Author Archives: Petros

Here is a list of international Certifying Acceptance Agents for the IRS.  In particular the IRS site mentions some of the big FATCA compliance firms:

National / International CPA Firms *

Deloitte and Touche, LLP
Ernst & Young LLP
KPMG LLP
PricewaterhouseCoopers LLP
BDO

For a list of Canadian IRS agents, see this list.

Comment: The IRS agents in our midst are operating an illegitimate business

No free country in the world actually allows the agents of the revenue service of a foreign country operate within its borders. To do so would be to admit the loss of sovereignty. But certifying agents of the IRS are doing work for the IRS.

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Here is a correspondance between “the knower” and me in the comment section of the Financial Post article, Canadian government faces constitutional challenge over FATCA deal. Perhaps “the knower” just needs to hear more about what’s really going on. I think that’s true of most Canadians. Once they understand what’s going on and that we are not making this stuff up, they’ll be on our side.

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One of the commonest responses by those who have never studied the issue of US personhood is,”If you don’t want to pay your taxes, then renounce your citizenship.” Well, just off the top of my head here are some reasons that people may be reluctant to renounce United States citizenship: Continue reading →

I reproduce the late honourable Jim Flaherty’s letter to the editors of major US papers from September 2011. My comments will be indented and in italic type:

Canada and the United States are neighbours and have long been the closest of friends. We share a common border and we share many common values.

In other words, the United States has jeopardized the friendship by threatening FATCA’s economic sanctions against Canada, an ally and a friend. We have seen that some leaders in the USA think that the USA should use FATCA sanctions against Russia in the recent dispute over Ukraine. Flaherty recognized already that FATCA was economic warfare against an ally.

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Statement of Claim against the Canadian Attorney General of Canada

This is a great text. Everyone in Canada should read it.

At one time Jack Townsend seemed to be sympathetic to the plight of innocent so-called Americans abroad. Lately, however, he seems to have forgotten that we even exist:

U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator (8/7/14)

He gets right down moralistic in this post. I think lawyers are better arguing law than they are morals–but because there is sometimes a relationship between law and morals, I suppose he feels qualified to make moral statements:

Of course, the human race is communal.  If not, we would not have a human race today.  Throughout most of our history, wealth was transparent to the community — maybe not in the sense of finite bottom-line net worth, but the trappings of wealth were physical.  We knew who the guys with wealth were and, in a sense, we knew how wealthy they were.  And we could assess the community’s coherence and bonding by how people contributed to the community and were rewarded for doing so.  With secret financial institutions for hiding wealth, we lose that ability to assess and, as a community, demand what is best for the community.

So, as readers who have read this far, will know.  I think transparency is a good thing.  FATCA is a good thing.  And the global initiatives it and the U,S. spotlight on tax havens have spawned are good things.

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From Bloomberg News, Russia Eyes Banning U.S. Chicken And Some European Fruit. But that is not all. They plan to ban the FATCA compliance industry as well:

In a separate development, Russia’s lower house of parliament, or Duma, may consider legislation to target companies in nations that impose sanctions against Russian citizens or businesses, according to Russian lawmaker Evgeny Fedorov.

The proposal would bar audit and consulting firms from nations defined as “country-aggressor” from working in Russia. If enacted, the law would cover Deloitte, KPMG, Ernst & Young LLP, PricewaterhouseCoopers LLP, Boston Consulting Group Inc. and McKinsey & Co., Fedorov said in a telephone interview today.

I’d love to see this in Canada too.  It is time to get the IRS tax collectors out of Canada. They have no business here. Now Russia, thanks to retaliatory measures against Obama’s increased sanctions, will do what no one seems to realize is the only logical thing to do: deport the US tax compliance industry.

It is also important to note that FATCA’s requirements are the same for all American taxpayers—expats are treated no differently. All citizens are required to comply with United States’ tax laws and FATCA is a tool to enforce them. Tax evaders should rightly worry that FATCA will reveal their illicit activities.

Mark J. Marzur, Assistant Secretary for tax policy, United States Treasury Department (emphasis mine)

FATCA hunts down “US taxpayers” as defined by US law, considers their legal activities in Canada carried out as Canadian citizens as illicit, and then tells these “US persons” that they should be rightly worried about their “illicit” activities. No, Mr. Assistant Secretary: You don’t have clue. You must go back to school and study international law: (1) The Master Nationality Rule says that every country has the right to consider their resident citizens as only their citizens and not the citizens of any other country; (2) the Dominant Nationalty Rule says that a so-called dual citizen has the right to protection of the country with which they they have the most ties; and (3) The Rule of State Nonresponsibility that a state has no right to protect a citizen–or steal from them–if they are currently inside a country in which they have citizenship. FATCA conforms to none of the international rules of dual citizenship.

By completely disregarding the international doctrines of dual citizenship,  the United States is a rogue nation, forcing other countries to “out” instead of protecting their own citizens.

The above statement of the Assistant Secretary raises a serious moral issue. If US Treasury wishes to ignore international law, then it is the United States which is involved in the illicit activity, not innocent Canadians who live in Canada and carry out their activities under the protection of the Canadian government (or the citizens of any other country for that matter). The immoral SOBs are not the accidental Americans–people whose only failure was birth in the United States–but the United States for taxing them.

The end result of immoral activity by the United States is war. We now see wars around the globe that the United States has instigated: Syria, Libya, Iraq, Egypt, Ukraine, and Israel/Palestine. The US is funding terrorists and neo-nazis in these various countries and it is causing instability, war, and death. FATCA is an extension within the financial realm of US imperial policy. It is financial terrorism: Financial American Terrorism Contra All.

Obama: Companies that avoid taxes are renouncing citizenship

President Barack Obama plans to go on the offensive later Thursday against companies that use cross-border mergers to avoid U.S. taxes, accusing them of essentially renouncing their American citizenship to shield profits. Bloomberg reports Obama will say in Los Angeles that companies using so-called inversions benefit from the economic advantages of being in the U.S. while adding to the tax burden of middle-class families. Democrats have called for action to stop inversions but analysts say near-term chances of legislation being enacted are very low.

Renouncing citizenship would appear to be a heinous crime, similar to treason. One such criminal, Peter Dunn, also appeared in a MarketWatch article by Al Lewis:

Tax man makes it hard to be an American, Commentary: Tough IRS rules hit the little guys hard

I feel honoured to be in a special class of criminal merely for exercising my universal and fundamental right to change my nationality.

Zerohedge offers US expats a new strategy for filing:

Just remember, the US courts have decided on the basis of the Required Records Doctrine that you can’t plead the 5th Amendment with regard to the FBAR. Of course, FATCA obliterates your 4th Amendment and Canadian Charter Rights as well. Could this be hypocrisy?