Overall impression of the conference:
Tax policy is simply to important to allow the discussion to be shaped and dominated by tax professionals! Perhaps they should not even be included in the discussion.
Advice:
Enjoy the video!
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Missed Tax Advice for the 2nd Obama Admin? Check out the video here: http://bit.ly/Zwo8qV
#ObamaTaxAdvice@TaxAnalysts@SoCalTaxProf -
#ObamaTaxAdvice Symposium has concluded. Thanks@PeppLawReview@SoCalTaxProf and everyone else who participated and watched! -
@PeppLawReview@DavidCayJ Why do we want to encourage lawyers to get billable hours out of something as bad as#FATCA ?#ObamaTaxAdvice -
@PeppLawReview Are we in the era when the State is in service to the Corpration, instead of visa versa. Good question#ObamaTaxAdvice -
#ObamaTaxAdvice@DavidCayJ “We’ve got to figure out how we deal with wealth” -
Via
@PeppLawReview:#ObamaTaxAdvice: Susan Morse from@uchastingslaw now presenting her paper, “The Transfer Pricing Regs Need a Good Edit” -
#ObamaTaxAdvice: David Cay Johnston: What Have We Learned Today? -
@PeppLawReview Here is a link to MSP 8 & MSP 15 in 2012 NTA Report to Congress. http://bit.ly/VL0oki#ObamaTaxAdvice#Americansabroad -
#ObamaTaxAdvice@DavidCayJ moments from providing closing remarks. Watch at http://new.livestream.com/pepperdinesol/lawreviewsymposium … -
@PeppLawReview To understand IRS practices & problems of#Americansabroad see MSP 8 & MSP 15 in 2012 NTA Report to Congress.#ObamaTaxAdvice -
@PeppLawReview Robert wud only like FATCA untill he lived abroad and had to deal with the US offshore Complexity & penalties.#ObamaTaxAdvice -
@PeppLawReview Allison is telling some of the realities. IRS offshore jihad is creating FEAR of FBRA penalties and mistrust .#ObamaTaxAdvice -
@PeppLawReview Allison is right, FATCA IGA is NOT recipicol. The Concept of taxing U.S. Persons around the globe is unusal.#ObamaTaxAdvice -
@PeppLawReview If we get it right? FATCA is NOT getting it right, So, we need to fix it. UNINTENDED CONSEQUENCEs.#ObamaTaxAdvice -
@PeppLawReview#ObamaTaxAdvice for us folk new to int’l tax issues, is FATCA basically the ugly big brother to FBAR? -
#ObamaTaxAdvice@TaxAnalysts@RobertGoulder FATCA is really a tax gap issue. All the other countries are watching it -
@PeppLawReview FATCA is the ‘Tip of the Spear’ of a global GATCA in the making! This is NOT good for a world economy!#ObamaTaxAdvice -
#ObamaTaxAdvice —@RobertGoulder, in defense of FATCA: “If you seek to tax a thing, people shouldn’t be allowed to hide that thing.” -
@PeppLawReview Robert Goulder of Tax Analysts It is not drone precision strike, it is carpet bombing. How can U like that?#ObamaTaxAdvice -
@PeppLawReview Robert Goulder of Tax Analysts Law students FATCA is your future That is terrible news for the future!#ObamaTaxAdvice -
#ObamaTaxAdvice: Law students take note:@RobertGoulder calls FATCA the future for tax lawyers’ practice -
#ObamaTaxAdvice@TaxAnalysts@RobertGoulder: Corporate residence is wherever you want it to be for tax planning and that can’t be sustained -
@PeppLawReview Robert Goulder of Tax Analysts what is Corporate residence in this day and age? Good question.#ObamaTaxAdvice -
#ObamaTaxAdvice@TaxAnalysts@RobertGoulder providing commentary -
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@PeppLawReview#Americansabroad should not be taxed on income abroad until repatirated just like Corprations#ObamaTaxAdvice -
@PeppLawReview Robert Goulder of Tax Analysts yet to be sold on Territoriality#ObamaTaxAdvice -
@PeppLawReview Robert Goulder of Tax Analysts agrees that Camp and Obama tax proposals not that different#ObamaTaxAdvice -
@PeppLawReview What do U think are the realistic chances that Congress will vote for domestic FATCA IGA reciprocity?#DATCA#ObamaTaxAdvice -
