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The Isaac Brock Society

Media and Blog Articles Open for Comments – Part 4 of 11 (Year 2017)

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-4-of-4)

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.   I’ll make a permanent list of links posted here and keep adding to it,  but not deleting, so we’ll end up having sort of a  “bibliography” of FATCA/CBT articles.  [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.

Notes:

From JC:   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.

From Badger:   On an important archival note, please use the Internet Archive Wayback machine https://archive.org/web/ (see bottom right ‘Save Page Now’ box to enter URLs of webpages you want saved for posterity, and try to save backup copies of articles and other items of interest in some other form – such as a datastick or external drive. Some important and very significant webpages and the fulltexts of articles are no longer available (although some can be retrieved if someone using the Wayback machine saved them).

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

2017.12.28
It’s time to address the double standard about tax havens, Angela Wrights, Macleans, Canada.
The US Is Becoming the World’s New Tax Haven, The Editors, Bloomberg View, US.
2017.12.21
Rep. Dina Titus Supports Americans Abroad Tax Reform, Democrats Abroad, US. 
Now That The GOP Tax Bill Is Approved, The IRS Gets Busy, Brian Naylor, NPR, US.
2017.12.20
Taxpayers will have to wait to find out how they fare under new legislation , Renae Merle and Aaron Gregg, Denver Post (reprint from Washington Post), US.
U.S. Shareholders –Take Action by December 31, KPMG.
2017.12.18
Have You Ever Felt Sorry for the I.R.S? Now Might Be the Time, Patricia Cohen, New York Times, US.
2017.12.12
EU finance ministers issue warning to Trump over tax reforms, RTÉ, Ireland.
2017.12.11
Banque: les consequences étonnantes de l’accord FATCA, Edouard Lederer, Les Echos, France.
2017.12.10
As Australia ousts MPs with dual citizenship, Canada’s Parliament embraces many in its ranks, Kathleen Harris, Canada. (mentions MP who “assumed his U.S. citizenship was automatically rescinded because he did not meet several requirements for continued citizenship. [But when travelling to Washington] was told he was ineligible to enter the U.S. on a Canadian passport because he was a U.S. citizen. He was . . . allowed in on a one-time basis . . . it cost him $3,000 to later sort out the administrative requirements.”)
2017.12.09
The American Diaspora: Outreach and Organization, Victoria Ferauge, The Franco-American Flophouse, Japan.
2017.12.08
Foreign-owned banks to be hit by US tax rules, Financial Times, UK.
Trump Tax Plan Worries Europe, Christian Reiermann, Der Spiegel, Germany.

For articles earlier in 2017, click here.

1,720 thoughts on “Media and Blog Articles Open for Comments – Part 4 of 11 (Year 2017)”

  1. @badger @karen

    Just who is he talking about when Bruce refers to people who feel little impact from US taxation overseas? He should run a disclaimer: *may severely impact those who wish to save for retirement, own a business or desire to thrive as first-class citizens where they live.

  2. @Bubblebustin – I suspect he’s thinking of homelanders abroad rather than long term expats. If you plan on returning to the US in 3-5 years, then CBT isn’t so much of a problem.

  3. Then he’s not telling the entire story, yet is part of an organization that’s supposed to represent “American Citizens Abroad”.

    Perhaps “American Citizens Temporarily Abroad” would be a more apt name for the organization that supports SCE (an attempt to make CBT work) and ignores the issues of long-term expats.

  4. I agree. Don’t forget that his version of RBT requires you to be wealthy enough to buy your freedom – but you still have to file FBAR!

  6. https://www.youtube.com/watch?v=ynl4PA0jwE0
    Remember the UBS scandal? In this video the whistleblower, Bradley Birkenfeld, speaks of tax evasion, corruption, fraud, money-laundering and terrorist financing … and his new book “Lucifer’s Banker”. He speaks about being imprisoned (40 months) when high-level Swiss bankers and culpable others remained free. Of course he doesn’t mention his $104M reward from the IRS or his own diamond smuggling escapade or how CBT/FBAR/FATCA affects him now that he is a permanent resident of Malta. He certainly doesn’t even hint at the collateral damage which has occurred since the US government dropped its ultimate solution to the UBS scandal — the big Fat Man FATCA bomb. If he’d known what was coming, would he have blown that whistle? I think so. He’s abiding quite comfortably in Malta and just waiting for the royalties from his new book to roll in to top up the account wherein lies his record-breaking whistleblower reward. Crimes were committed, yes, but look how Bumbledorf Obama chose to blow up the lives of the many in the pretense of tracking down the relatively few, rotten bad guys.
    https://daphnecaruanagalizia.com/2017/03/ubs-whistleblower-bradley-birkenfeld-resident-malta/

  8. This concerns form 8864 for expatriation.
    Anyone knows or can help me find a link showing how to calculate the amount to list for retirement pension paid as monthly payments?
    If it is the net present value, where to find life expectancy and interest rate agreable to … the IRS.

