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. teen = even

2. Or do a company inversion into the USA?

3. @Calgary, @Moderator…..

   The following recent comment needs to be on the front page as this is hot news. Basically, very recent IGA agreements have a sunset clause if the USA does not provide reciprocity.

   What does this tell me about Canada? You guys need to notify your friends in the NDP, maybe post what you send off to them. Demand Canada gets the same deal!!

   http://isaacbrocksociety.ca/2014/03/05/obama-administration-asks-congress-for-fatca-reciprocity-in-latest-green-book/comment-page-1/#comment-2543142

   Here is a link to the South Africa IGA;

   http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/FATCA-Agreement-South-Africa-6-9-2014.pdf

   And yes, that new clause is in there.

   Will Canada demand the same? Lets push them on that.

4. Ron Paul says we are sinking the dollar with FATCA and sanctions.

   http://www.eurasiareview.com/10082014-ron-paul-us-sanctions-russia-may-sink-dollar-oped/

5. Ron Paul is right.

6. Allison Christians quickly picked up on the lawsuit being filed and the human rights complaint being lodged.
   http://taxpol.blogspot.ca/
   Also Robert Woods at Forbes did an article titled “Canadians File Suit To Block FATCA And Prohibit Handover Of U.S. Names To IRS”.
   http://www.forbes.com/sites/robertwood/2014/08/12/canadians-file-suit-to-block-fatca-and-prohibit-handover-of-u-s-names/2/
   These and hopefully other articles to come should bring more donations into the ADCS fund.

7. Re: Plaintiffs Ginny and Gwen Commence FATCA Lawsuit in Federal Court of Canada

   EmBee, above, and others, on the Court Challenge thread (top of page 1), have posted links to articles appearing today about the lawsuit filed by Ginny and Gwen yesterday at the Federal Court of Canada.

   I’ll post the links here as well (and plan to update the list at the top of this thread this evening)

   Forbes, US

   http://www.forbes.com/sites/robertwood/2014/08/12/canadians-file-suit-to-block-fatca-and-prohibit-handover-of-u-s-names/

   Tax, Society and Culture, Canada
   http://taxpol.blogspot.ca/

   New Democratic Party, Canada

   http://www.ndp.ca/news/canadians-fight-back-against-conservative-tax-snooping-law

   Le Journal de Montréal, Canada
   http://www.journaldemontreal.com/2014/08/12/la-fatca-contestee-en-cour-federale

   Global News, Canada

   http://globalnews.ca/news/1504452/dual-citizens-sue-feds-over-fatca-deal-letting-banks-pass-info-to-irs/

   Globe and Mail, Canada

   http://www.theglobeandmail.com/news/politics/dual-citizens-launch-legal-challenge-on-canada-us-tax-deal/article20007176/?cmpid=rss1

   Financial Post, Canada
   http://business.financialpost.com/2014/08/12/canadian-government-faces-constitutional-challenge-over-fatca-deal/

   Wall Street Journal, US
   http://online.wsj.com/articles/expats-in-canada-sue-over-u-s-effort-to-collect-taxes-abroad-1407856738

   Law.360 (paywall)
   http://www.law360.com/banking/articles/566464/us-expats-sue-canadian-gov-t-over-fatca-cooperation

   AllVoices (Forbes article)
   http://www.allvoices.com/news/17644023-canadians-file-suit-to-block-fatca-and-prohibit-handover-of-us-names-to-irs

8. “The foreign financial account reporting system is said to be all about keeping people from evading taxes by hiding assets overseas. I’m starting to think that it is really just a strange sadistic plan to torture random taxpayers for fun and profit.”

   http://rothcpa.com/2014/08/tax-roundup-81214-fbar-filing-acrobatics/

9. Headline on Tue, 12 Aug 2014 20:19:16 GMT | By CBC News, cbc.ca states that:

   CANADIANS SPEND MORE ON TAXES THAN FOOD, SHELTER: Fraser Institute

   . . . hmmm . . . does this sound like a “Tax Haven”?

10. @Bubblebustin
    Its confiscation of extraterritorial wealth. Taxes are paid for services from the government and are for the people. Expats get none of these benefits but are expected to pay anyway – for nothing.

11. May we make use of the U,S Taxpayer Bill of Rights? Or may we make sport of them and present to the forum for comment?

    http://www.irs.gov/uac/Newsroom/IRS-Adopts-Taxpayer-Bill-of-Rights;-10-Provisions-to-be-Highlighted-on-IRSgov,-in-Publication-1

    1) The Right to Be Informed
    2) The Right to Quality Service
    3) The Right to Pay No More than the Correct Amount of Tax
    4) The Right to Challenge the IRS’s Position and Be Heard
    5) The Right to Appeal an IRS Decision in an Independent Forum
    6) The Right to Finality
    7) The Right to Privacy
    8) The Right to Confidentiality
    9) The Right to Retain Representation
    10)The Right to a Fair and Just Tax System

    ** #10 sounds of interest that we may argue that the treatment of Americans abroad is not fair and just compared to Americans living in America.
    What to add:
    11) The Right to Simplicity of Tax Preparation
    12) The Right to Reasonable Penalties

    We might send an amended list to the U.S. Tax Advocate.

