Liberty and justice for all United States persons abroad

The Isaac Brock Society

Posted on by Posted in Issues regarding US persons abroad 65 Comments

Wendy McElroy has written an interesting article describing the means by which one would be stopped at the border due to a tax debt. In spite of how frightened everyone is about crossing the border, there is at least one factor that a majority of expats would not meet and that is, having a sizeable tax debt. Mere non-compliance appears not to be a strong enough condition to warrant use of some of the more stringent methods available such as passport check,TECS, FBAR, or Consumer Credit eports.

Ne Exeat Republica The IRS’s powerful new weapon is actually an old one that hearkens back to 18th century English royal court, and was introduced in America as a tax collection tool by the Revenue Act of 1918. It is called ne exeat republica, which is Latin for “let him not go out of the republic.” The writ is issued to prevent a person from leaving a jurisdiction until he satisfies a claim brought against him in court. In practical terms, the IRS is using this law to obtain a court order that prevents people who owe taxes from leaving the U.S. once they have entered

Who would be most vulnerable to ne exeat republica? According to current IRS policy, “Writ Ne Exeat Republica is another action authorized by IRC §7402(a). Writ Ne Exeat Republica is the appropriate suit action when the taxpayer: is about to leave the U.S., is unlikely to return to the U.S., and has conveyed or concealed property so that the property may be taken out of the U.S.”

An IRS Field Service Advisory (November 20, 1998, WL 1757128 (IRS FSA)), described the writ and the circumstances triggering it as follows: [A] writ of ne exeat republica is an extraordinary collection remedy which may result in a taxpayer being temporarily confined in prison (if unable to post suitable bond) for the taxpayer’s non-payment of federal taxes, where the Service can show generally: (1) the existence of significant tax liabilities; (2) the taxpayer has a present ability to pay the tax liabilities; but (3) the taxpayer has chosen instead to attempt to place both himself and his assets beyond the collection jurisdiction of the United States. The writ’s purpose is to ensure “the taxpayer’s continued submission to the jurisdiction of a court” in order to award effective relief … to collect tax … to reduce tax claims to judgment, and/or to compel repatriation of assets.”

IRS policy can change quickly. The people most currently vulnerable, however, would probably be those who meet the following criteria:

*they have been identified as non-complaint by the IRS;
*they have a sizeable ‘debt’;
*they reside abroad or intend to leave the U.S.;
*a tax case can be sustained in court;
*they are without assets in the U.S. but hold considerable ones abroad;
*the tax treaties with the foreign nation does not facilitate collection (Canada is IRS friendly).

No one knows how the process of entering or leaving the U.S. will evolve. The prudent should assume it will only get more difficult and unpleasant.

The IRS Manual outlines some of the tools at the IRS’ disposal for the location of taxpayers and their assets. I am listing only those which seem to impact expats easily and to create awareness of what information they are working with. In many cases, it seems many expats may still be able to “fall through the cracks” due to lack of a US Passport, SSN, never having had a (traceable) US address, etc.


Part 5. Collecting Process
Chapter 1. Field Collecting Procedures
Section 18. Locating Taxpayers and their Assets (Cont. 1)

5.1.18.13 (03-27-2012) United States Passport Office

United States Passport Office

1. The Service may obtain passport information from the United States Passport Office in connection with an official investigation. Request a passport check when the taxpayer travels overseas frequently (or there is reason to believe the taxpayer travels overseas frequently). Requests for information from the US Passport Office are called “passport checks.” Passport checks provide information contained on the most recent passport application filed by a U.S. citizen. The information may include the following :

• the last known mailing and/or permanent address of the applicant
• applicant’s occupation
• applicant’s employer
• applicant’s phone number
• emergency contact’s name, address and phone number
• spouse’s name and birthplace.

5.1.18.13.3 (05-20-2008)
Using Passport Information

1. Use any new address or new asset information received from the passport office as discussed above.
2. See IRM 5.1.12.25, Outgoing Mutual Collection Assistance Requests, if you determine that the taxpayer:
A. resides in a treaty country, or
B. has assets in a treaty country

The TECS system appears to also have limitations again, based upon matching information already in an agency’s database. The case must be strong enough for the IRS to have issued a Federal Tax Lien before one can be placed on a TECS list. This reinforces the fact that the debt must be sizeable before one need worry about being apprehended at the border. It is somewhat amusing to notice how many times the reader is cautioned not to reveal to the taxpayer, how his/her identifying information was obtained. It also seems important to note that a TECS historical record will only record an entry to the US for a citizen or green card holder; though if border info is freely exchanged, one may assume the US could request that info from the other country.

