Liberty and justice for all United States persons abroad

The Isaac Brock Society

Media and Blog Articles Open for Comments – Part 6 of 11 (Year 2019)

You can access all years at this link: Media and Blog Articles – Links for All Years

If clicking on a link brings you to the wrong page in the comment stream, click here to get to the most recent comments.

 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.

2019.12.15
Canadians travelling to or through the US should pay attention to their withering rights, H.M. Jocelyn, CBC News, Canada.
2019.12.12
EU revives issue of FATCA information exchange as year-end deadline for banks approaches, Helen Burggraf, AmericanExpatFinance.
2019.12.10
13 Reasons Why I Committed Citizide, John Richardson, TaxConnections.
US tax filing requirements that Americans living in Canada should know, David Altro and Avi Guttman, Globe and Mail, Canada.
2019.12.07
Confirmed – Rep. Holding to leave Congress at end of 2020, after reintroducing Tax Fairness for Americans Abroad Act,  Helen Burggraf, AmericanExpatFinance.
2019.12.06
Trump is trying to make it took expensive for poor immigrants to stay, Annalisa Merrelli, Quartz, US.
2019.12.05
Revenue Neutrality And A Move To Residence-based Taxation: Open Letter To Democrats Abroad, John Richardson, Karen Alpert, Laura Snyder, TaxConnections.
What It’s Like to Retire Abroad,  Glenn Ruffenach, Wall Street Journal, US.

Earlier 2019 articles are in the  Media and Blog Articles 2019 Archive.  Links to previous years’ archives are also at that link.

2020.01.01: This thread is now closed. Please comment at Media and Blog Articles Part 7 of 7
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523 thoughts on “Media and Blog Articles Open for Comments – Part 6 of 11 (Year 2019)”

  3. The previous page show lots going on in terms of addressing the injustices (more than in past years), while some here at Brock may think it kind of quiet as there has not been many features and postings here than in past years and we are waiting to hear from the Canadian Government in regards to the lawsuit.

  7. “US signs off on ‘milestone’ double taxation treaty with Switzerland”

    https://www.thelocal.ch/20190718/us-signs-off-on-milestone-double-taxation-treaty-with-switzerland

    The DTA means exchange of information on tax matters between the two countries will now be easier.
    [..]
    In a statement, the SIF also noted a mandatory arbitration clause “ensures that double taxation is avoided even in cases where the competent authorities cannot reach an agreement in the mutual agreement procedure.”

    Protocols with Japan, Luxembourg, and Spain were also ratified. US citizens resident in those countries, and filing US tax returns, may want to check whether the protocol for their country includes this mandatory arbitration clause.”

  8. The IRS says (about mandatory arbitration):

    “Certain U.S. income tax treaties provide for mandatory binding arbitration to resolve eligible cases in which the competent authorities have endeavored but are unable to reach a complete agreement. To date, arbitration is included in the U.S. income tax treaties with Belgium, Canada, France, and Germany. More information on mandatory binding arbitration under these treaties, together with associated documents, is available through the following links” etc

    https://www.irs.gov/businesses/international-businesses/mandatory-tax-treaty-arbitration

  11. “Five Things to Know about the Pending Tax Treaties in the Senate”

    https://taxfoundation.org/us-tax-treaties-senate-2019/

    Interesting analysis of why four have at long last been voted on and passed by the US Senate (in order to fend off the MLI, as I suggested above); why three haven’t yet been passed but probably soon will (only waiting to have BEAT-related language removed); and one (the MLI) may languish indefinitely.

  12. One may only hope that the U.S. prods France/Macron to point out the hypocrisy of such statement (Tweet by Trump): The tax part not the wine part:

    France just put a digital tax on our great American technology companies. If anybody taxes them, it should be their home Country, the USA. We will announce a substantial reciprocal action on Macron’s foolishness shortly. I’ve always said American wine is better than French wine!

    https://twitter.com/realDonaldTrump/status/1154791664625606657?s=20

  14. DT: “We tax our companies, they don’t tax our companies”

    Sounds like he has no clue about the territoriality for COMPANIES that his administration passed.

  18. You can’t have RBT with FBAR continuing. I did not see mention of SCE excluding FBAR.

    Many have said FATCA SCE would mean more paperwork for banks (such as then have to certify each person each year that they are a resident of a country). Plus is problematic for places such as the common market of Europe when people may often live in one country but have an account in another, and work in another. As Karen points out there is no penalty on banks for over-reporting, so they will likely choose what is easiest for them and that is to keep the over-regulation and discrimination in place.

  21. Can’t see how this would actually work;
    “U.S. citizens and long-term residents (lawful permanent residents in eight out of the last 15 taxable years) whoexpatriated on or after June 17, 2008, may not have met their filing requirements or tax obligations. The InternalRevenue Service will address noncompliance through a variety of treatment streams, including outreach, softletters, and examination. ” http://src.bna.com/J30

    When the IRS has such deep funding problems, how could they possibly be successful at going back to 2008 to review, locate, track down and compel expatriates? Expats (and those with surrendered PR status) are outside the US. And the IRS has significant constraints in trying to collect extraterritorially even if it could locate people outside the US retroactively and manage to assess US tax or penalties. Are they merely trying to use threats as leverage again?

    I can’t see why anyone with no US assets would even respond from outside the US. Especially those who’ve already expatriated.

  22. Will the IRS try to compare tax returns received against the list of those who have renounced? That sounds like a major paper exercise, particularly as the renunciation forms don’t ask for a social security number.

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