@PeppLawReview How can there be real reciprocity when FATCA IGA reciprocity only asperational. Nn a Full blown DATCA in US#ObamaTaxAdvice -
#ObamaTaxAdvice: Susan Morse from@uchastingslaw now presenting her paper, “The Transfer Pricing Regs Need a Good Edit” -
#ObamaTaxAdvice: Susan Morse (UC-Hastings), The Transfer Pricing Regs Need a Good Edit -
#ObamaTaxAdvice — Christians: In a world of dual citizens, citizenship-based taxation does not work; penalizes Americans for going abroad. -
#ObamaTaxAdvice Allison Christians from#LAWMcGill Get real on citizen based taxation! Switch to residence based tax -
@PeppLawReview switch to residence-based taxation and do away with Citizenship taxation! AMEN Clear MESSAGE#ObamaTaxAdvice -
#ObamaTaxAdvice — Christians considers FATCA: “reciprocity an aspiration at best,” US tax jurisdiction “intrusive.” But, FATCA can be saved -
#ObamaTaxAdvice Allison Christians from@LAWMcGill FATCA: Fix it or Forget It -
@PeppLawReview Public exposure for all Corporates FATCA – fix it, or abandon it! Will not stop offshore taxation#ObamaTaxAdvice -
@PeppLawReview Boy,this is an audiences that should know! This is shocking. NO wonder FATCA is the worst law unknown in US#ObamaTaxAdvice -
#ObamaTaxAdvice: Christians: FATCA, and EITI: we are the master of our tax donmain -
@PeppLawReview Christians discusses EITI, a little know concept.#ObamaTaxAdvice -
#ObamaTaxAdvice — Christians asking what FATCA is. Less than half the room raises their hands. And practically no one can identify EITI -
#ObamaTaxAdvice: Christians: The mercenary tendency of the tax state -
@PeppLawReview FATCA begets Domestic DATCA begets Global GATCA Creating a GATCAwellian future.#ObamaTaxAdvice#Americansabroad -
@PeppLawReview FATCA, the worst legilsation most Americans have never heard of.@repealfatca and start over.#ObamaTaxAdvice -
#ObamaTaxAdvice — Christians on why we must save the income tax: “States devolving to taxing the easy to tax” -
@PeppLawReviewIf Christians educates you on the unknown provisions of FATCA legislation. Pay attention. NO public scurtiny
#ObamaTaxAdvice -
#ObamaTaxAdvice — Allison Christians from@LAWMcGill now presenting her paper, “Putting the Reign Back in Sovereign.” -
#ObamaTaxAdvice: Allison Christians (McGill), Putting the Reign Back in Sovereign: Advice for the Second Obama Administration -
@PeppLawReviewIf Allison Christian speaking at the FATCA FACT Finding Forum with transcript http://bit.ly/VbSX4g
#ObamaTaxAdvice -
#ObamaTaxAdvice — Reuven Avi-Yonah from@UMichLawspeaking now. His paper is on SSRN:http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2197829 … -
@PeppLawReviewIf Reuven Avi-Yonah paper. The case against Citizenship Taxation http://bit.ly/13tFkB7
#ObamaTaxAdvice -
#ObamaTaxAdvice: Moderator: Khrista McCarden. Panelists: Reuven Avi-Yonah, Allison Christians, and Susan Morse. Commentary: Robert Goulder -
#ObamaTaxAdvice: Reuven Avi-Yonah (Michigan), Corporate & International Tax Reform for the Second Obama Administrationhttp://taxprof.typepad.com/taxprof_blog/2013/01/free-live-webcast-today-.html … -
Friday afternoon in Malibu,
@PeppLawReview packs in 100+ to hear#ObamaTaxAdvice great panelists, great attendees. -
#ObamaTaxAdvice — Fourth and final panel, Business and International Tax #2, now underway. Watch onlinehttp://new.livestream.com/pepperdinesol/lawreviewsymposium … -
#ObamaTaxAdvice: Panel 4: Business and international tax (continued) -
#ObamaTaxAdvice — Burke clarifies her position in Q&A: Lowering the corporate rate might not be advisable. -
#ObamaTaxAdvice — Schler: Global cooperation no panacea; problems would remain -