5.1.18.14 (03-27-2012) Treasury Enforcement Communications System

Treasury Enforcement Communications System = TECS

1. The Treasury Enforcement Communications System (TECS) is a database maintained by the Department of Homeland Security (DHS), and it is used extensively by the law enforcement community. It contains information about individuals and businesses suspected of, or involved in, violations of federal law.
2. For IRS field Collection, TECS provides two sources to help make contact with taxpayers or locate assets :
A. Revenue officers can request that delinquent balance due taxpayers be entered into TECS, and the Department of Homeland Security (DHS) will then advise IRS when those taxpayers travel into the United States for business, employment, or personal reasons. The taxpayers entered into TECS for this purpose are on a DHS lookout indicators list. IRS employees must help maintain the TECS database by requesting that appropriate taxpayers be entered into TECS or be deleted from TECS. (See IRM 5.1.18.14.6.1 for criteria for including taxpayers in TECS data base.)
B. Revenue officers can also request information housed in TECS on past travel that a taxpayer has made to and from the United States.

5.1.18.14.1 (03-27-2012)
TECS: DHS Lookout Indicators

1. Many of the taxpayers entered into TECS for a DHS lookout indicator are International ones because the cases usually concern persons who reside abroad. However, domestic taxpayers may also be entered into TECS if we have been unable to locate them and if they are believed to travel outside the US . Taxpayers placed on TECS are often not subject to ordinary administrative and judicial collection procedures because they frequently reside outside the jurisdiction of the US Courts. Information derived from placing a taxpayer on TECS can facilitate contact with these taxpayers or provide asset information which, in turn, may facilitate collection of their delinquent liabilities.

1. Customs and Border Protection (CBP) will notify the TECS Coordinator when ICE becomes aware that a balance due taxpayer on TECS is arriving in the US.
2. (2) CBP will provide the TECS Coordinator with some or all of the following information:
• the taxpayer’s address while in the United States
• nature of visit
• transportation of any currency over $10,000.00
• any other available travel and/or asset information.

Reminder:
The reason it is important to enter a taxpayer on TECS is it allows CBP to notify the IRS in the future (via the TECS coordinator) about when and where a taxpayer will be traveling.

1. Taxpayers will be entered on TECS for a lookout indicator only when the case meets all of the following conditions:
• The taxpayer is living outside the United States and the United States commonwealths and territories or is about to depart to reside in a foreign country.
• The taxpayer has not voluntarily resolved his/her case by full payment or other voluntary action, including an installment agreement (IA).
• A Notice of Federal Tax Lien (NFTL) has been filed for all balance due modules. See Treasury Regulation § 301.6323(f)-1.
• The total unpaid balance of assessment equals or exceeds the dollar criteria for requesting a taxpayer be entered on TECS.
• ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
6. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
7. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

Exception:
Exception: Enter a balance due taxpayer on TECS if, despite an official IRS domestic address of record, you believe the taxpayer resides in a foreign country or travels outside the United States and the United States commonwealths and territories on a frequent basis and we have not been able to contact the taxpayer.

5.1.18.14.7 (03-27-2012)
TECS Historical Travel Information

1. TECS also is a database that tracks historical travel information about taxpayers. This IRM section provides guidance for using the historical travel information available in TECS. This information may also help you attempt taxpayer contact and/or locate asset information as it can contain extensive records of commercial airline flight arrivals and departures. TECS also contains other records of air and sea travel, records of border crossings, and the specific dates that individuals have traveled to and from the United States.
2. The travel information in TECS can facilitate collection of delinquent liabilities from taxpayers who are not subject to ordinary administrative and judicial collection procedures because they often reside outside the jurisdiction of the US Courts.
3. TECS provides information that may not otherwise be available to the Service, such as where a taxpayer has traveled. This travel information may lead to the discovery of where the taxpayer has assets or conducts business activity. Additionally, TECS travel information can help determine the taxpayer’s correct country of current residency.

Caution:
Never confirm or deny the existence of a TECS record of historical travel information if a taxpayer asks how you learned about his/her past travel. Taxpayers must submit a written request to obtain information about the source of the travel information. Follow the procedures below if a taxpayer wants to request source information.
Note:
TECS historical travel information will provide both US entrance and exit information for non-resident aliens. It will only provide US entrance information for US citizens and Green Card holders.

