Category Archives: Issues regarding US persons abroad

FATCA IGA Legislation Trial at Canada’s Federal Court of Appeal — Court files now say: “Order dated 10-DEC-2021 rendered by Chief Justice Noël Matter considered without personal appearance The Court’s decision is with regard to the hearing scheduled for 13-DEC-2021 in Vancouver Result: adjourned to a date to be fixed by the Judicial Administrator at the earliest convenience of the parties…”

As this last day of covid calendar year two crawls through its final hour, this new article outlines collateral damage on the renunciation front. Sauve qui peut!

https://www.theguardian.com/us-news/2021/dec/31/americans-seeking-renounce-citizenship-stuck

Circa December 24, 2011 Breaking News: In anticipation of #FATCA, Santa Claus arrested as part of Obama #FBARFundraiser https://t.co/5hqKrFYXtx

— U.S. Citizen Abroad (@USCitizenAbroad) December 24, 2021

Over the last ten years, the Isaac Brock Society has been a source of research and education. It has also been a source of news reporting:

“Reporting On What The Mainstream Media Would Never Have The Courage To Report”

For example …

On December 24, 2011 Brock (per Petros) was the first to report the arrest of Santa Claus along with the shocking accusation of Santa’s possible US citizenship.

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A Tenth Anniversary

People often overestimate what they can achieve in one year and underestimate what they can achieve in ten years!

From @HelenBurggraf 2016: Isaac Brock Society: Blog of Canadian 'Accidental Americans' becomes global info resource https://t.co/ZZMQObwGmX

— U.S. Citizen Abroad (@USCitizenAbroad) December 18, 2021

The Isaac Brock Society was launched in December of 20211 on wordpress.com. In early December 2011 I received an invitation from Petros (one of the original founders of Brock) to participate as an author. My first post was on December 12, 2011. That first post was the first in more than 500 more original posts and (I am guessing) thousands of comments. Brock was formed after the summer of 2011 which was a particularly significant period of US hostilities toward Americans abroad. This hostility was facilitated in equal parts by:

– the media (delivering messages from the IRS and compliance industry)
– the IRS (conflating resident Americans with Americans abroad)
– the cross border compliance industry (pressuring long term Americans abroad to enter the OVDI/OVDP programs)

The Summer of 2011 And The World Which Spawned Brock

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THREE DAYS to FATCA IGA Legislation Trial at Canada’s Federal Court of Appeal

THE DECEMBER 13 TRIAL WAS DELAYED AND WE HOPE THAT IT WILL BE RESCHEDULED IN (EARLY) 2022.  The title of the Appeal Court litigation is DEEGAN ET AL. v. ATTORNEY GENERAL OF CANADA ET AL. and Court file number is A-370-19.

Australia Treasury is seeking submissions from stakeholders on Australia’s Tax Treaties.  Deadline 31 October.  More details at:

Fix the Tax Treaty:  Treasury Tax Treaty Consultation

Fix the Tax Treaty:  Treasury Submission

The Australia Treasury site;

and in this article by Helen Burggraf in AmericanExpatFinance.

Thanks, JC, for informing us of this.

Fabien Lehagre, founder of l’Association des’Américains Accidentels/ the Association of Accidental Americans is instituting a lawsuit, aiming to force the State Department to reopen the services of the US Embassy that handle renunciation / relinquishment requests.
The lawsuit’s purposes are:

➡️ Because this action will allow us to publicize the fact that the State Department is depriving tens of thousands of people of a fundamental right.

➡️ Because this action will allow us to make the link with our first complaint which aims to make it free to obtain a certificate of loss of nationality.

➡️ Because this action will allow us to shed light on the reasons why tens of thousands of citizens who have American nationality want to renounce American nationality: discrimination induced by FATCA, impact of Citizenship Based Taxation, difficulty in investing as a US Citizen.

➡️ Because the fees necessary to finance this litigation are very low compared to the real cost of a lawsuit in the United States.

PLEDGE SUPPORT and/or CONTACT Fabien for further information at this link!

EndFATCA is fighting to end FATCA and discrimination against EU/US duals citizens and US citizens in Europe, as well as remove barriers to renunciation.

They have previously submitted a petition and appeared several times before the EU Parliament in the past five years.  They are now presenting a supplemental petition to the European Parliament on September 2nd.  Any resident of the EU, or any person with EU citizenship who resides anywhere in the world, can sign the petition.   Please add your support!    (You can also read about the Petition on the EU Parliament’s wehsite: Petition No 0323/2021)

The 13 requests in the Petition are also briefly described at this link

As well as Europeans, EndFATCA’s website is of interest and use to US persons and FATCA fighters around the world, as it also includes access to 1300 supporting documents and a list of all important initiatives around the world against FATCA.

The Institute of Tax Law at Queen Mary University’s Centre for Commercial Law Studies in London, UK, will host a panel discussion, via Zoom, on the topic of “the Taxation of Expatriate and Cross-Border Individuals,” featuring a number of experts on the subject, including QMUL’s Senior Lecturer (Associate Professor) in International Tax Law, Bernard Schneider, Edoardo Traversa, a tax and European law criminology professor at Belgium’s Université Catholique de Louvain, as well as three of SEAT’s co-founders: John Richardson, Karen Alpert and Laura Snyder.

The Discussion will be June 29th, 4 to 6 pm British Summer Time (5 to 7pm Central European Summer Time, 11am to 1 pm Eastern Daylight Savings Time). This online discussion is free and open to all. Registration is required. Full information at Stop Extraterritorial American Taxation (SEAT).

Excellent podcast today, in which Peter Paulsen interviews international tax lawyer John Richardson on “The Challenges Faced by [Americans Abroad] and the Prospects for Change.”  John explains the various interlocking reasons why the difficulties of US citizens abroad worsened critically with FATCA, and gives specifics of the problems facing US citizens abroad as a result.

This following statement, regarding the Isaac Brock Society, really stuck me because it reminded me of how each of us, by adding pieces of information, not to mention some very serious original research, have built a really big and useful repository.  I want to thank everyone who’s contributed to the site — even if you only made one comment, that may have been a very useful addition to the compendium.

“To this date, there is no site that contains the volume of research, the sort of meticulousness of discussion on these issues . . .  .  And so, it has been a very, very good source of education … comfort .. meeting place .. for people whose lives have been turned up and down by these issues.”

Isaac Brock Society is mentioned between approximately 22.30 and 25.00.

BUT this podcast is really worth a full listen – concisely and clearly covers the egregious situation as it  is in May 2021.