#ObamaTaxAdvice: Michael Schler of Cravath skeptical of Burke’s emphasis on taxing passthroughs; REITs should at least get similar treatment -
#ObamaTaxAdvice: Commentary: Michael Schler (Tax Partner, Cravath, Swaine & Moore, New York) -
@PeppLawReview If Profit shifting abroad reduced interest deduction in the US, it wud reduce the behaviour, says Sullivan#ObamaTaxAdvice -
#ObamaTaxAdvice — Sullivan: Proposes allocating interests by gross profit. Benefits: (1) simple; (2) acts as a brake on profit shifting. -
#ObamaTaxAdvice@TaxAnalysts Martin Sullivan: Instead of allocating interest by assets, what about allocating by gross profits? -
@PeppLawReview Unilateral action always leads to resentment around the world about US financial imperialism See FATCA#ObamaTaxAdvice -
@PeppLawReview Geithner says he might favor a territoral tax system for Corps, but what about real DNA people?#ObamaTaxAdvice -
#ObamaTaxAdvice@TaxAnalysts chief economist Martin Sullivan: Territorial can mean a lot of different things, it all depends on the details -
#ObamaTaxAdvice: Martin Sullivan (Tax Analysts): territorial tax system can be “with teeth” (raise revenue) or “toothless” (reduce revenue) -
#ObamaTaxAdvice — Martin Sullivan from@TaxAnalysts now up. -
@PeppLawReview Territorial reform for paper people, Corporations,must also apply to real DNA persons. Repeal Citizenship tax#ObamaTaxAdvice -
#ObamaTaxAdvice: Burke: Congress should expand the corporate tax base and impose an entity-level tax on large partnerships. -
25% rate dividends cap gains & 25% Corp rate wud reduce the effect of Corps being a vehicle for tax shelteing per Burke
#ObamaTaxAdvice -
#ObamaTaxAdvice: Burke: Rise in income tax rates and decrease in corporate tax rates would create incentives to retain corporate earnings -
@PeppLawReview Blocker Corporations was what Romney used, right? To lower his effective rates?#ObamaTaxAdvice -
Double Irish Dutch Sandwich should be a two-layered Guinness-based ice cream on an apple tart.
#ObamaTaxAdvice#ObamaRecipeAdvice -
#ObamaTaxAdvice — Burke: “I’m all for repealing the stepped up basis.” -
#ObamaTaxAdvice Karen Burke@USanDiegoLaw: If we’re going to lower the corporate tax rate, someone is going to have to subsidize it -
#ObamaTaxAdvice Karen Burke@USanDiegoLaw : In 1950s corporate tax responsible for 50% of tax revenue today it’s less than 10% -
#ObamaTaxAdvice — Burke: Reduction in corporate tax rates necessary; passthrough entities should bear greater tax burden. -
#ObamaTaxAdvice: Burke: Passthrough sector accounts for almost 50% of net business income. -
#ObamaTaxAdvice: Karen Burke (San Diego), Passthrough Entities: The Missing Link in Business Tax Reform -
#ObamaTaxAdvice — Karen Burke from@USanDiegoLaw now delivering her paper. Watch onlinehttp://new.livestream.com/pepperdinesol/lawreviewsymposium … -
#ObamaTaxAdvice — Can US act unilaterally to remedy a global problem? Bank says no. Cooperation not only appropriate but inevitable. -
#ObamaTaxAdvice — Steve Bank from@UCLA_Law: Corporate tax reform a “global phenomenon” -
#ObamaTaxAdvice: Bank: Any U.S. corporate tax reform must reflect global corporate tax reform. -
#ObamaTaxAdvice: Steve Bank (UCLA), The Globalization of Corporate Tax Reform http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2200662 … -
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#ObamaTaxAdvice w/ Steve Bank from@UCLA Problem is multinationals aren’t paying taxes anywhere, it’s a global problem not just a US problem -
#ObamaTaxAdvice: Grayson McCouch (San Diego), Who Killed the Rule Against Perpetuities? -
#ObamaTaxAdvice: McCaffery: It is time to give up on the estate & gift tax. It no longer serves any compelling policy objective. -
This is the first of two Business and International Tax panels.
