Yearly Archives: 2012

WhatamI commented:

I was born in the US to Canadian parents in 1954. We moved back to Canada in 1966 when I was 12. I have a Canadian certificate of “Canadian Citizen Born Abroad”. I’m now 58. I’ve never worked in the US, never filed any US tax form, never had a US passport. My Canadian passport of course says I was born in the US. As a kid, I remember my mother saying I was a dual citizen up to a certain age. I remember going to the US consulate here in Calgary in the early 70′s. I was somewhere between 18 and 22 or so. I went to ask if I was a dual citizen and what advantage there was to it. As I recall, I was told dual citizenship didn’t really exist and that I wasn’t an American citizen.

Continue reading →

According to G&M writer Adam Radwanski’s Twitter feed:

http://twitter.com/aradwanski

As a follow up to the interviews of Swiss bank employees who feel betrayed by the banks (https://isaacbrocksociety.ca/2012/08/28/interviews-on-swiss-tv-bank-employees-upset-about-their-names-being-disclosed-to-the-us/)  Swiss Francophone RTS’ TTC (“Toutes taxes comprises”)  has come out yesterday with a broadcast tracking the diminishing confidence that the Swiss have in the banks.  The situation has been going on for at least a decade, probably starting with the SwissAir crisis:  http://www.rts.ch/video/#/video/emissions/ttc/4243403-les-banques-dans-la-tourmente.html

There will be another Infrarouge debate tomorrow (Wednesday) on RTS, entitled “Special Program- Bank Employees: Has Switzerland Capitulated?   http://www.infrarouge.ch/ir/1930-emission-speciale-employes-banque-suisse-elle-capitule

There is a FORUM at the bottom of the page, I would encourage everyone to sign up and post their comments, in French if possible, but if you can only write in English the post should also be accepted.  It is important to constantly remind the viewers and readership of journalists like RTS Info that the bank-related issues are not only about FatCats and money laundering but also about lowly bank employees just trying to do their job and make a living, and people living in Switzerland, paying Swiss taxes, and being nonetheless chased by the IRS for double taxes, FBAR and FATCA, and being shunned out of even the most basic and neccesary banking services by many banks in Switzerland.

At a first look, the Obama store is quite impressive.  It’s got goodies for all kinds of people, many of which were discriminated against in the past.  A google on “women” returns 1’980 hits.  “African” scores 1’950 hits.  Nurses, Latinos and environmentalists just barely trailed behind with 1’940 listings each.  “Jewish” returns 1’930 listings.  “Veterans” is listed 1’920 times.  While the word “Gay” only returned the home page, “LGBT” was found 1’840 times.  Quite impressive!  Pets are listed 1’820 times.  There is even an “LGBT for Obama Dog Bandana“!  Dogs are very important voters in presidential elections, with a relevance of 470 results.   “Asian“, being less profitable for the campaign than dogs, returned 198 listings linked 194 times to “Pacific Islanders”.  However, AAPI‘s do have their own collections page listing 4 items, unlike dogs.   For babies, 198 listings were returned, but nothing for Mormons, for whatever reason, even though they are not Muslims who also have nothing to buy.

But, that’s not why I went to the store.   I want to the store to see how valuable Americans abroad are for campaign contributions and I looked and looked, but could not find.  No abroad, no overseas, no expat, no nothing.  Not even “US person“, FATCA, FBAR, or offshore.  Foreign, however, popped up 1’760 times, but that’s only to say:

This contribution is not made from the funds of an individual registered as a federal lobbyist or a foreign agent, or an entity that is a federally registered lobbying firm or foreign agent.

So, what does this show?  It shows that Americans abroad, Mormons and Muslims are not shopping at the Obama store.  I certainly could shop at the Obama store and wouldn’t mind doing so, but what have Democrats offered Americans living abroad?  Nothing that I could find.  Yet, even if I could find something for Americans living abroad, the billing page only accepts the United States in the country dropdown.

David Hemler fled the US Air Force whilst stationed in Germany during the 1980s and ended up living in Sweden under the false identity of a Swiss immigrant born in Zurich.  He only revealed himself last month after deciding to make contact with his US-based family who hadn’t heard from him since that time. He has since become a Swedish citizen and works for the Swedish government and has also received legal assurances that he should’t be deported.

Too bad you don’t automatically lose US citizenship when you desert as a serviceperson, though I imagine that such a bill has probably been floated from time to time.  Could he, or anyone else in this situation, be arrested if he tried to go into the US Embassy to renounce/relinquish citizenship? I say this, because I imagine that he has absolutely no idea of all the paperwork and failure-to-file penalties that the IRS is now going to expect from him nor of the looming FATCA deadline. I’d say he picked a pretty bad time to publicly reveal to his banks that he wasn’t born in Zurich as well…

http://www.bbc.co.uk/news/magazine-19331209

 
Cross-posted from Perspectives at USxCanada InfoShop.

 
From a broadscale, abstract perspective, the voluntary and other disclosure programs of the IRS after 2009 bear resemblance to the post 9/11 decade of tottering toward ever more byzantine and restrictive financial reporting to U.S. authorities by unfortunate “U.S. persons” who merely reside “overseas.”

 
The Decade

At the level of decade, the multiple period provisions of Form 8854 Initial and Annual Expatriation Statement bear witness to a wish to tighten the screws ever more, with very different regimes operating pre-2004, 2004-2008, post-2008. One other indicator, from a different direction, is the institution in mid-2010 of a punitive $450 fee for renunciation of U.S. citizenship, in face of a skyrocketing rate of ship-of-state jumpers.

 
Voluntary Disclosure

The voluntary disclosure programs of 2009 to the present manifest steadily upward penalty increases, to a current 27.5 percent.

According to sketchy IRS reporting as of early 2012, the 2009 program generated $3.4 billion with 95 percent closure, and the 2011 program generated another $1 billion. [1]

More IRS reporting in mid-2012 shows acquisition of another $0.6 billion and 1500 further disclosures (compared to 33,000 in the first two) under the new third open-ended program. [2]  (This 1500 quantifies the “hundreds” who were said to be eagerly coming forward after September 2011. [1])

This looks like a clear case of diminishing returns.

 
All Extraterritorials

Yet another enforcement prong, in operation for about a year, deserves scrutiny. In December 2011 the IRS restated existing procedures for persons “residing outside the U.S.” under the guise of advertising policy relaxation. [3]  The IRS then followed up in mid-2012 with an announcement of specific guidelines to come. [4]  At the end of August 2012 the specifications [5] made it apparent that potential participants would gain little assurance by “coming in from the cold,” could well expose themselves to unwarranted harsh scrutiny, and would certainly subject themselves to severe compliance costs in the form of legal and accounting fees.

The IRS together with its master the United States government increasingly look like dancers paired as a mad duo dervish, whirling ever faster in dubious pursuit of payoff phantasms, with onlookers increasingly bemused by the perverse chasing of the partner’s tail.

 
References

[1]  IRS Offshore Programs Produce $4.4 Billion To Date for Nation’s Taxpayers; Offshore Voluntary Disclosure Program Reopens

[2]  IRS Says Offshore Effort Tops $5 Billion, Announces New Details on the Voluntary Disclosure Program and Closing of Offshore Loophole

[3]  Information for U.S. citizens or dual citizens residing outside the U.S.

[4]  IRS announces efforts to help U. S. citizens overseas including dual
citizens and those with foreign retirement plans

[5]  Instructions for new streamlined filing compliance procedures for non-resident, non-filer U.S. taxpayers