Liberty and justice for all United States persons abroad

The Isaac Brock Society

Category Archives: Issues regarding US persons abroad

Drones on the Canadian border

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U.S. suggests drones, underground sensors to beef up surveillance along Canadian border

Here is the interesting bit:

The Canada Border Services Agency said it was in both countries’ interest for the border to remain “open, efficient and secure.”

“From our huge trade relationship to our common security concerns, we will continue to work together to keep the border open to legitimate trade and travel but closed to terrorists, criminals and other threats,” it said in a statement.

I wonder what other threats might be.  From the American perspective, it could only mean the threat of expat tax evaders trying to go to and fro on the border without settling with the IRS.  My house is a few kilometres from the border.  I wonder what the range of the missiles on the drones is and what sort of destructive capacity they have.

 

Interesting article about the Constitutionality of the Exit Tax

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http://www.americanbar.org/groups/taxation/publications/tax_lawyer_home/ttl-win12-berg.html

This article is pay-walled to members of the American Bar Association but it does seem to have a rather interesting premise. I also note the author appears to pick a fight with  IBS Wall of Shame member Bruce Ackermann of Yale University. If anyone gets access to this article it might be something interesting to look it.

Chinese companies pulling out of U.S. stock markets amid accusations, complaints

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http://www.thestar.com/business/article/1241600–chinese-companies-pulling-out-of-u-s-stock-markets-amid-accusations-complaints

Hi folks. I know I haven’t posted anything in quite a while. It’s been a busy time at work over the summer but I’ve been to the site off and on.

Anyway, I thought you all might find this interesting. Could this be a sign of things to come? Do you think companies in other countries could follow suit? Note the paragraph stating:

“Some Chinese companies say they are pulling out of U.S. markets because a low share price fails to reflect the strength of their business. Withdrawing also eliminates the cost of complying with American financial reporting rules.”

Both our forefathers were slaves: When is a comparison correct and when isn’t it?

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Precious angel, you believe me when I say,
What God has given to us no man can take away.
We are covered in blood girl, you know both our forefathers were slaves.
Let us hope they’ve found mercy in their bone-filled graves.
Bob Dylan

From the Library of Congress

Petros, a visible Asian minority whose grandparents fled Japanese oppression of Korea, asked Recalcitrant Expat, a visible African minority whose ancestors suffered as slaves in the United States, to discuss the legitimacy of making comparisons between the plight of U.S. expats today with past atrocities.  This is in the aftermath of the posting of a Hitler spoof video which compared FATCA’s rounding up of U.S. citizens for taxation and FBAR fines to how Hitler rounded up the Jews for extermination in camps.  This post is a result of their common reflexions.

Continue reading →

A Stupid — At Least Unfair — IRS OVDI/OVDP Trick; Denying Overpayment Credit for Barred Years

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Jack Townsend is well known as a measured, serious, non hyperbolic Law Professor who has an excellant blog called Federal Tax Crimes.  His analysis of court cases and his tireless fielding of questions, have helped me (and many other minnows) know more about tax law and the OVDP / OVDI processes then I have ever imagined possible.  He discourages polemics, but has provided outlets for Open Forum recommendations to the IRS.

So, when you see a heading of a blog post like this one above, and he starts out like this:

“I write to rant about a practice inside the OVDI/OVDP civil penalty structure.”

and goes on to say,

My argument to that is the same as Vinny’s responsive argument in My Cousin Vinny, here, paraphrased, “That’s bullshit.”

You SHOULD pay attention, and frankly so should the IRS.  🙂 I encourage you to go read this post for yourselves. 

 

 

Former Canadian MP and head of the OECD says Daniel J. Mitchell is really bad guy

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Remarks from Donald Johnston below:

I should tell you that the OECD began the program with a misnomer, calling it “harmful tax competition”, which, as I recall, was the language actually used in the résumé from the G-7 at the Lyon summit. They used the term “harmful tax competition”.

 

    Well of course that opened the door to those who like to charge the OECD as being a European-controlled organization where people like to pay a lot of tax, where the social contract is financed with taxpayers’ dollars at exorbitant rates. They like to charge that the OECD—when it refers to tax competition—is really saying that everybody should pay the same tax. Well of course nothing could be further from the truth. I don’t know if Jeffrey Owens testified on this point or not, but the OECD, from an economic point of view, had regarded competitive tax rates as being very healthy and that they could be very efficient. So the notion of competition in tax, which backfired in terms of the initial communications on this program, was corrected in 2000 and it became essentially “harmful tax practices”.

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Interesting CDN Govt Travel Expense Reports for visits to IRS and OECD

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I thought it might interesting to go through the Government of Canada Travel Expense reports and see WHOM and how often do various Canadian Government officials deal with the US Treasury Department and Internal Revenue Service.

How are some of the more interesting travel logs:

Terrance McCauley Assistant Commissioner Compliance CRA visit to IRS National Office Washington, DC May 7th 2012

http://www.cra-arc.gc.ca/gncy/xpnss/mcauley2/2012/q2/3265t1-eng.html

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Yet another list of employees turned over by HSBC, lawsuit filed against Swiss Federal Council

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According to an HSBC internal source, employees received an email last Thursday that mentioned a second transmission of employee data:

http://www.rts.ch/info/suisse/4194901-une-nouvelle-liste-d-employes-de-banque-transmise-aux-etats-unis.html

 

In the meantime, Douglas Hornung, lawyer for bank employees, has sued the Federal Council (President and Cabinet):

http://www.rts.ch/info/suisse/4193502-plainte-penale-contre-le-conseil-federal-dans-l-affaire-des-donnees-bancaires.html

 

Tim Walberg’s inflation-indexing tax reform plan offers very limited relief to U.S. Persons abroad

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Expat homeowners will see some benefit; expats with other local assets won’t

A couple of weeks ago, Timothy Walberg (R-MI) introduced H.R. 6225, a short series of tax code amendments to “provide for economic growth and personal financial liberty”. Its full text is finally available. Right before the summer recess, Congresscritters introduce all sorts of tax legislation for the purpose of grandstanding and campaigning rather than actual lawmaking. Walberg’s bill is more of the same, but at least it contains the kernel of a nice idea: indexing individual taxpayers’ basis in certain assets to the cost-of-living adjustment.

The significance of Walberg’s plan is that when people sell their assets and pay capital gains tax, they’d only be paying tax on the amount that actually reflects an increase in the value of the asset, as opposed to the decrease in the value of the U.S. dollar — unless that asset is an ETF, a mutual fund, or a business you formed in the country where you actually live, in which case you’re clearly an Evil Tax-Evading Traitor who doesn’t deserve the benefits of “personal financial liberty”. Continue reading →