Liberty and justice for all United States persons abroad

The Isaac Brock Society

Category Archives: Issues regarding US persons abroad

Us and Them

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The “us” at Brock are all individuals who have suffered the impact, directly or indirectly, of the peculiar United States attitude toward its own nonresident nonaliens, and especially the perverse contortions of that attitude since 9/11.

That is going only by the Brock tag line. We attract some resident aliens, and various others as well.

The main “them” is the unsympathetic homelanders, above all those with power: the ones who manufacture a morass of so-called law; and the ones who enforce it, through taxation — the IRS, and through citizenship — Dept. of State.

A big part of our special agony is self-division. Each of us is also them, even after concluding the formalities of severing citizenship and filing the final paper. For those who stop short of that clear divorce, the duality is likely to fester, and to become ever more agonizing in times that will not even be “semi good.”
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Are you the same person you were one year ago? How has the last year affected your life?

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In January the Isaac Brock Society commented on the question: Has your life been stolen from you by the IRS? That post generated a lot of comments. We are now one year into the IRS attack on U.S. citizens abroad.

In my post, directed to Joe Green, I commented that:

I venture to say that many U.S. citizens abroad are not even the same people they were a year ago.

Marketpinetree left the following comment:

Markpinetree

*This applies to me: ” I venture to say that many U.S. citizens abroad are not even the same people they were a year ago.” My life is now a nightmare and I still don´t know what I can/should do to regain some peace and a full night´s sleep. It started in 2009 when, by chance I learned abour FBARs and from that time on it has become more and more disturbed affecting me, my family and my work.

In what way(s) has your experience with the IRS changed the kind of person you are? Do your friends recognize you?

 

 

 

 

Here’s more: Democratic Gov. O’Malley (Md): Romney ‘bet against America’ with offshore holdings

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Here is another one in what is clearly a coordinated attack. There are no comments yet on this, so those who are inclined should get over there.

 

 

 

 

 

 

Gibbs, Democrats hit Romney over offshore bank accounts

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The Hill has a video and story up this morning regarding Romney’s offshore accounts. It provides a good opportunity to comment to a readership that is in DC about what you think about this “offshore issue” and FATCA. I posted a lengthy comment, but is now in under review.

Note: You can edit once you post, and that is what I was doing that sent it into moderation. The first post ran all together without paragraph breaks. I think it is the second edit for a spelling error that prompted the review, so be careful.

Here is the link Continue reading →

Breaking news: Generalissimo Francisco Franco is still dead. And Reuters just noticed Denise Rich’s 2011 renunciation.

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Lynnley Browning (Twitter: @LynnleyBrowning) brings us the two-and-a-half-month old news that songwriter Denise Rich, the ex-wife of Marc Rich, had her name published in the Federal Register back in April due to her renunciation of U.S. citizenship in November 2011. Her editors at Reuters seem to have decided that a neutral statement of the aforesaid fact wasn’t good enough for the headline, so they pushed it out over the wires it as the inflammatory “Socialite Denise Rich dumps U.S. passport”. The story has also been picked up by HuffPost and MSNBC.

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While Obama uses drones to kill people in South Asia as example of U.S. power, Romney builds companies to feed people in South Asia as power of U.S. example

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US drone strikes will give the term “blowback” new meaning

The example of U.S. Power

An interesting article appeared in the MumbaiMirror on Saturday July 8/12. My impression is that the MubaiMirror is a low quality newspaper. But like the Toronto Star, it does reflect popular sentiment. Continue reading →

8854 Encore!

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The excuse for flogging this horse: it ain’t dead yet! Plus, this stuff needed to be pulled together.

When I posted Form 8854 on 13 June 2012 I facetiously hoped for two professionals to come up with diametrically opposed views.

Michael J. Miller soon weighed in with some very useful comments, based on actual off-the-record conversations with IRS. That information seemed to be received with joy, because it was so what people wanted to hear.

Petros followed up with a second thread on the topic on 19 June 2012: Please read this post if your actual expatriation date is before 2004 (Updated)

Some of you have been over there already, but I only recently came across the Phil Hodgen comment (to his own magisterial Why People Expatriate) that describes the core question as

A vexing problem … [that will] … require someone to be a crash-test dummy to test this in the Federal courts.

Hodgen says he might dedicate a separate posting to this in the future. In the meantime, does anyone feel like pursuing a new career as a crash-test dummy? Without someone steppping up to hit the wall, only perpetual uncertainty for all US persons in the affected class!

Not diametrically opposed exactly, but definitely messier now, definitely more equivocal than univocal.

May the dialectic continue to swerve and clatter its way toward the never-settled approximation of what actually is. If a troubling issue seems too neat, and relatively resolved, the result can’t be real.
 

Financial Post “An Unnecessary Overreaching of U.S. Tax Law into Canada”

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There was a request for posting of this Financial Post article of a few days ago.  I, too, thought it an excellent piece and made a few comments.

An unnecessary overreaching of U.S. tax law into Canada by Prof. Vern Krishna, CM, QC, LSM, tax counsel with Borden Ladner Gervais LLP and executive director of the CGA Tax Research Centre at the University of Ottawa.

The best thing Joe Green and Democrats Abroad could do is encourage all Democrats to vote for Romney

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Cross-posted from RenounceUScitizenship.

This is a response to the  email from Professor Green. Note to members of the Isaac Brock Society: This post is in part, an attempt to consolidate a number of the comments to Professor Green’s email.

Dear Professor Green:

U.S. citizens abroad – Democrats, Republicans and Independents – thank you for the “FBAR/FATCA Task Force” and we note with gratitude that:

Your FBAR/FATCA Task Force has been working steadily to seek relief for overseas Americans facing onerous tax reporting burdens.

Furthermore, your six proposals would be welcomed by U.S. citizens abroad – to be specific:

  • 1. Define a foreign or offshore account as an account in a country other than one’s country of residence or the US, thereby recognizing the legitimate need for local banking services;
  • 2. Raise the FATCA reporting threshold to $1 million to put the focus on taxpayers with wealth sizeable enough to justify the costly and complex investment structures normally used to conceal assessable earnings;
  • 3. Index the reporting threshold to inflation so that it goes up every year just as the Section 911 income exclusion does;
  • 4. Add a provision that excuses anyone who does not owe taxes (because of the Section 911 exclusion or any other exemption or a tax treaty) from the obligation to file form 8938, regardless of the threshold reporting;
  • 5. Merge the FBAR reporting requirement with the developing FATCA legislation to eliminate duplication in filings; and
  • 6. Offer amnesty to overseas Americans who are delinquent taxpayers, inviting them to pay what they may owe and restore their status as tax-compliant citizens. (See our opening remarks for our success in this area.)

That said, your proposals are merely an attempt to improve the conditions of the prison of citizenship-based taxation.  You are essentially just accepting the ideas of citizenship-based taxation, FATCA, FBAR and the rest. Gotta be in prison anyway. Why not put the effort into getting along better with the guards! Continue reading →