Liberty and justice for all United States persons abroad

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. Depends what you hope for.

    Not to be chased by the IRS – already available

    To be free of America – already available

  2. To hope that the US will be made to see the error of its ways and stop treating its citizens like shit may be a hope too far. They’ve had 250-odd years.

    Change may come, if it suits them to allow that to happen. Personally I wouldn’t count on it.

  3. Solomon Yue Tweets:

    Republicans Overseas plaintiffs in #FATCA challenge seek US Supreme Court review. This fight 4 9M overseas Americans’ constitutional rights & freedom continues. It is part of RO multipronged attack: FATCA lawsuit & House hearing & regulation review by Treasury, + #TTFI 2 end #CBT

    https://twitter.com/SolomonYue/status/943874903492591617

    I responded:

    Perhaps late in this #FATCA / FBAR suit,

    Yet #FBAR deserves more than one claim of Unconstitutionality.

    I bring your attention to:

    “Home country [USA] causes job limitations abroad”

    Report employer accounts !

    .@GOPIsrael @SwissTechie @TCKmysteries

    #TaxReform FAIL

    https://twitter.com/JCDoubleTaxed/status/943930063849889792

  4. @JC Yes, Americans abroad is often associated with tourism. It is increasingly being used for U.S. athletes who may be abroad for only a few games.

    @BB Americans overseas is a term that is indeed associated with the U.S. military.

    I note that AARO is Americans resident overseas, perhaps to get around this issue. Maybe adding the word living, residing to Americans abroad is a way around this?

    Under NO circumstances expatriate. It can mean former citizen and has all the wrong connotations.

    The name might do well to appeal to something Americans believe they value (equality, liberty, etc.). It is a shame that the T.E.A. (Taxed enough already) Party name is taken, since that is us in a nutshell.

  5. Hope may be badly battered, but it isn’t dead. Thanks to all who have posted some very positive recent developments. The fight is on and we are even gaining the beginnings of support from the Democrats. Good to see!

    Merry Christmas to those who celebrate it, and, to everyone, a better year in 2018 than the one now passing into history.

  6. Not exactly an article but I cannot think of a better place to put this.

    I am in contact with some people who are interested in having a demonstration in London UK. There are no specific dates/places yet, just an initial idea. I indicated I would post in a few places. If you are interested please email me and I will put you in touch with them. nobledreamer16 at gmail dot com

  7. I’m amazingly in the spirit in spite of being delivered a lump of coal by Donald Trump and the GOP FOR Christmas.

    Merry Christmas to all, and may we find a peace we can live with in the New Year.

  8. Free on Amazon for the time being:

    How to Become a Citizen of Any Country by Jon Sterling
    https://www.amazon.com/How-Become-Citizen-Any-Country-ebook/dp/B0147B85VS/

    It’s worth the price, but little more. It doesn’t mention any of the citizenship-by-ancestry options (e.g. Ireland, Poland, etc.), leaves out quite a few of the citizenship-by-investment (e.g. Bulgaria, Belgium), doesn’t even mention Israel’s Law of Return, and so on. The biggest omission is that it leaves out one country: the United States.

    This book is a great idea, hastily and badly collected. Someone ought to do it properly.

    Its best feature is that it lists the addresses of the embassies (in the USA) of most countries. So if you want to apply for Eritrean citizenship, at least you know where to send your application.

  10. “The EU’s Tax Haven Blacklist – Will the U.S. Eventually be Added?”
    https://www.bna.com/eus-tax-haven-b73014472806

    Will the new tax bill finally nail the US as non-co-operative for tax purposes.

    For the last couple of years, [the OECD] has maintained a list of jurisdictions committed to AEOI under the CRS. In the early days, the OECD also maintained a “naughty boy” list of jurisdictions that had not committed to the CRS despite being asked to do so. The U.S., uniquely, wasn’t on either list. Instead, it formed a class of its own – or rather a footnote to the list of committed jurisdictions. This read as follows:

    “The United States has undertaken automatic information exchanges pursuant to FATCA from 2015 and entered into intergovernmental agreements (IGAs) with other jurisdictions to do so. The Model 1A IGAs entered into by the United States acknowledge the need for the United States to achieve equivalent levels of reciprocal automatic information exchange with partner jurisdictions. They also include a political commitment to pursue the adoption of regulations and to advocate and support relevant legislation to achieve such equivalent levels of reciprocal automatic exchange.”

