Media and Blog Articles – Part 1 of 11 (to 26 May 2015)

3,971 thoughts on “Media and Blog Articles – Part 1 of 11 (to 26 May 2015)”

1. @all It would not be correct to assume that Boris Johnson is happy to pay off the IRS. I bet he is really pissed off. I believe he is doing it for political reasons. A pissed off British PM may do more for the cause than a pissed off London mayor, one may hope.

2. Escaping JFK Arrest, London’s Mayor Boris Johnson Pays IRS

   http://www.forbes.com/sites/robertwood/2015/01/22/escaping-jfk-arrest-londons-mayor-boris-johnson-pays-irs/?commentId=comment_blogAndPostId/blog/comment/1057-32783-9755

3. I seriously doubt the US would have risked an international incident by allowing the mayor of London to be arrested! That’s a bogus claim. I refuse to be intimidated by this bullshit. Total propaganda!

4. How could Boris possibly aspire to be pm if he continues to hold US citizenship?The UK cant have a leader with divided loyalties.

5. Nice mention of IBS here:

   Experts Question Accuracy of New York Times Story on Chinese Taxation

   http://www.taxanalysts.com/www/features.nsf/Features/4EC670927489765C85257DD40068C82B?OpenDocument

6. @heidi I believe the loyalties of Boris Johnson are with London/U.K. and not the US. He says it is difficult to give up citizenship as we all know – he would probably have to sell UK assets to pay the US exit tax and then sell more assets to pay the UK and US capital gains tax/Obamacare tax, and the circle continues until he has $0 after paying the compliance folk.

7. @JC
   On the Boris thread we came to th conclusion that he wont have any exit tax to pay. Seeing that he is back in England. There is a provision it seems- that if you go back and live in the land you were a citizen of at birth – there is no exit tax. So he should actually be spared that.

8. @jc .He doesn’t have to pay the exit tax as a dual as long as he is up to date with filing. I expect him then to relinquish/renounce if he expects to get my vote. How could any future leader be trusted not to have a divided loyalty. Many consider the UK to be the US poodle, having a US PM would confirm it. I think his bid would be dead in the water.

9. The US Congress has now done a report on “offshore evasion”, Brockers need to sift through it.

   http://freebeacon.com/issues/report-tax-evasion-avoidance-costs-united-states-100-billion-a-year/

10. “….The IRS collects, often because the threat of its reach is just too big. Even overseas. Even political figures. Everywhere.”
    Another paid advert for US extraterritorial CBT in Forbes.

    Fact is that there are lots of famous and political figures who are “US taxable persons” abroad. At one point we were trying to compile a list. I doubt that the IRS has assessed and collected US taxes against Bhumibol Adulyadej the King of Thailand, who was born in Mass. http://en.wikipedia.org/wiki/Bhumibol_Adulyadej “….Forbes estimated Bhumibol’s fortune—including property and investments managed by the Crown Property Bureau (CPB), a unique body that is neither private nor government-owned—to be US$30 billion in 2010, and he was the leader of the magazine’s list of “The World’s Richest Royals” from 2008 to 2013.[8][9][10][11][12] In May 2014, Bhumibol’s wealth was once again listed as US$30 billion.[13] Officially the assets managed by the CPB are owned by the crown as an institution, not Bhumibol Adulyadej as an individual.[14]” http://en.wikipedia.org/wiki/Bhumibol_Adulyadej

    So, Forbes has included the King in several lists it compiled of the “World’s Richest Royals”, and says that Boris is an object lesson to US taxable persons wherever they may be, but never mentions King Bhumibol Adulyadej.

11. You’re right on the money here, badger.

    For us to further explain to those *snowbirds* we might know who poo-poo articles like this, here is something from Phil Hodgen. Note that it applies to those of us who have expatriated (not to get back into any US-defined *US Person* definition) and for those who don’t have the information that we now have — Canadian snowbirds. It applies to both:

    …and from Phil Hodgen:

    Too Many Days In the USA
    So the only way that an expatriate can become a resident alien is by spending too much time in the United States in a calendar year. Well, I guess you could become a citizen or green card holder again, too. But let’s ignore that.

    In order to keep this email reasonably short, I will send you to the blog post that reader O commented about, where I talk about the substantial presence test (that’s what “too many days” is called in the Internal Revenue Code). Instead, I will give you the guiding principles here.

    Principle Number 1: Figure It Out Annually
    The first thing to remember is that you figure out your resident status on an annual basis. You might be a resident one year and a nonresident the next.

    Principle Number 2: Three Year Average
    The second thing to remember is that this is an equation to be solved for a three year period. When you are figuring out whether you are a resident (or not) for this year, you will look at how many days you were in the United States in the current year, last year, and the year before that.