    Thanks

  9. @James – do you mean 8854? Do you expect to be a covered expatriate? What kind of pension is it, and are you trying to calculate for the mark-to-market section or only for the listing of assets? If I recall correctly, for mark-to-market it’s estate tax rules, and for the asset listing it’s gift tax rules.

    You might want to post questions in the Renunciation thread at http://isaacbrocksociety.ca/renunciation/ because that’s where people who are currently dealing with the 8854 often look.

  11. Bopp’s submission is classic. He even throws them a bone, suggesting foreign banks submit 1099 interest forms to the IRS. Of course this is impractical, but it gives the Democrat dogs a bone to chew on, as well as calls their bluff, in that a 1099 requirement would indeed track down ‘foreign’ tax evasion, limited to evasion of interest income. Excellent!

  13. @JC & Barbara

    Bopp’s submission was very good. However, I see two problems with the recommendations:

    1.) The 1099 Int’s should be for “US residents,” not “US citizens.”

    2.) RBT is recommended while RO is actively lobbying for TBT.

  14. Lucy Salyer (University of New Hampshire) presented a paper on “Reconstructing Citizenship: The Forgotten Right of Expatriation” at the annual U.S. Capitol Historical Society symposium last week.

    Can’t find much online about the paper; following is just the symposium schedule
    http://uschs.org/news-releases/2017-annual-symposium-reconstruction/

    USCHS live-tweeted from her talk
    https://twitter.com/USCapHis

    Lucy Salyer gives our last #reconstructionhistory presentation–on the 1868 Expatriation Act.
    https://www.instagram.com/p/BUAMnK9gV4W/

    Salyer: Expatriation (ability to renounce citizenship of a country) is something of a forgotten right today. That is, it didn’t used to be recognized universally. US belief–citizenship could be chosen (volitional). European take–citizenship was forever, etched in a heart at birth. Advocates of expatriation draw on language/arguments of other Reconstruction issues for support. Irish & other immigrants saw Naturalization Act as their 14th Amendment.

    Question line starts up for Lucy Salyer!
    https://www.instagram.com/p/BUAQqxIAeRn/

    A direct link to the “forgotten right” tweet
    https://twitter.com/USCapHis/status/863106073728868353

  15. “GOP lawmakers question IRS summons to Coinbase users”

    “In a letter Wednesday, House Ways and Means Committee Chairman Kevin Brady, R-Texas, Senate Finance Committee Chairman Orrin G. Hatch, R-Utah, and House Ways and Means Oversight Subcommittee Chairman Vern Buchanan, R-Fla., asked Koskinen for more information on the John Doe summons it issued to Coinbase for its users’ records.
    [..]
    In the letter, lawmakers wrote of concerns about the basis, scope, and impact of the summons, which is expected to affect approximately 500,000 active Coinbase users. It would lead to the production of millions of pages of associated records, many of which contain personally identifiable information, they contend. Many of the Coinbase users do not complete enough transactions to have to report activity to the IRS, according to the lawmakers, who estimated that 90 percent of the customers engaged in less than $10,000 in cumulative, gross transactions during the entire period requested by the IRS in its summons….”

    https://www.accountingtoday.com/news/gop-lawmakers-question-irs-summons-to-coinbase-users

  19. Somebody please correct me if I’m wrong but it seems to me repeal of the estate tax and the gift tax would inevitably have a considerable impact for those trying to renounce “cleanly”, as the IRS rules for calculating net worth are based on the gift tax and the rules for calculating the expatriation tax for covered expatriates are based on the estate tax.

    But… it does seem unlikely anything is going to get done on anything any time soon.

  21. @Bubbles

    That + this might be disastrous for us:
    (though Mr. Marini is reprehensible for packing his facts to scaremonger people to enter OVDI…..)