5.1.18.14.9 (03-27-2012)
Taxpayer Request for Source Information

Advise the taxpayer to do the following if a taxpayer asks how you learned about his/her past travel:
1. write a letter requesting source information under the Freedom of Information Act (FOIA)
2. send the letter to the address provided at The U.S. Customs and Border Protection web site:http://www.cbp.gov/xp/cgov/admin/fl/foia/

5.1.18.14.10 (03-27-2012)
Using TECS Historical Travel Information

1. TECS contains information about specific dates of past international travel and locations of travel for individuals over a period of several years. It has extensive information concerning airline travel and also contains some information on other modes of travel into the US. A request for this information will provide the revenue officer (RO) with all travel information that is available; there is no need to specify particular time periods of travel

5.1.18.14.11 (03-27-2012)
Procedures for Requesting Historical Travel Information from TECS

1. Prepare Form 13931, TECS Historical Travel Request, for submission to the TECS Coordinator and include the following information:
• Taxpayer Name (Last, First, Initial)
• Known Alias(s)
• SSN
• Place of Birth (City & State or Country)
• Passport Number
• Citizenship (if not U.S.)

In spite of the original purpose of The Bank Secrecy Act (1970) to track funds engaged in money laundering and terrorism, the description below proves that the point of collecting FBAR is for the government to have acccess to information in order to locate/confiscate taxpayer’s assets.

5.1.18.16 (08-15-2013) Foreign Bank and Financial Account Report

Foreign Bank and Financial Account Report

1. A taxpayer is required to file a Foreign Bank and Financial Account Report (FBAR), Form TD F 90-22.1, if he/she has financial interest in, or signature authority over, one or more foreign financial accounts that have an aggregate value greater than $10,000 at any time during a calendar year.

2. When a taxpayer files an FBAR form, IDRS command code IRPTR will reflect that Form TD F 90-22.1 was filed by or for the taxpayer. However, command code IRPTR does not provide any of the specific information entered on the form such as the name of the bank, account number, account balance, etc.

3. See IRM 5.9.4.19, Foreign Bank and Financial Account Reports (FBAR).

4. FBAR forms are loaded onto the Currency Banking Retrieval System (CBRS) so all the information on the FBAR form will be available from CBRS. IRPTR includes the filing of an FBAR (Foreign Bank and Financial Account Report) form by a taxpayer. Although IRPTR will not reflect all information present on the FBAR form, additional information may be obtained by researching the CBRS which lists all FBAR filings. CBRS will reflect any foreign bank account or other information that was listed on the FBAR form.

5. Conduct CBRS research when IRPTR reflects that a taxpayer has filed an FBAR form to obtain the name of the bank where the account is located, the amount in the account, co-owners, and other useful information. Complete an OL5081 to become a system user and obtain a User ID and password.

Reminder:
The information is not always complete as it will only reflect the information the taxpayer entered on the form.

I would never have thought of the IRS using a credit bureau report to track a taxpayer however, with the rate that information of all types is being exchanged, it is conceivable that the IRS may, in the future, be able to request a foreign credit report.

5.1.18.18 (03-27-2012)
Consumer Credit Reports

Consumer Credit Reports

3. At the time of publication of this IRM, there are three principal consumer credit bureaus:
• Equifax
• Experian (formerly TRW)
• TransUnion

Note:
At the time of the publication of this IRM revision, Headquarters has arranged a national contract with Experian.

5.1.18.18.2 (08-15-2013)
Limitations on Ordering Consumer Credit Reports

5. You cannot secure a consumer credit report using a foreign address. See IRM 5.1.18.18.2.1 below for further information on obtaining credit reports on taxpayers with foreign addresses.

5.1.18.18.2.1 (03-27-2012)
Credit Bureau Requests for Foreign Taxpayers

1. Do not attempt to secure a credit report using a foreign address. The credit bureau vendor does not store any foreign addresses in its database.

2. Revenue officers assigned taxpayers with last known addresses in foreign countries may use the last known United States address for a taxpayer if the case requires requesting a United States credit report.

• It does not matter how old the last known address is.
• The taxpayer address used for a credit bureau request should be the same as that on the Integrated Data Retrieval System (IDRS) except when the address on IDRS is foreign. Use the last known United States address in that instance.

4. If the taxpayer has never had a known address in the United States, a credit report cannot be requested.

While there are no guarantees, I find the information above somewhat reassuring that most expats are unlikely to have real concern about being apprehended at the border. Hassled, maybe, but if one has not applied for a US passport, has never had a US address, no SSN, and remembers that for all practical purposes, his/her assets are located outside of the juridiction of US courts, there should be no reason to allow anxiety to create more difficulty than is likely to be experienced.

