Hi a few comments were spammed, one by Tim, three by 416. The automatic spam filter Akisimet is what makes possible for posts to be unmoderated. But we have to keep on top of thing. Apologies. Peter
Yearly Archives: 2012
Free Seminar: Roy A. Berg JD LLM
Roy A. Berg, as some may have noticed, has been following our blog, and has chimed in more than once in our conversation. This is very welcome. We are happy for those who have professional experience to speak on issues whenever they are willing.
FATCA Discussion Thread (Ask your questions) Part One
Ask your questions about FATCA.
Renunciation and Relinquishment of United States Citizenship: Discussion thread (Ask your questions)
Ask your questions about Renunciation and Relinquishment of United States Citizenship and Certificates of Loss of Nationality.
US expat tax and FBAR: Discussion thread (Ask your questions) Part One
Please note this thread is an archive and no longer current. The conversation is continued here:
Please ask your questions here about US Expat tax and FBAR.
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Fiscal Alternatives to Managing Human-Capital Flows
I found this paper today as I was researching another topic for the Flophouse and the title alone, Sharing The Spoils: Taxing International Human Capital Flows, intrigued me. So I had a look (Petros has probably already read it), thought it had some interesting ideas and so I offer it up to you for your reading pleasure. After all, it is Friday (the 13th no less).
For our purposes I thought the section four on Alternative Worldwide Regimes for Individual Income Taxation starting on page 25 is worth a read:
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Expat Tax Forum Hijacked (Updated)
It comes as an absolute and utter surprise to me that the excellent discussion at the Expat Forum regarding United States expat tax has been suspended because a small group of people with an agenda, who had no respect for the expat forum rules, have hijacked it. This is from Expat Forum owner Bob Sheth:
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U.S. citizenship-based taxation harms U.S. economy
This post is cross posted from Renounceuscitizenship.
See also: Roger Conklin writes about why he left Brazil in 1977 ; The US trade deficit: Was it caused by greedy companies or greedy government?
We are living in interesting times. During all the years of my tax consciousness I have lived with the assumption of U.S. citizenship-based taxation. When the IRS began its “reign of terror” on U.S. citizens living outside the United States and many people learned about their tax filing obligations, the discussion about citizenship-based taxation began. The U.S. is the only Western democracy and of one two countries (Eritrea being the other) which taxes on the basis of citizenship. The rest of the world taxes on the basis of residence or what is commonly referred to as “territorial taxation”. In a global world where:
See also:
Stop Citizenship-Based Taxation – Repeal FATCA
Citizenship-based taxation, the U.S. trade deficit and the destruction of U.S. capital
The French mini-FATCA
I suspected something like this was brewing. There is a projet de loi here in France that is quite similar to FATCA though it is limited to trusts.
You can read more here. (Article in English)
Here is a choice quotation:
Canadian RRSPs and the OVDI penalty base
This post has been cross posted from renounceuscitizenship.
See also:
OVDI Switcheroo: Canadian RRSP back in the penalty base
Re: OVDI Switcheroo: Canadian RRSP back in the penalty base
Those who entered OVDI understood (hopefully) that they were paying a fine based on a percentage of a base of assets. Obviously the lower the base, the lower the amount of the penalties. An interesting thread on this appeared on the Jack Townsend blog.
For Canadians who entered OVDI (for whatever reason) there has much been much concern over whether RRSPs would be part of the base for which the OVDI penalty was calculated. People have been asking: will RRSPs be included or not? Why won’t the IRS take a position? Now, what follows is just my thinking and interpretation. It is not legal advice (or any other kind of advice). But, here is how I think you should view this and the arguments you should make.
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