I came across the following exchange in the comments section to a recent Isaac Brock post. Like many of the comments posted, I found this exchange particularly interesting. What are your thoughts on the requirement of “Reporting”? What if there were no prospect of suffering penalties for failing to report? Is there a legitimate privacy issue? Are there things that are not the business of the Government? Although this is not a direct analogy in the case of Roe v. Wade the U.S. Supreme court (per Justice Blackmun) did find a right of privacy in the Constitution that justified a prohibition of abortion laws. Continue reading
Monthly Archives: February 2012
Yet another renunciant whose name isn't in the Federal Register. How many more are there?
Reuters ran an interesting piece on St. Kitts’ economic citizenship programme today, which inevitably touched on the issue of renunciation of U.S. citizenship. However, I was disappointed that the author missed the opportunity to fact-check the U.S. government in the following paragraph:
Adam Bilzerian, a professional poker player and the son of former corporate raider Paul Bilzerian, said he worked through Henley to get citizenship in Austria. But put off by the cost and exclusivity of Austria’s program, he purchased property in St. Kitts, filled out some paperwork, and within a year, became a Kittitian. Then, he became one of 231 Americans to renounce his U.S. passport in 2008. In 2011, government records show, the number of Americans renouncing their citizenship reached 1,788 – the highest number since the government began keeping track in 1997.
Except that Bilzerian’s name does not appear in those “government records”. Continue reading
After Five Decades of Abuse, Enough is Enough!
“ENOUGH IS ENOUGH”
AFTER FIVE DECADES OF ABUSE
IT’S TIME FOR A CHANGE
THIS COMING OCTOBER WE WILL MOURN
THE 50TH ANNIVERSARY
OF THE DEATH OF
A LEVEL PLAYING FIELD
FOR OVERSEAS AMERICANS
AND NOW IT’S TIME TO GET IT BACK
Reproduced by permission of Andy Sundberg, Fellow and Secretary, the Overseas American Academy , Geneva , Switzerland , 16 January 2012. Email contact: andy at sundberg dot com Continue reading
Extreme Measures
The IRS is going to extreme measures to make headlines …
U.S. tax attorney Chris Rusch arrested in Panama City
If you pursue the link below to read the rest of this gripping story, also consider (1) Where the story is coming from, and (2) The veiled pitch for business.
If only journalists in Canada and elsewhere would dramatize the persecution of ordinary extraterritorials with such fervor.
Steven Mopsick's blogspot and his latest post
Our new friend, 30-year IRS veteran, Steven Mopsick, has been a really good sport. He’s defended the orcs of Mordor, his former colleagues at the IRS fearlessly, and he’s taken our abuse like a trooper. He’s asked me if I wanted to put up his new post on FATCA, and I said to myself, why the heck not? Meanwhile, go have a look at his blog, especially this little piece, called FATCA Red Herring, which starts with this whopper, “For all the groaning about FATCA, there is one ‘red herring’ which should be given the lie right away, and that is the silly notion that FATCA is an attempt to force the application of U.S. law on foreign financial institutions.” Well, if nearly 400 pages of orcish regulation isn’t an attempt to force U.S. law on FFIs then I don’t know –but wait, these regs still hadn’t come out when Steven wrote that post–so you’re off the hook, Steve–I am being unfair.
Again, caveat emptor! The Isaac Brock Society maintains a non-endorsement policy of tax-professionals (see here). Also, please read not just the post, but the full comment stream.
New Rules For Foreign (Non-American) Banks with American Clients
by 30-year IRS veteran
Is a Certificate of Loss of Nationality really necessary? New FATCA regulations are in gobbledygook
Petros isolates the term “Certificate of Loss of Nationality” (CLN) in the new FATCA rules.
Interesting historical source of US Canada tax information
I found a rather interesting website of a now deceased Vancouver tax lawyer/preparer who at one time dealt with US Canada tax issues. The site has a series of newsletters and question and answers going back to 1993 (This is was in the “day” when there was an IRS attache located at the US embassy in Ottawa who dealt specifically with Canada). I would not necessarily bet my life on information from a dead person that is 15 years old but going through his newsletters (I am still going through starting in October of 1993); he appears to at least have some answers from the then IRS attache in Ottawa that “may” in fact explain some of the situations people find themselves in. The real funny thing is at least as of 1993 the IRS could administratively require anyone living outside the US who hadn’t filed to file returns going back to 1967.(I guess there was a big tax law change back in that year. This was definately before my time maybe Roger would know).
Here is his first newsletter from October 1993 that deals with the filing requirements.
This is the newsletter I am studying right now from March 1994 that talks about dual nationality and loss of citizenship issues.
Eritrea evil; USA good
Guest post: Roger Conklin sends in a couple of links regarding the United Nations condmenation of Eritrea.
Here are a couple of many links on the Internet with respect to this resolution of condemnation. One includes a Video of Susan Rice, US representative on the Security Council, speaking in support of this resolution. The second is the text of the resolution.
Bring Back the Money….
Here is the latest that is coming out of DC on territorial taxation that was just proposed yesterday. Of course, as to be expected, it is Corporation directed in its focus. They are the ‘super persons’ that get all the attention around Congress these days. However, there is language that is encouraging here. I think we need to be writing Senator Enzi, as he is asking for comments. He is stopping short with his efforts, and these measure should include US citizens residing abroad as well. Regional taxation should be for all, not just super persons! In our letters, we can use many of the excellent arguments Roger has provided us as support. The bills title should be… Bring Back the money and create more export jobs in the US with Territorial taxation for all!
"IRS Commissioner Doesn't File Own Taxes: I Find The Tax Code Too Complex" – Interview with C-SPAN
Key quote at 1:10 in the video!