Globe and Mail:http://www.theglobeandmail.com/news/politics/cra-stalls-conrad-black-mansion-sale-with-liens-over-unpaid-taxes/article30006844/
    CRA stalls Conrad Black mansion sale with liens over unpaid taxes

    “The second lien is for unpaid income taxes of $2,771,196.84. The lien was filed by the Canada Revenue Agency on behalf of the U.S. Internal Revenue Service through the Canada-U.S. tax treaty, according to the documents.”

    Is this not Canada collecting taxes for the U.S.? Maybe I’m missing something.

14. @BC_Doc: It’s not the US that needs to be protected from us, we need to be protected from them!

    If I had the funds, the knowledge and/or the ability, I would build the wall myself.

15. @Cheryl – doesn’t Canada only refuse to collect US tax demands if the person is a Canadian citizen? Apparently Black gave up his Canadian citizenship so he could become a lord.

    Black and former Hollinger International executives face a raft of civil lawsuits. The US internal revenue service is also after Black, who surrendered his Canadian citizenship to be ennobled Lord Black of Crossharbour in 2001. The IRS claims Black owes almost $71m in unpaid taxes and penalties. The IRS alleges that Black failed to report and pay taxes on income stemming from personal use of Hollinger’s corporate jets, the use of corporate money to acquire papers written by president Franklin Roosevelt and Roosevelt’s private secretary, and Hollinger’s purchase in 2000 of a $5.9m New York apartment for his use. Black says he was not required to file tax returns because he was not a US resident.

    https://www.theguardian.com/business/2010/jul/21/q-a-conrad-black-fraud

16. Thanks @iota. I guess it makes sense if it is non-Canadian income.

17. @ Cheryl,

    CRA will assist collection because he wasn’t a citizen of Canada during the tax period for which he owes the IRS money. But if the person is a Canadian citizen at that time, they won’t.

    Canada-US Tax Treaty, s. XXVI A (8)

18. Oops, I only meant to renounce temporarily: http://www.ctvnews.ca/canada/conrad-black-meant-to-renounce-canadian-citizenship-temporarily-1.2094865

    https://www.thestar.com/news/canada/2015/06/18/conrad-black-on-why-hes-lost-his-love-for-the-conservatives.html

    https://en.wikipedia.org/wiki/Conrad_Black
    In an interview with Peter Mansbridge in May 2012, Black said he would consider applying for Canadian citizenship “within a year or two”, when he hoped the matter would no longer be controversial and he could “make an application like any other person who has been a temporary resident.” However, in light of Black’s criminal conviction it remains unlikely for him to succeed, as Canada’s immigration laws normally prohibit overseas criminals from receiving citizenship.^[88] The decision to grant or reject his application would be at the discretion of the federal Cabinet.^[89]

19. Thanks Pacifica. I understand now.

20. Interestingly, the substantial presence test applies even when you’re jail.

21. @BB: That was my first thought, too. Even if he managed to run Hollinger from Canada, with the six years he spent in the clink, he’s done for 😛

22. @Isabelle Brock

    I agree 100% with your comment. Canada’s greatest external threat, IMO, is and always has been the United States.

23. @All

    Why are you even talking about poor Conrad when you should be concentrating on how hard done by Ms. Sophie Grégoire Trudeau is? She needs STAFF, don’t you peasants know? Conrad renounced- or was duly stripped of his citizenship; dear Sophie is a first class Canadian citizen. Just ask her fit husband or her nannies. Maybe she could set up a GOFund me account.
    Like many others who don’t understand where boundaries are or who blur the differences between CAN/USA, Ms. Trudeau version 2.0 wants to convince us she is the First Lady of Canada.
    Not happening on my watch. Of course, I could be wrong. Perhaps it is covered by a section of the IGA I didn’t read? I’d even brush up on my decrepit French language skills to have a tete a tete with her.
    I’d ask her to take on the cause of damage being done to us second class citizens.
    Surely she could get behind that. With or without staff.

24. Quote from Thomas Jefferson;

    “As the Royal Navy began to impress into its service British expatriates stationed on American vessels, President Jefferson wrote to Treasury Secretary Albert Gallatin that “I hold the right of expatriation to be inherent in every man by the laws of nature . . . the individual may [exercise such right] by any effectual and unequivocal act or declaration.”

    https://riceonhistory.wordpress.com/2011/11/15/the-expatriation-act-of-1868/

    Boris Johnson;

    “”We were told by President Obama that in respect of international trade we would have to get to the back of the queue, not a position that America normally requires the United Kingdom to be in when it comes to other matters such as the Iraq War.”

    http://www.express.co.uk/news/politics/669177/boris-johnson-brexit-eu-referendum

25. Yes it’s time for Koskinen to go but I won’t hold my breath that it will happen. And if/when he goes there will be another bureaurat chief who will step in to keep on abusing the taxpayers according to the directions of Congress (more specifically those who control Congress).
    http://www.politico.com/story/2016/05/john-koskinen-irs-impeachment-house-republicans-223166

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