    I saw this one on Twitter about FBAR forums: This could be a separate feature:
    http://taxpol.blogspot.com.au/2014/08/fbar-e-filing-violates-taxpayer-bill-of.html?spref=tw

12. Allison Christians sums it up very well in her comments about tyne complaint sent to the UN Human Right Commission:

    “The UN sanctioned Eritrea in 2011, for extracting a comparatively tiny amount of tax on its disapora. It did so apparently at the behest of the United States. Yet three years later the whole world is engaged in the process of perfecting citizenship taxation for the US, with no discussion whatsoever, at any official level.”

13. National Post article: http://epaper.nationalpost.com/epaper/viewer.aspx

14. Neill and Others — would you like to respond regarding the answer to my comment below @ http://www.examiner.com/article/citizenship-renunciations-half-of-2014-approaches-total-for-bush-last-term?

    calgary411 • 4 days ago

    You know not of what you speak or write about. It would be responsible of you to make a correction:

    QUOTE:
    Most expatriate’s names do not appear on the Taxpat Lists. In fact, the government has a special term that they use to identify these people. The term is “covered expatriate.” In order to qualify as a covered expatriate and have your name appear on one of the lists for 2014, an individual expat must have either a net worth of more than$2,000,000 on the day prior to expatriation or have had an average annual net income tax liability of $157,000 for the 5 years ending before the date of expatriation. That means that every name on those lists are in the top one percent (1%) of income earners or the income group that pays 68% of all federal personal income tax collected. That income group is precisely the group that we can least afford to lose.
    QUOTE

    My name, my husband’s name, my daughter’s name have all appeared on a past “Name and Shame” list and to say that we have either a net worth of more than $2,000,000 on the day prior to expatriation or have had an average net income tax liability of $157,000 for the 5 years ending before the date of expatriation, besides being an out-and-out misleading lie, could be too funny for words if it weren’t so sad. My daughter was born abroad and I have been abroad since 1969. I became a citizen of another country in 1975 when I was WARNED that I would be losing my US citizenship. If only THAT had been correct.

    There are LOTS of names on the so-called “Name and Shame” list that are NOT “Covered Expatriates”. You’d best do better homework before spouting off such nonsense. For most of us nor is it is a “name and shame” list.

    That said, I am ASHAMED at what the US has become. Change to Residence Based Taxation like the rest of the world, and you wouldn’t have these opportunities for incorrect information in your such articles and go after the tax evaders you rightly should go after — they RESIDE in the boundaries of your own country and send their untaxed money offshore. Most of those renouncing have been abroad for many, many years and have chosen to make their lives in other countries. Last I checked, the USA still calls itself a democracy that allows that.

    Solid_Facts • 23 minutes ago

    calgary411, it appears that you and your family are some of the very few who incorrectly made the Taxpat Lists, due to bureaucratic incompetence by government workers. But rest assured that the vast majority of the names on the Taxpat Lists fit the legal definition of a “Covered Expatriate”. The law is very specific about whose names should and should not appear on those lists and they should contain only the names of “Covered Expatriates.” A very few bureaucratic errors doesn’t change the law nor the validity of what those lists tell us about wealthy expats.

    26 U.S. Code § 6039G (http://www.law.cornell.edu/usc… states:

    “Notwithstanding any other provision of law, not later than 30 days after the close of each calendar quarter, the Secretary shall publish in the Federal Register the name of each individual losing United States citizenship (within the meaning of section 877 (a) or 877A) with respect to whom the Secretary receives information under the preceding sentence during such quarter.”

    Then we look at 26 U.S. Code § 877 (a) (http://www.law.cornell.edu/usc… and see that it defines a “Covered Expatriate,” as I defined it in the above article.

    Incidentally, I was under the same misconception as you, till one of the top lawyers in the world, for dealing with U.S. expatriations, corrected me. David Lesperance was named by the Wall Street Journal as “probably the top lawyer in the business of advising wealthy U.S. citizens on how to expatriate to lower-tax countries.” After talking with David Lesperance of Lesperance & Associates, in Dundas Ontario Canada, I went back followed all of the links in the law, to all of the various subsections and found that he was absolutely correct. I had missed that nuance, buried deep in the law.

    Under the law, as it stands, the Taxpat Lists “should” contain only the names of “Covered Expatriates.” The few other names that appear on those lists are bureaucratic mistakes. But like no-fly lists, once your name is on the list, even if it’s a mistake, it’s next to impossible to get it off. Out of the 3000+ names that will appear on the Taxpat Lists this year, there should be no more than 10 names on the lists that should not be there and likely closer to zero. Even government workers aren’t so incompetent that it would be any worse than that.

