Check this out.
Toronto tempts bankers tense about Volcker rule
How can a country do so much to make one want to avoid it?
Monthly Archives: March 2012
US Tax and Filing for Canadian Residents — a Presentation by Roy Berg, Moodys Tax Advisors
Roy Berg is a U.S. tax lawyer based in Calgary and has extensive experience representing Canadian residents with U.S. tax and filing obligations. He frequently contributes to the Isaac Brock forums and has recently given several educational presentations at various locations in Alberta. His firm, Moodys Tax Advisors (www.moodystax.com), recorded one of the presentations and has agreed to make it available free of charge to those who have an interest. Several Isaac Brock members have attended these presentations, the reviews of which are available on the various forums.
US Tax Policies = Margaret Thatcher's Poll Tax
I found an interesting video this evening describing the debacle of Margaret Thatcher’s famous poll tax back in 1990. I found a lot eerie similarities between Thatcher’s tax policies back then and what is going on today with US FATCA, FBAR, increased enforcement of citizenship based taxation et all especially the stubbornness of both Thatcher and the US political establishment.
This does give a pretty good visual overview of what a real tax revolt is like.
Oh Canada! Our Home and Adopted Land
Dear Canadians… Thought you would be interested in seeing this article at Forbes.
Is Stephen Dunn a Canadian, or are your voices being heard across the border?
The United States taxes its citizens and resident aliens on their worldwide income. U.S. law prevents double taxation by allowing a credit for foreign tax on income which is also subject to U.S. income tax. The U.S.-Canada Income Tax Treaty of 1980 provides process by which Canada Revenue will collect…
Read more here.. http://www.forbes.com/sites/stephendunn/2012/03/18/oh-canada-our-home-and-adoped-land/
Ignorance is an excuse in the case of FBAR
Lately, I keep hearing people say that ignorance of the law is no excuse and it does not constitute “reasonable cause” in the eyes of the IRS. Both notions are false with regard to the Foreign Bank Account Report (FBAR).
Prominent US Tax Professor and blogger coming to McGill University
I wanted to post that a fairly prominent US tax law professor and new blogger Allison Christians is becoming the H. Heward Stikeman Chair in Tax Law at McGill University. From reading her blog she appears to be moderately pro FATCA although perhaps not as strongly as some other US tax profs I have seen out there(She is more pro information sharing citing the current US Canada agreement as an example). She has three blog posts I suggest you might want comment on. I have put links below:
http://taxpol.blogspot.com/2012/03/countries-dont-help-each-other-to-tax.html
She discusses the current US Canada information sharing arrangement in the above post and discusses DATCA
http://taxpol.blogspot.com/2012/03/international-tax-gangsters.html
General post on offshore evasion
http://taxpol.blogspot.com/2012/03/netherlands-to-share-more-tax-info-with.html
Discussion on the Netherlands joining the FATCA five agreement
Prof. Christians is almost certainly a US Person. Hopefully she will be enjoying filling out all those FBAR forms upon her arrival in Canada. Note: lets not get too nasty. Who knows Prof. Christians might be a Canadian citizen in a few years time.
It's not 1980 anymore, it's 1984
Our own Ladybug sent me the following 1980 document from the US Consulate in Calgary. It has this don’t-die-of-laughing-they-really-did-say-it line: ” … a person who has already lost U.S. citizenship by that date [Oct. 10, 1978] may not have it restored.” Oh that the rules were what they were. Now, no matter whether you lost it back then or not, you have it whether you want it or not. One line, however, is still all too true: “Did you know … That U.S. laws, regulations and procedures are always changing, and what was true some years ago may not be true now?”
Dueling Editorials.. DATCA vs FATCA
We have a case of dueling editorials in the Miami Herald between Senator Rubio and Rep Posey on one hand, (March 7) and a response on March 15 by Emily McMahon, acting assistant secretary for tax policy, Treasury Department, Washington, DC. I have posted the links in other threads, but wanted to give this duel a little more visibility, as it really represents FATCA vs DATCA battle. Although you won’t see that direct connection in the editorials of either authors. But the EU 5 country FATCA agreement for tax data exchange reciprocity rests on the IRS being able to impose DATCA on US banks. The only place that is pointed out, is in the comments section which I encourage you to read and add your own comments.
Offshore depositors won’t be hurt by Emily McMahon
vs
A destructive IRS mandate by Senator Rubio and Rep Posey
November 21, 2012 NOTE: Not sure what to read into this, but both of these editorials have disappeared from the Miami Herald, and you just get the 404 errors. Searches on titles or names yield nothing! I should have kept copies.
Accounting Firm PromoInfo US/Canada
A new 15 March 2012 issue of Wealth and Tax Matters from PriceWaterhouseCoopers appears to have just been released. The first separate article is “Stricter new U.S. investment reporting rules” and the second article is “Act now, save later – Gifts made in 2012 may lead to substantial estate tax savings for U.S. citizens” [ … not to mention reduction of net worth ].
http://www.pwc.com/en_CA/ca/high-net-worth/publications/pwc-wealth-matters-2012-03-en.pdf
A story from OVDI hell or: How to exact tribute from a country without firing a shot
A reader sent me the following e-mail and eventually gave me the permission to publish it earlier this week. The IRS is hammering Canadian residents who they deem to be US persons. All Canadians should be aware of the hazard–that if we allow the IRS to shake down our people who happened to be “United States persons” it makes all the rest of us poorer because (1) it decreases our taxable base; (2) it reduces the total investment in the Canadian economy (destroying jobs); (3) it will increase the total tax burden on workers who have to pay the Old Age security for people impoverished by United States taxation of Canadians; (4) it is a very real threat to Canadian sovereignty because it is the exaction of tribute from Canadian taxpayers. We should all be very alarmed about United States extraterritorial taxation! We must put pressure on our politicians to nip this in the bud. Here is the story of one Canadian couple who the Godfather Douglas Shulman Barack Obama is shaking down:
Dear Mr Dunn,