#ObamaTaxAdvice -
#ObamaTaxAdvice: Ed McCaffery (USC), Reimagining Estate Tax Reform -
#ObamaTaxAdvice panel on Business/International Tax being moderated by Tom Bost from@pepperdine Tweet your questions to@PeppLawReview -
#ObamaTaxAdvice now resuming. Tom Bost moderating w/ Steve Bank, Karen Burke, & Martin Sullivan on the panel. Michael Schler w/ commentary -
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Lunch Break. See you all back at 1:45pm!
#ObamaTaxAdvice -
McCaffery: A consistent VAT tax can act similar to an inheritance tax, taxing the spending of inheritance.
#ObamaTaxAdvice -
Tax Analysts’
@jthorndike: “If inequality is the problem, then the estate tax has never really been the answer.”#ObamaTaxAdvice -
@jthorndike (Tax Analysts): The resistance of the rich to progressive tax reform is a very important thing to understand#ObamaTaxAdvice -
@jthorndike: “If tax is such a failure, a distraction, then why the durability of the distraction?”#ObamaTaxAdvice -
@jthorndike up now with commentary on the tax papers.#ObamaTaxAdvice -
Repetti: “A progressive income tax can play a role in reducing inequality.”
#ObamaTaxAdvice -
RT
@taxanalysts: Repetti: “Higher income inequality correlates with greater measures of health and social problems.”#ObamaTaxAdvice -
Repetti: “Higher income inequality correlates with greater measures of health and social problems.”
#ObamaTaxAdvice -
Up now: Jim Repetti, Boston College Law School. http://bit.ly/Zwo8qV
#ObamaTaxAdvice -
James R. Repetti (Boston) presenting: Occupy the Tax Code: Using the Estate Tax to Reduce Inequality.
#ObamaTaxAdvice -
McCouch: “The $5 million dollar exemption for estate and gift taxes makes no sense at all.”
#ObamaTaxAdvice -
Grayson McCouch (San Diego): “The $5 million estate and gift tax effective exclusion is a mistake and should be curtailed”
#ObamaTaxAdvice -
@RBreaux87 Great! Thanks for watching! Remember to tweet your questions to@PeppLawReview!#ObamaTaxAdvice -
Up now: Grayson McCouch, University of San Diego School of Law. Watch LIVE: http://bit.ly/Zwo8qV
#ObamaTaxAdvice -
Ed McCaffery (USC): Canada has figured out how to tax capital gains at death, we can too.
#ObamaTaxAdvice -
McCaffery (USC): “Tip #1 for the Obama Administration: Repeal §1014, the stepped-up basis on death rule.”
#ObamaTaxAdvice -
#ObamaTaxAdvice: Watch panel on estate and gift tax featuring@SoCalTaxProf, Ed McCaffery, Grayson McCouch, Jim Repetti, and@jthorndike. -
RT
@pepplawreview: Estate and Gift Tax Panel begins now!#ObamaTaxAdvice http://ow.ly/gWfwA -
Ed McCaffery (USC): The Estate Tax is bad in theory, impractical in practice, and largely moot.
