Author Archives: Petros

Have a peak at this screen shot from the ING Direct (France) website:

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Jet Li is easily the fourth most famous recent renunciant of US citizenship, after Eduardo Saverin, Denise Rich, and Superman. Details regarding his reasons and motives are scarce.  But I doubt that anyone should be surprised or dismayed by Li’s choice to expatriate.  He must be fabulously wealthy.  Does his renunciation make him “despicable“. Did the United States make Jet Li a great actor and martial artist?  Does he owe the United States perpetual allegiance?

Perhaps a little effort to understand is in order.

Last weekend, I watched the film Fearless  in the original Mandarin with English subtitles. Jet Li plays the part of Huo Yuanjia, the historical founder of Jinwu Sports Federation.  Early in the film, after the Huo Yuanjia wins a match, he celebrates with his friend and financier, Nong Jinsun.  They are drinking from tea cups and Huo makes a face and says:

Huo: This tastes terrible.

Nong:  It’s coffee. It comes from the West. It’s robust. Our country has grown very weak now. We are living in dangerous times. We need to regain our power and our strength. We have to learn from them, learn from the West. Otherwise, I am afraid our country shall continue its course. Continue reading →

The following response to the Isaac Brock Society appeared in a comment.

I am with the CBA and we have been following your discussion.  We certainly understand the concerns that you have with FATCA. However, you seem to be under the impression that Canadian banks are planning to willingly go along with the FATCA requirements and this is certainly not the case. In fact, the Canadian banking industry agrees with your concerns and we have been and will continue to fight to change the extraterritorial reach of FATCA and lessen the impact it will have on Canadian banks and their customers.

We have information on our stance on FATCA on our website:
http://cba.ca/en/research-and-advocacy/47-regulatory-enviornment/598-foreign-account-tax-compliance-act–

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The following article (pdf) appeared in the July 9 (2012) edition of Tax Notes.  It is reproduced here with the express permission of the author.

Tax Justice For Americans Abroad, by Steven J. Mopsick.

Here is the link to the CBC Radio (New Brunswick) of the interview with Profs. Russ Hunt and Marie Cashion:

CBC Radio:  Dual Citizens

They have asked for feedback:

infoam [at] fredericton [dot] cbc [dot] ca ; or talk back at 1-800-561-4222 (I don’t know if this number works outside of NB).

Those of you who are not on the USTAX [at] stu [dot] ca listsrv that Russ Hunt is operating will not have received the following message:

I’ve added some information to my US Tax Web site about the recent announcement from the IRS announcement that it intends “to help dual citizens residing in Canada deal with their US tax filing obligations” and to “offer assistance to those with Canadian retirement plans.”

I was prompted to do a bit of research and add it to the site by the news that the IRS initiative had been “welcomed” by Jim Flaherty, and by a request to do an interview with the local CBC Information Morning show. Marie Cashion and I will be on at 7:15 tomorrow morning. If you’ve up at that hour on a holiday weekend, congratulations; you can hear it on line at http://cbc.ca/nb ; if not, sometimes interviews are posted on the Web site. In any case, my expectation is that it will be much more useful to have a look at my site:

http://people.stu.ca/~hunt/ustaxinfo/

— Russ

Steven J. Mopsick, 30 year IRS vet, commented on the procedures announced by the IRS 26 June 2012:

NEW FILING PROCEDURE
FOR AMERICANS ABROAD: TOO LITTLE BUT NOT TOO LATE

On June 26, 2012, the IRS announced a new filing compliance procedure for non-resident U.S taxpayers. The procedure provides that current non-residents including dual citizens, who have not filed U.S. income tax and information returns, may file three years of delinquent tax returns and six years of delinquent FBAR’s without fear of IRS punishment.  Provided the delinquent returns are (a)“simple returns,” (b) the IRS determines that the taxpayer’s package presents a “low level of compliance risk” (c) and the returns show less than $1,500 of tax due for each year, the taxpayer can expect an expedited review process possibly resulting in no assertion of penalties or further follow up procedures.  The notice makes it clear that this new procedure is not a substitute for a voluntary disclosure nor the more formal OVDI 27.5% tribute program and that if a taxpayer has a well-founded  worry about the risk of criminal prosecution he better consult a lawyer.

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A reader posted a comment with this article:

Free Advice to My Schoolmate Barack Obama: Want to Grow Exports and Create More Jobs? Don’t Tax Americans Abroad

Dr. Saud Al-Ammari is Managing Partner, Saudi Arabia & Gulf Region, Blake, Cassels & Graydon LLP, Al Khobar, Kingdom of Saudi Arabia. He has experience in a wide variety of corporate and commercial matters inside and outside the Kingdom. He served for ten years as special counsel and later general attorney for Saudi Aramco. Dr. Saud participated as legal counsel and a member of the team negotiating the Kingom’s accession to the World Trade Organization and served as chairman of OPEC’s legal defense team.

Here is a salient point:

The unintended consequences of taxing expatriate Americans by the US Government is that fewer of them seek employment overseas, and even fewer are hired by global firms. With fewer proponents of American goods and services who can influence buying decisions, there are fewer exports made by domestic companies, and in turn, fewer jobs in America. Ultimately, the US Treasury collects less overall revenue and America has a less competitive economy.

Thus Dr. Al Ammari agrees 100% with Roger Conklin.