    That cryptic footnote is still in place, even though there has not been the slightest sign that the commitment it refers to will ever amount to anything more than words. FATCA remains, as it always has been, entirely one-way traffic.

    A Non-BEPS Compliant U.S. Patent Box?

    The FATCA footnote is a fig-leaf, designed to obscure the uncomfortable truth that the U.S. has opted out of the nascent global regime for mutual automatic exchange. For a while last week, it looked as if even that flimsy covering was about to be ripped away. Last Thursday (30 November), as the U.S. Senate prepared to vote on its tax reform bill, Senator Rand Paul (R-Kentucky), a long-time opponent of FATCA, tabled an amendment for its repeal. But that amendment never made it into the final version of the bill, passed by the Senate in the early hours of Saturday morning (December 2). So, for the time being at least, the OECD (and by extension the EU) will be able to maintain the dubious proposition that the FATCA regime renders the U.S. at least “largely compliant” with global AEOI requirements.

    But that is not the end of the story. As we saw earlier, the EU’s Criterion 3 requires a jurisdiction to commit, by the end of 2017, to the agreed OECD anti-BEPS minimum standards and to their consistent implementation – a provision that will eventually be replaced with one requiring a jurisdiction to receive a “positive assessment” from the Inclusive Framework as regards the effective implementation of those standards.

    One of the minimum standards, accepted by the U.S. in common with all other parties to the BEPS project, is Action 5 – Countering Harmful Tax Practices. A major focus of Action 5 is preferential IP regimes, such as patent boxes. As part of the moves to align taxation with substance, Action 5 provides that such regimes must require a “direct nexus between the income receiving benefits and the expenditures contributing to that income”.

    When the Obama Administration signed up to Action 5, the “nexus” requirement was essentially a non-issue for the U.S. because it had no patent box regime. But the tax reform bill passed by the Senate last week provides for the introduction of a U.S. patent box in all but name – a 37.5% deduction (21.785% for taxable years beginning after December 31, 2025) on part of a U.S. corporation’s “foreign-derived intangible income” (FDII). This produces an effective rate of 12.5% (15.625% for taxable years beginning after December 31, 2025) on such income compared to the new general corporate tax rate of 20%. And guess what – the proposed new quasi-patent box regime contains no explicit “nexus” requirement.

    Intellectual Gymnastics

    [If the Tax Cuts and Jobs Act] is enacted without such an amendment, is it possible for the new regime be compliant with BEPS Action 5? If it isn’t, how will the Inclusive Framework be able to give the U.S. a positive assessment on implementing the BEPS minimum standards? And if it can’t, wouldn’t that make it impossible for the U.S. to satisfy Criterion 3 of the EU’s blacklist criteria?

    Given the hoops that both the EU and the OECD have gone through to avoid putting the U.S. on the naughty step, it may not be beyond their ingenuity to find a way of accommodating the FDII deduction, even if it remains bereft of a “nexus” requirement. But if they do, it will require a feat of intellectual gymnastics that puts their previous efforts into the shade.

  13. Sounds to me like partisan struggles over which political faction gets credit for proposing remedies for CBT/FATCA.

    Which is ok if it means change does actually happen. Who cares which bunch claims credit – not I.

  16. @BC_Doc…. ¿Qué pasa?

    Hey, a Happy New Year from the other side of the pond!!

    Hey, the best thing of our long road together? We have learned the big bad wolf is sufferring from COPD. May it be fatal sooner rather than later.

  17. @BC Doc…I just sent my MP a copy of the ACA press release on the State Department Credit Union checking account for expats……

    The MP was SHOCKED.

    I want SDFCU to take out full page ads in The Telegraph, Daily Express, Guardian….

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