    The equation you solve is this:

    You are a resident of the United States in the current year if: (number of days in the USA in the current year) + (number of days in the USA last year)/3 + (number of days in the USA in the year before last year)/6 @#8805; 183.

    Principle Number 3: Remember 183
    The magic number is 183. When you solve the equation and the result is 183 or more, you are a resident for that year.

    People get confused. They think the rule is a 6 month rule: spend 6 months in the United States and you are a resident. Not so.
    
    It is “the sum of your calculations is greater than or equal to 183” rule. It so happens that 183 is ½ a day longer than half of the year. But keep in mind that we have an arithmetic problem here, not a “6 months in the USA” problem.

    You can hit 183 as the answer to your arithmetic problem by staying in the United States for 183 days in a single calendar year.

    You can also hit 183 as the answer to your arithmetic problem by staying in the United States for a number of days over a three year period, even though you were never in the USA for 183 days in any one year.

    Safety Numbers: 30, 121
    There are two numbers to keep in mind if you want to keep yourself safe from becoming a resident alien because of time spent in the United States.

    30 days. If you spend 30 or fewer days in the United States in any calendar year, it is impossible for days of presence to cause you to be a resident alien for that that year, taxable on your worldwide income.

    121 days. If you spend 121 days or fewer in the United States year in and year out, you will never be a U.S. resident for income tax purposes. You can prove this to yourself by plugging in 121 as the number of days for all three years in the equation noted above. You will see that the total is just under 183. For kicks, plug in 122 for all three years and see what happens.

    Nonresident Status When You Spend Too Much Time in the U.S.
    Let’s say that you screwed up after you expatriated. You spent too much time in the United States and in doing so you made yourself into a resident alien, taxable on worldwide income.

    There are two possible strategies that nonresident aliens can use to avoid resident status triggered by too many days in the United States. An expatriate is a nonresident alien. Under the current exit tax rules, there are no special rules that discriminate against expatriates.

    Closer Connection (Form 8840)
    You might be able to use a strategy called the “closer connection exception”.

    Go look at Form 8840 and the instructions to that form. In general, if you can prove that your true home is outside the United States (you have a closer connection to another country than your connection to the United States), AND …
    you spent fewer than 183 days in the United States in the current year, you can opt yourself out of the substantial presence test.

    This means that you were in the United States for fewer than 183 days in the current year, but when you did the three year mathematics the result exceeded 183.

    Consider this as a possible way to pull (nonresident status) victory from the jaws of (U.S. tax resident) defeat if you end up spending a lot of time in the United States after you expatriate. If you successfully use this strategy, you are a nonresident of the United States for all tax purposes. (Compare that to the hybrid half-good/half-bad news for the income tax treaty strategy, described next.)

    Income Tax Treaty (Form 8833)
    A second strategy is to use an income tax treaty as a trump card.

    Find out if your home country has an income tax treaty with the United States. If it does, look at Article 4 (or Article 3 in a few very old treaties). This is a tie-breaker rule. If you can be claimed as a resident of two countries, this is how the two countries will resolve the problem so only one will tax you as a resident.

    If this works, you will file Form 8833 with the IRS to claim nonresident status. Now you are not taxed on your worldwide income. However (and this is massive) for all other purposes you are a U.S. taxpayer.

    This means all of the invasive paperwork the IRS insists on … you have to file it. Yes, FBARs and the like.

12. @George,
    Skimming suggests the document is all about making the laws tougher. Nothing about correcting the problems. You can contact the author though:
    jgravelle@crs.loc.gov
    We should all do that.

13. @George
    I didn’t see much in the report on individuals as opposed to non-carbon based U.S. persons. I followed up the Zucman reference and the individual offshore evasion focused on is assumed to be largely done through shell corporations and trusts. Zucman does note that the U.S. does not have an entirely clean record on shell corporations. He doesn’t really deal with the problem of trusts. The Zucman article does at least mention that FATCA causes problems for ordinary Americans overseas (p. 142-3).

14. Robert Wood post at Forbes on Boris Johnson

    It mentions the ADCS lawsuit too, with a link to his August post about the lawsuit.

15. The International Man has just posted Part 2 of Muzzled No More’s series and What Really Happened linked to it. The word is spreading and we have MNM to thank for this.
    http://www.internationalman.com/articles/fatca-the-worst-law-nobody-has-ever-heard-of-part-ii

16. Thank you so much, EmBee! I’m glad to see the whole thing is up at International Man now. I’m so grateful to Nick Giambruno for publishing it!

17. Congratulations, MuzzledNoMore, and thanks for letting us know, EmBee! I’ve posted also at the FATCA Tracker site, which has little or no discussion — but perhaps some will read this and other information provided there.

