72 thoughts on “Toronto May 2 Citizenship Based Taxation Forum live comments”
US citizenship is NOT voluntary for my son, Mr. Kirsch. Thanks, Petros!
Debate moderated by John Richardson: surprised at the amount of agreement between Kirsch and Schneider.
Schneider. Taxes should not be the tail that wags the citizenship dog.
Kirsch is embarrassed by the US sending a bill to those evacuated.
Petros: The presence of Murray Rankin, who is the Official Opposition’s Revenue Critic is significant. Has he asked any questions or made any comments yet?
Kirsch if every country adopted CBT that would complicate things. Laughter.
@petros
Schneider. What is the cost? The citiZenship penalty, on income, destroys retirement planning, foreign exchange penalizes phantom gains. Compliance costs, intrusive reporting obligations, limitations on banking and investment.
Thanks for mentioning this. My $78K FBAR fine from 2009 OVDP was increased by almost one third due to foreign exchange rates prior to the 2008 crash.
Wish I could have attended, but still too ill. My non-American husband is there, still fuming that he had to send all his Canadian returns to the IRS (because of our joint accounts). Hopefully someone will address the plight of the non-US spouses.
@ Anne Boleyn
I think Senator Hervieux-Payette may have mentioned your truly outrageous penalties at the Senate hearings on April 30th. Unfortunately she muddled things a bit. Hope you’re feeling well soon and glad your husband is able to attend the great debate. I am so looking forward to seeing a video of this.
Rankin hasn’t ask question. We had short break, and now Phil Hodgen will speak.
Phil fixes problems of citizen abroad including expatriations. Phil wants to talk about the concrete problems as opposed to CBT in the abstract.
International tax too. difficult to u derstand to expensive to satisfy
Americans abroad do not know the rules, make mistakes.
Irs only knows the hammar.
Hodgen
Forms
8621 mutual fund confiscatory.
3520, 3520-a. Normal estate planning with a trust (you are presumed to be tax evader)
5471 Foreign Corporation, 10,000 fine for not filing
FinCen 114, Form 8938. FBAR
RRSP treaty protected, IRS requires private letter ruling, phil has secret solution
De optimize
no mutual funds, stick to stocks , bonds, cas
deemphasize retirement savings
Don’t own a business
Hodgen still
OVDI almost always a bad idea. Ignore those who use fear aw a marketing device. OVDI always more expensive than going through a normal of penalties.
ignore IRS anti-marketing about fixing problems the normal way.
Clean up mess because the USA is very well armed.
Hodgen does a lot of quiet disclosures. Lawyers want you OVDP because it minimizes their liability risk.
Rrsp leaving you Rrsp of the form is a treaty election. A win by omission. Just comply going forward 8971.
Hodgen still
Expatriation why:
Risk isn’t worth it
Estate taxes
income tax
Shouldn’t that be form 8891?
Phil Hodgen would cost a car to fix problems of a normal teacher. Go to a normal accountant for 4k. Joe Green question.
Hodgen File FBAR s just do it if under a million
In regard to the RRSP, is Hodgen’s suggestion to just begin filing 8891 forms, and not filling past few years 8891s with 1040x amends?
Expatriates receive US inheritances wired to their accounts.
@Husky apparently, previous omission should be considered a treaty election. So yes
Kuenzi, the real cost of CBT is born by Middle Class American families
CBT does not catch the super wealthy but middle class. Standard diversified investing does not work for Americans abroad, particularly outside of CDN and UK, which have treaties for retirement accounts.
Kuenzi, Foreign Life insurance does not qualify for tax deferral.
US citizenship is NOT voluntary for my son, Mr. Kirsch. Thanks, Petros!
Debate moderated by John Richardson: surprised at the amount of agreement between Kirsch and Schneider.
Schneider. Taxes should not be the tail that wags the citizenship dog.
Kirsch is embarrassed by the US sending a bill to those evacuated.
Petros: The presence of Murray Rankin, who is the Official Opposition’s Revenue Critic is significant. Has he asked any questions or made any comments yet?
Kirsch if every country adopted CBT that would complicate things. Laughter.
@petros
Schneider. What is the cost? The citiZenship penalty, on income, destroys retirement planning, foreign exchange penalizes phantom gains. Compliance costs, intrusive reporting obligations, limitations on banking and investment.
Thanks for mentioning this. My $78K FBAR fine from 2009 OVDP was increased by almost one third due to foreign exchange rates prior to the 2008 crash.
Wish I could have attended, but still too ill. My non-American husband is there, still fuming that he had to send all his Canadian returns to the IRS (because of our joint accounts). Hopefully someone will address the plight of the non-US spouses.
@ Anne Boleyn
I think Senator Hervieux-Payette may have mentioned your truly outrageous penalties at the Senate hearings on April 30th. Unfortunately she muddled things a bit. Hope you’re feeling well soon and glad your husband is able to attend the great debate. I am so looking forward to seeing a video of this.
Rankin hasn’t ask question. We had short break, and now Phil Hodgen will speak.
Phil fixes problems of citizen abroad including expatriations. Phil wants to talk about the concrete problems as opposed to CBT in the abstract.
International tax too. difficult to u derstand to expensive to satisfy
Americans abroad do not know the rules, make mistakes.
Irs only knows the hammar.
Hodgen
Forms
8621 mutual fund confiscatory.
3520, 3520-a. Normal estate planning with a trust (you are presumed to be tax evader)
5471 Foreign Corporation, 10,000 fine for not filing
FinCen 114, Form 8938. FBAR
RRSP treaty protected, IRS requires private letter ruling, phil has secret solution
De optimize
no mutual funds, stick to stocks , bonds, cas
deemphasize retirement savings
Don’t own a business
Hodgen still
OVDI almost always a bad idea. Ignore those who use fear aw a marketing device. OVDI always more expensive than going through a normal of penalties.
ignore IRS anti-marketing about fixing problems the normal way.
Clean up mess because the USA is very well armed.
Hodgen does a lot of quiet disclosures. Lawyers want you OVDP because it minimizes their liability risk.
Rrsp leaving you Rrsp of the form is a treaty election. A win by omission. Just comply going forward 8971.
Hodgen still
Expatriation why:
Risk isn’t worth it
Estate taxes
income tax
Shouldn’t that be form 8891?
Phil Hodgen would cost a car to fix problems of a normal teacher. Go to a normal accountant for 4k. Joe Green question.
Hodgen File FBAR s just do it if under a million
In regard to the RRSP, is Hodgen’s suggestion to just begin filing 8891 forms, and not filling past few years 8891s with 1040x amends?
Expatriates receive US inheritances wired to their accounts.
@Husky apparently, previous omission should be considered a treaty election. So yes
Kuenzi, the real cost of CBT is born by Middle Class American families
CBT does not catch the super wealthy but middle class. Standard diversified investing does not work for Americans abroad, particularly outside of CDN and UK, which have treaties for retirement accounts.
Kuenzi, Foreign Life insurance does not qualify for tax deferral.