65 thoughts on “Ne Exeat Republica — The Next IRS Tactic vs. Expats and Accidental Americans?”

  1. I agree, AnonAnon:

    Why, oh why, is there no serious public debate on this other than in web sites like this, leaving us all to speculate about the risks to ourselves and to our families without assurances and support from our own governments?

    …and who defines the biggest chickens and the smaller chickens? Where is the line drawn? I don’t want to figure out some work-around or look over my shoulder for the rest of my life just because I came forward with my name and story. I know my son (and others like him) have very minnowish situations. I want the same justice for all of them – no matter whether they are a big or a little chicken. I want some kind of law that makes sense PERIOD for their — and, of course, others’ protection from the threats of the US slave master. Since the US seems not to care to change to RBT, the only tool that makes sense to me is the Canadian Charter Challenge. To me, it’s a matter of principle and our rights. We should not have to look for a bloody work-around!

  2. @calgary411

    I agree with u… u have no options other then challenge of the charter.. since your son can’t give up his citizenship… people with disabilities should be allowed to claim another citizenship rather be given if they are born in another country. With your name out there… it gives a face to a subject that no one understands.

    CBT is something I don’t think the US will change… its big money maker for them… I asked some of my relatives & people I meet in the US.. not one of them knew what I was talking about when I asked. They all thought the same as we did… don’t live in the US… don’t pay unless made there… So when the gov’t use *tax evader* everyone…. including myself thought of millionaires.. but then I thought about it… if they were in the US & moved after tax money out… how is that evading… taxes been paid already… instead of me using the funds to buy something… I just saved it elsewhere

  3. When people with unresolved OVDI issues can be given a Nexus pass, what’s there to worry about at this point?

    The key here would be to have a tax judgement against you.

  4. …and after we allow them to eat all the big chickens, you’ve given up the principle that they can come for chickens in someone else’s coop! I agree with Calgary411: they need to be barred from snacking here period, and on principle. You can’t come up with a principled reason to allow them to choose what chickens they want to snack on now without risking them raiding the entire coop.

  5. @George III, “There is still the question, can a USA tax claim be used to mess up someone credit rating?”

    Currently in the USA, some local governments are able to sell off local tax liens to investors.

    I think the time is near when the federal government (US) will start packaging up and selling assorted tax liens to “investors” just like banks sell off old written off credit card debt.

    In that scenario I could envision an individuals local credit report facing a negative entry dependent on where that debt ended up.

  6. @WhiteKat, ” I am looking into your suggestion to use an oath of allegiance as a relinquishing act, to be able to truthfully say to my bank ‘No I am not a US person’ when that US inheritance comes through and shines a light on me, but its not looking good so far.”

    First, copy this prayer and remember it, Say it everyday to put matters in perspective;

    God grant me the serenity to accept the things I cannot change; courage to change the things I can; and wisdom to know the difference.

    Second, it sounds like you are not planning on getting a CLN based on your facts and circumstances. Put a file together outlining how you relinquished starting with the US Code section, add in that page from the Congressional Report that says a CLN is not mandatory. Start going on record where you can do it safely and state in writing that you relinquished your US Citizenship gained by birth in the USA. Maybe in a cover letter to a Canadian Passport application. Keep all that in a file. Maybe have an attorney look at your file and ask for an opinion letter if you have in fact relinquished.

    Can a person who has relinquished US Citizenship in accordance with 18 USC but may be undocumented (no CLN) answer NO to “Are you a US Citizen?” I think they can rightfully answer no to that question.

  7. “I think the time is near when the federal government (US) will start packaging up and selling assorted tax liens to “investors” just like banks sell off old written off credit card debt.”
    The Harden Case i previously posted will prevent Canadian court from recognizing USA tax debt any way they package it. Seriously some of you complain about the Americans being ignorant.