18. @ All
    Please give the International Man article some traffic so Nick Giambruno will be encouraged to continue dishing out the facts of FATCA. And for your listening pleasure (thanks to an @calgary411 find), please tune into this terrific interview that Keith Redmond did. He was outstanding.
    http://radio.foxnews.com/2015/01/26/american-expat-keith-redmond-on-why-some-americans-abroad-renounce-us-citizenship/

19. New US tax complexity for the *homelanders*, green card holders, especially…

    http://www.newsmax.com/Newsfront/Obamacare-tax-code-H-R-Block-no-one-understands/2015/01/19/id/619435/

    “Now that the Affordable Care Act has made healthcare a tax issue, no one can understand it,” says the tax-preparation giant, which has more than 24 million tax clients worldwide.

    Many of those who will be hurt are lower-income earners. According to H&R Block’s Tax Institute, almost three out of every four in this group are unaware of the fact that they need to file anything with the IRS due to the fact they receive insurance through Obamacare.

    Former IRS Commissioner Mark W. Everson said the new Obamacare requirements will deliver a “shock to the system.”

    “Low-income filers are not used to itemizing and it will be a big challenge for them,” he told the Daily Caller. “You’re introducing a whole new level of complexity.”

    Some Obamacare users will find that their refunds are smaller than expected because they were penalized for failing to enroll in a federally approved health insurance plan. Other users may find out that they have to repay the U.S. government for subsidies they received to pay their health insurance premiums because they failed to accurately predict how much money they would make in 2014.

    Complying with the new Obamacare tax code will prove complicated. IRS Publication 5187, which tries to explain to taxpayers how to comply with the new Obamacare regulations, is 21 single-spaced pages long, the Daily Caller noted.

    Thank you, Canada. Please don’t let Harper move us to anything like this!

20. I got to know Keith Redmond through a facebook group. He is the leading anti-FATCA person in France. He knows about IBS but I don’t know if he posts here. He does mention the Canadian lawsuit towards the end of this 10 minute interview on radio. Extremely articulate and he says he could have gone on for 20 more minutes at least.

    Keith Redmond
    8 hrs ·

    Please find the link where you can listen to my interview about our plight as Americans overseas on The John Gibson Show broadcast on Fox News Radio from Thursday, 22 January 2015. http://radio.foxnews.com/2015/01/26/american-expat-keith-redmond-on-why-some-americans-abroad-renounce-us-citizenship/

21. India pushing US over tax issues including FATCA (many Indian FIs are late on compliance due to misunderstanding the rules). Again, good to see someone asking questions, even if they might not get the answers.
    http://timesofindia.indiatimes.com/business/india-business/India-and-US-countries-mean-business-Transfer-pricing-investment-treaty-on-the-menu/articleshow/45998031.cms

    Looks like Social Security of Green Card holders an issue:
    “Indian workers pay the US government by way of social security contributions that you can never recover… The Indian aid programme is involuntary. We want this changed and one major issue that must be addressed is a totalization agreement that’ll allow Indian workers recover the $3 billion aid they provide every year to the US,” Arvind Subramanian, chief economic advisor, said last weekend.”

22. @Publius
    India provides 3 billion aid to USA? Now thats a switch of events. Didn’t we always think that America provided the aid to others?

23. I don’t know if you read here at IBS, Keith Redmond, but you are a star in the sky! What an amazingly articulate speaker you are! I am also thankful to the interviewer for really sitting back and letting you talk for the most part. You educated countless Americans on Thursday and I am deeply grateful!

24. US government shares personal data collected under Obamacare with advertisers and commercial interests:

    ‘Government health care website quietly sharing personal data’
    By RICARDO ALONSO-ZALDIVAR and JACK GILLUM
    Jan. 20, 2015 5:58 PM EST

    “The government’s health insurance website is quietly sending consumers’ personal data to private companies that specialize in advertising and analyzing Internet data for performance and marketing, The Associated Press has learned……”………

    ” connections to dozens of third-party tech firms were documented by technology experts who analyzed HealthCare.gov and then confirmed by AP. A handful of the companies were also collecting highly specific information. That combination is raising concerns.

    Leading lawmakers on Tuesday asked the administration to explain how it oversees the data firms to make sure no personally identifiable information is improperly used or shared.

    “This new information is extremely concerning, not only because it violates the privacy of millions of Americans, but because it may potentially compromise their security,” Sens. Orrin Hatch, R-Utah, and Charles Grassley, R-Iowa, wrote to the administration.”………..

    http://bigstory.ap.org/article/31490a20926d4ed3b98ff2d0ed8fc81d/new-privacy-concerns-over-governments-health-care-website

25. More on Canadian snowbirds: http://www.cbc.ca/news/canada/canadian-snowbirds-rules-you-need-to-know-1.2925513

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