Draft Fatca regulations will include reciprocity, experts say – Risk.net.
Reciprocity? I think we all understand that’s useless, no?
Draft Fatca regulations will include reciprocity, experts say – Risk.net.
Reciprocity? I think we all understand that’s useless, no?
http://www.irs.gov/pub/irs-utl/recommendations_tad2011-1.pdf
Response Due:
January 26, 2012
October 26, 2011
MEMORANDUM FOR DOUGLAS SHULMAN, COMMISSIONER OF
INTERNAL REVENUE SERVICE
FROM: Nina E. Olson
National Taxpayer Advocate
SUBJECT: Recommendations Regarding Taxpayer Advocate
Directive 2011-1
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This is a post I wrote this morning and put up on the Flophouse. I know that most of you already know all this but I wanted to gather together the links and publish an argument for why FATCA concerns everyone, not just U.S. Citizens or Green Card Holders abroad. It may be obvious to us but not everyone understands what this law will mean for them. I’m still getting way too many people telling me that FATCA is justified to catch those “evil tax evaders” or that it isn’t their problem because they are not Americans (are you sure about that, folks?) This is my answer.
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This has been cross posted from RenounceUScitizenship.
In a recent post I suggested that there were two big obstacles to U.S. living abroad being in compliance with tax and reporting requirements. I identified the cost of tax and FBAR compliance as being one. I suggested that the second was the lack of clear guidelines and procedures from the IRS. This post generated a few comments. One of the most interesting was the following: Continue reading →
Petros has convinced me to try my hand at doing my own posts, so here goes.
Thought I would start with this one. It relates to a recent “victory” of a financial sort for someone who joined the OVDP program back in 2009. We knew him as Moby.
After 27 long months, he won a long struggle with the IRS bureaucracy. He did not “just roll” over and pay out the absurd OVDP penalties designed for willful Whales. Instead he “Opted Out” of the process. This represents a real success if you don’t count the cost in LCUs (life credit units) that he expended in his effort.
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Cross posted from USxCanada InfoShop
This is a description of a lengthy technical legal article from over two years ago, recently exhumed and annotated by usxcanada. Balanced in an academic sense; the main concern seems to be pursuing the whales; no minnow perspectives here. Regrets that conditions of use do not permit reposting of the full pdf.
Yu Hang Sunny Kwong
Catch me if you can: relinquishing citizenship for taxation purposes after the 2008 Heart Act
Houston Business & Tax Law Journal 9:3 (Fall 2009) 411-444
The headline says it all and I thought it was so charming that I had to share it with you. This article was published earlier this month in the Luxembourg publication Paperjam.lu and it begins with this comment:
En 2009, on célébrait l’investiture de Barack Obama. Aujourd’hui, la Place espère ne pas subir la loi des États-Unis. (In 2009 we celebrated the investiture of Barack Obama. Today la Place is hoping it will not have to submit to American law.)
Anyone who tells you otherwise, anyone who tells you that America is in decline or that our influence has waned, doesn’t know what they’re talking about. That’s not the message we get from leaders around the world, all of whom are eager to work with us. That’s not how people feel from Tokyo to Berlin; from Cape Town to Rio; where opinions of America are higher than they’ve been in years.
U.S. President Obama’s State of the Union address, January 24, 2012
One of the things that bothers me the most about this hideous situation is that little emphasis is placed upon the responsibility of the US government/government agencies to notify citizens abroad of their requirements to file tax and information returns. I came across this list of recommendations from the Department of Treasury, Office of Tax Policy, May 1998 report, requested by Congress. This report has been discussed by Schubert1975 with regard to CLN’s being backdated to the expatriating act (with the effect of negating tax liabilities for many “citizens”). At the end of the report, are a number of efforts suggested to improve revenue collection while balancing “legitimate privacy and other interests of Americans living and traveling overseas.”
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Check this out to learn how the mainland regards those who renounce citizenship – I’m flabbergasted.
https://twitter.com/#!/renounceus/status/162051454004232192