#ObamaTaxAdvice -
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Thanks
@FATCA_Fallout for joining the conversation by tweeting to@PeppLawReview. Stay tuned for panel on Estate & Gift Tax!#ObamaTaxAdvice -
@PeppLawReview although, admittedly, AU & NZ income tax filings are simplier. A gross income is a gross income, not an AGI#ObamaTaxAdvice -
@PeppLawReview My experience, with NZ and AU, is when A GST gets installed, the income tax filing does NOT go away.#ObamaTaxAdvice -
@PeppLawReview Good panel, & good discussion. Thanks for letting us watch. Need microphones for questions in the audience.#ObamaTaxAdvice -
@FATCA_Fallout Also, a VAT could mean that 100 million less must fill out those forms.#ObamaTaxAdvice -
@PeppLawReview Simplicity suggestion. Make all Americans fill out tax forms without software or proffessional advice. 🙂#ObamaTaxAdvice -
#ObamaTaxAdvice: FDR and JKK agreed: biggest mistake of American left was to rely on the income tax to fund the government. Stark is right. -
@PeppLawReview I do hear the answer, and know it is Congress passes the law, but the combination is toxic for compliance.#ObamaTaxAdvice -
@PeppLawReview New Zealand too has a 5 % assumed return rate but the calculation to compute is very complex. Not great idea!#ObamaTaxAdvice -
@PeppLawReview How do we get Tax simplicity with reduction in form complexity? IRS has never met a form they don’t like!#ObamaTaxAdvice -
Send your questions now to
@PeppLawReview#ObamaTaxAdvice -
@PeppLawReview@BruceBartlett: is exactly right about form complexity. That is a BIG tax in professional fees alone!#ObamaTaxAdvice -
@BruceBartlett: We need a substantial increase in the Tax-GDP ratio.#ObamaTaxAdvice -
#ObamaTaxAdvice: Bartlett: I’m a strong supporter of Graetz’s tax reform plan -
#ObamaTaxAdvice: Watch@BruceBartlett commentary now!http://bit.ly/Zwo8qV -
#ObamaTaxAdvice: Bartlett: Likes Brown’s idea to audit members of Congress, but let’s go further: require them to release their tax returns -
@BruceBartlett: “I would make it a matter of law that every member of congress must produce their tax returns”#ObamaTaxAdvice -
@PeppLawReview A mark to market asset tax is too radial. Many unintended impacts especially 4#Americansabroad with FX rates#ObamaTaxAdvice -
David Miller: “Most rich people would trade away their deductions for a 10% point reduction in a moment.”
#ObamaTaxAdvice -
#ObamaTaxAdvice: Commentary by Bruce Bartlett (New York Times, Fiscal Times) -
#ObamaTaxAdvice: Miller: To dent income inequality, we must dent wealth inequality via mark-to-market system -
@PeppLawReview Middle class has had it pretty good when it comes to both share and effective rate of taxes paid.#ObamaTaxAdvice -
David Miller: “More middle class are moving to the upper class than the lower class.”
#ObamaTaxAdvice -
#ObamaTaxAdvice: Commentary by David Miller (Tax Partner, Cadwalader (New York)) -
@PeppLawReview Thank you. I will. Very interesting so far, especially the points on middle class tax share and rates#ObamaTaxAdvice -
@PeppLawReview Good point. Middle class tax cuts have reduced effective rates faster than their reduction in income.#ObamaTaxAdvice -
Stark: “Middle class tax cuts have been the political grease that make possible tax cuts for the top quintile.”
#ObamaTaxAdvice -
@FATCA_Fallout Stay tuned for our afternoon panels: “Business/International Tax #1-2” @ 1:45-4:30pm#ObamaTaxAdvice -
#ObamaTaxAdvice: Stark: middling middle class tax cuts are the grease that enable huge tax cuts for the rich -
#ObamaTaxAdvice: Stark: income, wealth has shifted from middle class to the rich -
Stark: The shrinking American Middle Class is a 30-year trend.
#ObamaTaxAdvice -
#ObamaTaxAdvice: Stark: The middle class in decline (Pew data Aug. 2012) -
@PeppLawReview Fundamental Tax reform must include the end of Citizenship taxation and adoption of Residency based system.#ObamaTaxAdvice -
#ObamaTaxAdvice: Kirk Stark (UCLA) & Eric Zolt (UCLA), Tax Reform and the American Middle Class -
Kirk J. Stark (UCLA): Tax Reform and the American Middle Class.
#ObamaTaxAdvice -
Lipman (UNLV): We must preserve the anti-poverty relief in the tax code.
#ObamaTaxAdvice -
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@PeppLawReview Please address the security and data theft concerns of FATCA BIG DATA collection on ALL#Americansabroad#ObamaTaxAdvice -
Lipman: “Social Security is the largest anti-poverty relief program in the country.”
#ObamaTaxAdvice -
@TaxAnalysts Americans don’t read these dense reports, & media don’t report, so I predict a BIG yawn. Look at#FATCA#ObamaTaxAdvice -
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Brown: Money can’t buy everything. Fundamental tax reform is still possible.
#ObamaTaxAdvice -
#ObamaTaxAdvice: 3 tax reform ideas: employer-provided pensions, preferential capital gains tax rate, mortgage interest deduction -
Dorothy Brown: “I predict that after the 535 report is released, the public will get angry.”