    The Canadian Court may recognize a USA court ruling, if it is not related to taxes, but USA tax debt is noncollectable other than the special rule of 1995 Tax Treaty. Why would a company want these debts unless they can collect. The Van Mark case is the last attempt by USA to use Canadian Banks to collect IRS money.
    I have a wiki answer that may need a little follow up.
    http://wiki.answers.com/Q/Will_your_bad_US_credit_history_follow_you_to_Canada
    Will your bad US credit history follow you to Canada?
    In: Credit Reports [Edit categories]
    Answer:
    The poster is not completely right. I’m an American who has moved to Canada. None of my credit history has followed me to Canada. You will basically start from scratch (which is not easy.) It is true that if you’re looking for a large loan (mortgage, for instance), a bank could be persuaded to pull your US history, but for anything else (credit cards, etc.) not only will they not ask for it, but they are usually not interested in getting it. NO bank in Canada (trust me on this) will pull your US history by default.
    http://wiki.answers.com/Q/Will_your_bad_US_credit_history_follow_you_to_Canada
    The question is still, can a USA tax claim that a Canadian court will not recognize effect your credit rating.

  8. @Publius

    We have most definitely been trying to spread the word regarding any facet of this nonsense for over two years now. Perhaps we can all take a look at what we are doing, what we haven’t tried and keep moving forward. It would be so helpful if we could somehow link efforts with those not in Canada.

    I would never “advise” someone to enter the Streamlined program. It is tricky and if for any reason one is denied entry, there is no way to really avoid the IRS insisting on the OVDP (name has apparently been changed back to original; OVDI only refers to the 2011 program). One thing I have heard in the Citizenship Issues Info Sessions is that the law says a taxpayer must file, it does not say one has to enter one of the IRS’ programs. I also have not heard anything to discontinue filing accoding to the 2011-13 Fact Sheet; in fact, the page was last revised on Feb 12, 2014, well beyond the starting date for the Streamlined Program. This certainly suggests that one can still file this way, which is what I did back in Dec 2011, renouncing in Jan 2012.

    For minnows, I really don’t see any reason to summarily dismiss filing according to the FactSheet. Maybe we should start a discussion about this? Comparing OVDP, Streamlined and FS-2011-13.

    I seem to recall seeing somewhere, an IRS report that indicated less than 500,000 FBARs (or 1040s, can’t remember which) were filed for the year in the report (2009?). So that leaves, conservatively, 5.5 million more filers. Let’s say 80% (also a low number) are minnows. That comes to 4,400,000 returns to be filed. Imagine all of those arriving in Austin/Detroit within even a year. How on earth would they be able to process all of them? And spend the time to single out any to levy penalties on? I personally believe the “urban legend” that all the FBARs are sitting in boxes and will rot before anyone gets around to looking at them.

    In spite of the obvious likelihood that people would not feel safe doing it, if 4,400,000 filed returns within a short period, it would be the best protest we could possibly put on.

  9. If they have gotten 500,000 FBAR’s then the compliance is pretty puny. I would have expected that many just from Americans on temporary overseas posting who would normally keep current on all IRS filings etc since they want to go back. 500,000 FBARs likely translates into about half that number of real people – probably less. Separate FBAR’s for each account – chequing, investment etc – it adds up. Even minnows can go over the $10,000 thresshold for a day.

    if people ever DO start sending them in, I’m for doing so in crayon and large scrawl so they have to manually input each and every one….

  10. @George III

    The Treaty was amended by the Third Protocol on March 17, 1995
    Jean Chrétien wa Prime Minister.
    Paul Martin was Finance Minister (Nov 4 1993 – June 2, 2002).

    I do not know what aspects of the Treaty that the Protocol addressed.

  11. @Hazy.

    Thanks! I learned that the Lien is the first of three steps the IRS must take before they try to seize an asset. After the lien comes the issuance of a Notice of Intent to Levy under 26 U.S.C. § 6331(d) and then the actual act of levy under 26 U.S.C. § 6331(a).

    From Wikipedia:

    “The term “levy” in this narrow technical sense denotes an administrative action by the Internal Revenue Service (i.e., without going to court) to seize property to satisfy a tax liability. The levy “includes the power of distraint and seizure by any means.[11] The general rule is that no court permission is required for the IRS to execute a section 6331 levy.

    In other words, the federal tax lien is the government’s statutory right that encumbers property to secure the ultimate payment of a tax. The notice of levy is an IRS notice that the IRS intends to seize property in the near future. The levy is the actual act of seizure of the property.”

  12. @AnonAnon

    There WILL be serious debate about the issue of CBT. Perhaps you have not seen this? Would be great if you could come, as well as any other Brockers whether in GTA or not.