    Republican Hopes for Rewriting Tax Code in 2017 Are Fading
    http://nyti.ms/2qB7RqK

    Only two months ago, Republicans in Congress and President Trump’s top economic advisers were confidently predicting that a sweeping rewrite of the tax code would be in hand by summer’s end.

    But with the White House consumed with constant upheaval, Congress facing the prospect of myriad investigations on top of its delayed duty to fund the government, and health care legislation still grinding through the Senate, those hopes have faded. Even with the less ambitious plan of just tax cuts — not a tax overhaul — the new mantra in Washington is “Maybe next year.”….

    Republicans in Congress must separately approve a budget resolution this summer if they want to use the reconciliation process to pass a tax overhaul with a simple majority in the Senate. That will determine the scope of the tax legislation that Republicans can pursue if they choose to exclude Democrats from the process.

  23. Some Canadian (and other country) accounts are, to the US for US Citizens and US Persons, *foreign trusts* (in our *foreign financial institutions*). May become relevant — new requirement *Legal Entity Identifier (LEI)*, now in the UK.

    https://www.kingstonsmith.co.uk/insights/eprivateclient-flurry-acronyms-fatca-crs-lei-pile-costs-regulations-trustees/

    …
    Introduced by Barack Obama in 2010, FATCA was seen to be ineffective, unpopular and costly. In common with so many before him President Trump has not behaved like candidate Trump. Whilst he is delivering on some promises, there has been silence on the future of FATCA. This means that FATCA is still enshrined in UK tax law.

    Globalization and increasing regulation are transforming the global tax framework. Surprise, surprise these challenges mean additional costs for trustees and no obvious increase in tax revenues.

    But hot on the heels of FATCA, the OECD introduced the Common Reporting Standard (CRS) as a global reporting standard.

    While trustees have yet to get to grips with FATCA and CRS, they are now being bombarded with requests to obtain a Legal Entity Identifier (LEI) – which will enable their investment managers to continue to trade on the Stock Exchange from early 2018.

    Endorsed by the G20, the London Stock Exchange (LSE) requires investors who are deemed to be legal entities to obtain a LEI number. A legal entity for these purposes includes trusts, companies, pension funds (but not self-invested personal pensions), charities and unincorporated bodies that are parties to financial transactions.

    Where investment portfolios are held within trusts, the trustees will be obliged to obtain an LEI. The LSE will charge an initial allocation cost of £115 + VAT and an annual maintenance cost of £70 + VAT per LEI. Some stockbrokers will obtain the LEI on behalf of their clients, sometimes with an administration fee charged on top of the registration cost.

    Since the introduction of FATCA, CRS and now LEI the compliance costs of having a trust have gone up significantly. These procedures do not add any value to a trust or provide any additional comfort to the trustees. They are simply another spool of red tape that has to be unwound on an annual basis, eating into the returns to be distributed to beneficiaries.

    It is easy to understand the frustration felt by trustees at the ever-increasing rules and the bump in professional fees that this complexity involves. The question may consequently arise whether the continued existence of some of these trusts can any longer be merited. Ironically, the legal costs of termination often persuade the trustees to keep going in the hope that regulation will one day decrease…
    …

  25. On Donovan withdrawal from Treasury #2 post:

    Treasury Secretary Steven Mnuchin’s efforts to fill out the top ranks of the department were dealt a setback as a Goldman Sachs Group Inc. banker withdrew from consideration to serve as his deputy.

    The decision could impede Mnuchin’s effort to deliver an ambitious economic agenda including an historic tax overhaul this year, de-regulation of the financial industry and reform of the housing finance system. Donovan was an “enormous asset” in helping build Mnuchin’s team at the Treasury, Tony Sayegh, the department’s spokesman, said in an emailed statement.

    Mnuchin has been in office since February with most key senior-level Treasury positions unfilled, including undersecretaries for domestic finance and international affairs. While in public forums Mnuchin often heaps praise on career Treasury staffers, he’s had to rely on counselors who don’t require Senate confirmation to step into senior positions. Counselors have more limits on their policy making powers than officials approved by Congress.

    Nominees for Senate-confirmed government positions must disclose their finances and sign an ethics agreement before going through a vetting process by lawmakers.

    The Trump administration has been wary of recruiting too many former Goldman Sachs alumni for higher-up positions.

    https://www.bloomberg.com/news/articles/2017-05-19/donovan-withdraws-as-nominee-for-u-s-treasury-deputy-secretary

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