#ObamaTaxAdvice -
@PeppLawReview FATCA = resentful angry#Americansabroad.Stop Citizenship Taxation. Adopt world standard of resident based#ObamaTaxAdvice -
#ObamaTaxAdvice: Brown: true tax reform begins when the IRS audits the tax returns of every member of Congress -
#ObamaTaxAdvice: Brown: Recent fiscal cliff tax legislation hurts persons of color -
#ObamaTaxAdvice: Dorothy Brown (Emory), The 535 Report: A Pathway to Fundamental Tax Reform -
Dorothy Brown: The recent fiscal cliff deal was not a good deal for the middle class.
#ObamaTaxAdvice -
@PeppLawReview Why do we think 544 pagers of Complex FATCA regulations & mulitple IGAs is going to solve Offshore Evasion?#ObamaTaxAdvice -
Brunori: We have a terrific opening panel today. Our speakers are truly among the leading thinkers in tax practice & policy.
#ObamaTaxAdvice -
#ObamaTaxAdvice: Moderator David Brunori promises the best panel of the day -
#ObamaTaxAdvice: Panel 1 begins: The Buffett Rule, the 1%, and the Fairness/Growth Divide -
#ObamaTaxAdvice: Graetz bottom line: tax system needs overhaul, not an income tax lube and oil change -
#ObamaTaxAdvice: Graetz advice to Obama: return tax system back to what it was in 1913 -
Prof. Michael Graetz of
@ColumbiaLaw: A 12% national sales tax could fund a $100k exemption from the income tax.#ObamaTaxAdvice -
Prof. Michael Graetz of
@ColumbiaLaw: Our nation should return to a tax system more like that of 1913.#ObamaTaxAdvice -
Graetz: “Today’s tax reform challenge is daunting.”
#ObamaTaxAdvice -
#ObamaTaxAdvice: Graetz: As the income tax approaches its 100-year birthday, it is time for it to quietly die. -
Graetz: “The IRS has become the administrator of many of the nation’s most important spending purposes.”
#ObamaTaxAdvice -
#ObamaTaxAdvice: Graetz: Tax reform that focuses on the income tax is a dead end. -
Graetz: Globalization has made increased taxation of corporate entities counterproductive.
#ObamaTaxAdvice -
#ObamaTaxAdvice Prof. Michael Graetz cites this tax gem from Greenspan in 2001, predicting easy payoff of U.S. debthttp://www.federalreserve.gov/boarddocs/speeches/2001/20010427/default.htm … -
I’ll be live-tweeting
#ObamaTaxAdvice from the@PeppLawReviewaccount later today. -
#ObamaTaxAdvice: Graetz: 1986-style tax reform (revenue and distributional neutrality) is impossible today -
Graetz: “There is no pot of gold from which to finance tax reform.”
#ObamaTaxAdvice -
Graetz: “Tax reform was not only revenue neutral but was also distributionally neutral.”
#ObamaTaxAdvice -
#ObamaTaxAdvice: Graetz: From inception, income tax was more about social justice than revenue generation -
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@BerginChris: “We are relentless in the pursuit of truth.”#ObamaTaxAdvice -
#ObamaTaxAdvice symposium about to begin! Don’t forget to watch live webcast & tweet your questions to@PeppLawReview.http://bit.ly/Zwo8qV -
RT
@pepplawreview: Watch@BruceBartlett@jthorndike@DavidCayJ@SoCalTaxProf & many others discuss#ObamaTaxAdvice @ 8:45am PST /11:45am EST -
Watch
@BruceBartlett@jthorndike@DavidCayJ@SoCalTaxProf and many others discuss#ObamaTaxAdvice Starts at 8:45am PST / 11:45am EST -
Watch
@PeppLawReview &@TaxAnalysts Symposium Live! Starts at 8:45am PST / 11:45am EST http://bit.ly/Zwo8qV#ObamaTaxAdvice -
One hour until the live webcast of
#ObamaTaxAdvice symposium. Tweet your questions to@PeppLawReview. http://bit.ly/Zwo8qV -
#ObamaTaxAdvice symposium! Pro tip: it will be webcast live and@PeppLawReview will be taking questions http://bit.ly/STh8lE Join in! -
Tomorrow @ 8:45am PST: Live Webcast of Tax Advice for Obama!http://bit.ly/Zwo8qV tweet us your questions!