    American Citizens Abroad Global Foundation Organizes 1st Conference to Debate Issues of Citizenship-based Taxation http://tinyurl.com/okz2cqm

    Taxation of #Americans Abroad in 21st Century: Citizenship-Based Taxation vs. Residence-Based Taxation http://tinyurl.com/n7y8js6 Toronto May 2

    Issue Gains Increased Attention as Congress Grapples with Challenges Facing Overseas Americans http://tinyurl.com/kyh8qxk

  13. @Tricia/Nobledreamer
    In going through my files, I found the following: Increasing Rates of FBAR Compliance
    From 2004 to 2009:
    – The number of FBARs filed with the IRS increased 145% from 217,699 to 534,043
    – FBAR-related examination increased 96% from 334 to 656
    – FBAR penalty assessments increased from $4.2 million to $20.5 million

    @ Anne Frank @ Tricia @All
    Even if FBARs for previous years were sitting in boxes (I know of five people including myself whose FBARs were alive and well sitting in the hands of IRS agents), as of the 2013 tax year, ALL FBARs HAVE to be filed electronically, exposing those of us who are 100% compliant to three possibilities of hacking and identity fraud: (1. Canadian Banks to CRA, 2. CRA to IRS and 3. Individuals to FinCEN (at least we know that our figures are correct down to the last cent).
    No mention in the IGA of protecting Canadians who are compliant with the obscene US CBT – hoping that this category of Canadians with US connections will be included in the Charter Challenge…..

  14. @ Anne Frank
    “If people ever DO start sending them in, I’m for doing so in crayon and large scrawl so they have to manually input each and every one….”
    They’ve got that covered by mandatory e-filing of FBARs — even if your computer isn’t compatible with their system, even if you don’t have a computer, even if your area doesn’t have internet service. If something is onerous or even impossible you can be sure the IRS will demand it.

  15. I am a Canadian citizen and former US citizen. If, in the unlikely (?) event that I were to be detained in the US under Ne Exeat Republica for failure to pay filing penalties (not taxes) that the IRS might decide I owed them, could I trust the Canadian government to assist me in returning home without paying such penalties? In the case of the current Canadian government, I very much doubt it. Can anyone believe the Harper government will make a statement of public policy clarifying that question and related issues, when they are already hiding the IGA and its implementation legislation?

  16. @ Anne Boleyn
    That’s a heckuva lot of e-exposure, isn’t it. I like how you summarized it. Every e-step increases the risk of miscreant abuse or a hack attack. There’s one more possibility to add — IRS to any alphabet agency who wants to know.

  18. The idea of the USA being able to claim payment from a Canadian on “taxes” owed to them is clear. It appears they cannot. however, the IRS will make you a criminal and this will not be a “tax” issue. When you become a criminal and a fugitive living in Canada, what then? This is my worry. With the government games being played here, What protection is offered for “criminals” trying to avoid the US government in Canada? This would likely be the next IRS ploy to get the money they want from you. Fatca is not for nothing, it is for financial gain. I highly doubt, if the USA makes the 30% threat to enforce it, they will simply accept an IOU from a Canadian hiding behind a border…..

  19. @Tricia/nobledreamer,

    Thank you for reminding me about the conference in Toronto on May 2. I wasn’t planning to go, because I am no longer a US citizen, having relinquished US citizenship long ago. I don’t think I have much to contribute toward convincing the US to change from CBT to RBT.

    My beef is with our Canadian government and its failure to protect former citizens and dual citizens from the predatory effects of US CBT tax laws and penalties. From what I can see, the conference program doesn’t involve any participation from representatives of the Canadian government, to whom I might be able to direct questions.

  20. @AnonAnon

    I quite understand your feeling. The idea is that we have a “Brockfest!”

    Remember when you wanted to have a celebration party a while back? We usually come together at the Info Sessions or something like this.

  21. @NativeCanadian –

    I agree with you. Of what use is the Canadian government’s assurance that it will not collect taxes on behalf of the IRS, if the IRS tries to collect penalties or pursue criminal charges against Canadian citizens or permanent residents instead?

  22. @Tricia/ nobledreamer,

    I still don’t think it would be useful of me or to me to attend the entire conference, but I could show up to meet some Brockers for lunch, if you can let me know where and when. In the St. Michael’s College cafeteria between noon and 1pm?

  23. @Once u are listed as a criminal… even hiding in Canada will do you no good… they will turn u over… in a heart beat… Here is something I didn’t know… if u are a criminal… crossing any border that has some sort of treaty with the US… u will be arrested & held until they pick u up… If u are a chinese citizen… hiding in China.. They can’t get u… but then.. u can never leave China unless u want to be arrested… I think if u even travel to Hong Kong… which is right next door… I think u can be arrested.

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