    Therefore, for all practical purposes, my original statement stands. If you want, you can add, “with the exception of a few very mistakes” to the original statement, which was, “That means that every name on those lists are in the top one percent (1%) of income earners or the income group that pays 68% of all federal personal income tax collected. That income group is precisely the group that we can least afford to lose.” Either way, the impact of the statement is essentially the same. At the current rate, more than 3000 wealthy U.S. citizens will renounce this year.

    For the record, I had originally contacted David, while doing research for my book, “The Rich Don’t Pay Tax! …Or Do They?” and he has followed my writings since. He is also the co-author of a book that will be coming out soon (I think in October) that you may want to consider. The title will be “The Flight of the Golden Geese” and it is my intent to be among the first to read it.

15. There is a recent media article on TaxConnections. From August 12 2014 by Robert Mariani
    August 11 2014
    Expatriation Increase At A Record Pace In 2014!

    It is written by a Tax compliance industry person.
    Here is a bit of it.
    For those who already are living overseas, more are saying they don’t plan to return. They are renouncing their U.S. citizenship and giving back their US passports.

    While giving up U.S. citizenship will free you from our worldwide taxation system, you’ll have to pay some pretty stiff taxes if that’s the reason you’re leaving the country for good. Many wealth citizens, who had an average annual net income tax liability for the five preceding taxable years (i.e., 2008 to 2012 for a 2013 expatriation date) that exceeds $155,000 (this amount is adjusted each year for inflation) (Tax Liability Test) or who had a net worth of $2 million or more as of the expatriation date (Net Worth Test) need to also consider that they will also be subject to an expatriation tax as though they sold their world wide assets on the date before their expatriation date.

    Former U.S. citizens also will face difficulty in even coming back into the United States for visits.

    http://taxconnections.com/taxblog/expatriation-increase-at-a-record-pace-in-2014/?inf_contact_key=45e212098c75cd1a7d2fe4cff528e9cfc2ffcb701aa925ba384dd4704fcb42cc#.U-udeVa4mlI

16. @ calgary411 & Neill
    Yours were such measured responses to “Solid-Facts”. I just went for cheeky. 🙂

17. Thanks for weighing in, EmBee. He still contends what he contends.

    Latest from “Solid Facts” —
    *******But as for your contention that the Taxpat Lists are “mostly normal people,” I’ll refer you to my above response to calgary411. If there are any names on the Taxpat Lists, that do not represent wealthy expats, then it’s only by mistake, since the law, though somewhat convoluted to read, makes it clear that only the names of “Covered Expatriates” should appear on the lists.

    *******

18. I am still thinking overnight that the taxpayer bill of rights – listed above – would be something that we may amend and send back to the US Taxpayer Advocate. It could be by way of press release and that could be picked up in the press (as it would then be a different story and angle) and get more sympathy from homelanders from our cause – they don’t like the IRS either. A first step of this is to put it out to the forum for comment and request suggestions for revision.

19. Complications is Streamlined. The IRS is treating taxpayers with prejudice for having made a good faith effort to become tax compliant.

    http://taxconnections.com/taxblog/disparity-in-treatment-of-taxpayers-who-qualify-for-transitional-relief-is-casting-a-shadow-on-the-new-streamlined-procedures/#.U-zZXGK9KSM

20. Copy of letter sent to President Obama

    http://www.forbes.com/sites/robertwood/2014/08/15/dear-mr-president-why-im-leaving-america/?utm_source=followingimmediate&utm_medium=email&utm_campaign=20140815

21. Charl…
    This is amazing. I went to comment on it. I am signed in but I can’t seem to get it entered.
    Also This is a good article for a separate OP.

22. @Charl
    Isn’t it about time for a letter like this? I honestly don’t get the dems abroad. I think that every single compliant american abroad should have been writing letters like these for a long long time. They aren’t in hiding like many others. They have absolutely nothing to lose and everything to gain.

23. @Polly Yes it is, way overtime I’d say. Say what you want about “The Woodie”, he keeps it current whatever his motivators are.
    @Nothernstar Something funky also happened when I tried to post my comment but it eventually went through. Maybe just internet goblins, keep trying but do copy first so you don’t have to rewrite….I can never remember what I initially said when that happens to me.

24. @calgary411

    There are numerous people on this blog who have reported that they appear on the name and shame list, despite not being “covered” expatriates. In many cases the names have been published before the 8854 has been filed in which case the IRS has no way to know if they are covered or not. Hardly a few few bureaucratic errors. Whatever their laws say – they don’t follow them.

    This is just another hassle on the path to freedom. The fact that your name may end up on a list of persons “supposedly wealthy”.

    Shame on them.

25. @calgary411

    I replied to “Solidfacts” as follows:

    There are hundreds of thousands of US expats/nopats/neverpats who would like to get on this list and it has nothing to do with wealth. They just want to free themselves from the utter bullshit that is involved in being a so-called “US Citizen” when they have few, if any, ties to the place.

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