#ObamaTaxAdvice@TaxAnalysts -
RT
@PeppLawReview: Live Webcast of Tax Advice for Obama! Friday-8:45am PST. http://bit.ly/Zwo8qV & http://bit.ly/VI7G9b#ObamaTaxAdvice… -
RT
@PeppLawReview: Live Webcast of Tax Advice for Obama! Friday- 8:45am PST. http://bit.ly/Zwo8qV & http://bit.ly/VI7G9b#ObamaTaxAdvice… -
Live Webcast of Tax Advice for Obama! This Friday @ 8:45am PST.http://bit.ly/Zwo8qV & http://bit.ly/VI7G9b
#ObamaTaxAdvice@TaxAnalysts -
We are pleased to announce a live webcast for our Tax Symposium next Fri, Jan. 18th. http://bit.ly/Zwo8qV
#ObamaTaxAdvice@TaxAnalysts
Pepperdine Law Rev. 
Tax Analysts 
Marvin Van Horn 
UC Hastings Law 
Paul Caron 
Aaron M. White 
Derek T. Muller 
Pepperdine Alumni 
Ryan Killian
*I think billing this law review as some sort of big time or influential conference is vastly overstating the case. Few will pay attention and fewer inside the beltway will give a damn. Oh well, i suppose we have to carry on. The best hope still lies with Flaherty and perhaps the NDP and the Libs. Wonder what Kevin O’Leary will do. I heard Amanda say he had given up his green card.
Just go here …
http://new.livestream.com/pepperdinesol/lawreviewsymposium
… and go to the end of the video for Prof. Christians presentation plus the mostly inaudible Q&A at the end of the final panel. Be sure to read the excellent comments below the video posed by Julian Hudson. Excellent comments but I see no responses. My opinion of so-called academic tax experts is not very high at this point. Their EQ (Empathy Quotient) is extremely low (Christians and Avi-Yanah excepted).
Duke says: The best hope still lies with Flaherty and perhaps the NDP and the Libs.
That falls somewhere on the spectrum between chuckle and belly laugh this fine Saturday. Isn’t the phrase “mind forg’d manacles” a lot classier than the the word “slaves”?
FATCA: You cannot FIX it, so you must DEEP SIX it!
At least this Pepperdine Law Conference has given us a momentary glimpse into the philosophical fountainhead of the FATCA disaster, and for that we may be grateful. We are reminded of how easily the face of evil can so cleverly disguise itself behind a mask of (false) logic and (self-serving) good intentions. That the views of Allison Christians would be so easily marginalized and dismissed as merely amusing yet ultimately impotent ravings of an extremist demonstrates just how powerful the pro-FATCA lobby truly is.
Let us not forget who the real leaders of our country are – the bankers, aided by their legions of lawyers. Whatever they counsel our Canadian government to do will be how this unfolds – mark my words.
We will soon understand in the most visceral way possible the true meaning of the term “collateral damage.” All we might have left for some temporary recourse are the words of the Canadian Charter of Rights and Freedoms as we slowly, painfully put them to their greatest test. However, this will take many years to play out and by then great, irreversible damage will already have been done as FATCA morphs into GATCA. The New World Order will have achieved its most important victory – complete control of the world’s financial system – and all without firing a shot.
“Let us not forget who the real leaders of our country are – the bankers, aided by their legions of lawyers.”
Bankers don’t have any interest in this happening. For them, FATCA or GACTA, means huge compliance costs, and lost of capital as people repatriate their money in one country and close accounts in others. Once the US bankers lobby against that will start, we might see some momentum in repealing the law and hope that the damage at that point can still be repaired.
Hopefully, the banking industry lobby is more powerful than the lawyers lobby.
@Christophe
My point about Canadian bankers is that they are simply looking for the least damaging outcome for themselves from a very limited set of bad options. Their calculus, and our government’s own sense of realpolitik, will be to cave-in and sacrifice a million U.S. Persons in Canada for the “greater good” of 34 million other Canadians, even if that narrative is absolutely false since the enormous costs of FATCA compliance will be borne by ALL Canadians.
As for the role of U.S. bankers, that will only have an impact if the U.S. does indeed force DATCA rules on its homeland financial institutions. There is no compelling reason to believe that this will actually come to pass, especially once a critical mass of IGA’s have been signed with foreign governments. The very wording of the model agreements ensures no commitment of reciprocity on the part of the U.S., so once they have everything they want then there will no longer be a need to hold-out the false promise of foreign access to U.S. financial institutions. At that point, the rest of the world will have already enslaved itself with no further need to dangle a chimeric carrot of reciprocity that would have had limited impact anyway due to the fundamental differences between the world’s residency-based and America’s citizenship-based taxation systems. The U.S. understands this difference very well and is simply using the language of “reciprocity” as a Trojan horse to secure full FATCA compliance by the rest of the world.
*Deckard1138
Lets not give in so easily. There are a LOT of us and still very few of THEM. We still have strength in numbers. We need to hold off the US as best as we can until we can get better organized.
@Tim
My feelings are hardly of wanting to “give in” but I think they do reflect my growing understanding of just how huge a fight we have on our hands and how little time is left on our side. If our efforts to reach out to the media and our elected officials have begun to bear any fruit then I guess we’ll know soon after Parliament reconvenes.
Can we actually head-off at the pass the signing of an IGA, or will we be forced into full reactive mode once it’s been quietly announced? The deafening silence of both our government and the Canadian Bankers Association leads me to conclude that, realistically, we will soon be confronted with having to repeal a Canadian IGA, a far more challenging task than keeping it from coming to pass in the first place. I don’t have any money on this, but if I were a betting man I know which way I’d go.
@Tim,
Do you think the rest of the LOT of us will ever show up? How do we convince others there is a fight to be had and of the strength we’d have in numbers?
Deckard1138 at 4:35 pm and 6:03 pm and 7:10 pm –
It bolsters my spirits to see a voice of Realpolitik speaking so clearly. Thank you and huzzah! Those who grasp at patent will-o-the-wisps – and especially those whose experiences of activism consist of little more than ether-blather – induce a sadness that obliterates scorn. Ostrich medallions will become a permanent feature on the menu of the IRS cafeteria. Sauve qui peut.
Pingback: The Isaac Brock Society - #FATCA may end the taxation of US Persons Abroad
@usxcanada
There will be more ostrich medallions at the IRS cafeteria coming out of UK if this happens as reported.
The $50K ostrich head covering sand is removed.
Just Me –
I myself do find ostrich very tasty, but it’s been a long time since I’ve crossed paths with an opportunity to partake. Perhaps I should apply for a job with the IRS? When I saw that recent comment somewhere on Brock about favoring simplicities in data processing, my antenna went on a tingle spree. Yes, absolutely. Why would any sane enterprise under a reporting constraint care about anything other than separating the zeroes (US persons) from the ones (non US persons). Leave it to the IRS to worry about who might have more than $50K. Why do all that extra pitfallish work just to tote their water bucket for them?
@usxcanada
I left this message to a FCC (FATCA Compliance Complex) guy on Linkedin in searching for a software solution to meet FATCA compliance requirements… He asked:
In a build vs. buy world, are there any off-the-shelf software programs currently on the market to help firms be FATCA-compliant?
To which I replied:
I know this might seem radical, but do neither. Rather than try to discriminate between US persons and non US persons, resident or nonresident in your country; rather than try to determine who is grandfathered, or who is above or below $50K, just make your life easy, and report everyone, everything!
This is the International Revenue Service after all, and the long term goal is a global GATCA of automatic exchange. Just send them your entire client account list, balances, transactions, etc and let them sort out what they want! Your clients won’t know the difference. Just tell them that the FATCA Fatwa made you do it, and see what if anyone balks. All right, I am tongue-in-check, but that is what it is coming to, so you might as well start educating everyone that we are now in the era of Facebook Banking. No privacy!. Total asset and account transparency is what they want, so might as well start with you! 🙂
This is germane to the subject of information sharing…
Will U.S. Hypocrisy on Information Sharing Continue?
by Lee A. Sheppard
In news analysis, Lee A. Sheppard explains why the United States is not engaged in information sharing with Latin American countries and why many nations avoid signing a tax treaty.
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