Here is the link to the CBC Radio (New Brunswick) of the interview with Profs. Russ Hunt and Marie Cashion:
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).
Former Pennsylvania police officer officer, Larry Hohol, has produced a video which exposes corruption in State of Pennsylvania regarding the case of New Yorker Robert Leone.
My plea with those who are planning to visit the United State that you realize that there are far greater risks with that country than just simply your fear of the IRS. The corruption is becoming systemic. At the end of the video, Mr. Hohol compares Pennsylvania to a Third World country. I laughed with bitter chagrin when he said that. Does anyone here believe that the United States isn’t already a police state?
[As a concession to Just Me’s being startled by the graphic photo of Robert Leone, I’ve moved the embed of the youtube video to after the “read more” click; Warning the video is somewhat graphic and violent, and the material may shock your pro-American sensibilities]
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.
What the new IRS rules mean for U.S. citizens living in Canada http://t.co/Z0It0qts – Not much so far – what is a "low compliance risk"?
— U.S. Citizen Abroad (@USCitizenAbroad) June 30, 2012
“For taxpayers in the grey zone — the small business owner, the high income earner, the wealthy grandmother with assets in a holding company — the news release may be less comforting,” said Christine Perry, a cross border tax specialist with Keel Cottrelle LLP.
“Until we get some indication of who is a compliance risk and who isn’t I think there will be a continued reluctance to come forward.”
U.S. taxman finally eases pressure on American citizens in Canada http://t.co/JdgWfOoM – Only for those who are "low compliance risk"
— U.S. Citizen Abroad (@USCitizenAbroad) July 1, 2012
The IRS was, in my view, slow to the point of negligence in determining some kind of relief for people who were put in a terrible situation through no wilful wrongdoing. And the agency still needs to clarify the details.
Brockers who are inclined to comment take note.
#americansabroad with Subpart F income – 15% tax on dividends and cap gains ends in 2012 http://t.co/LvKzxVbT CFC owners take note #FATCA
— U.S. Citizen Abroad (@USCitizenAbroad) June 30, 2012
#americansabroad #FATCA #FBAR in 2013 the tax on dividends goes from 15% to 44.6% – Obamacare only part of the reason http://t.co/LvKzxVbT
— U.S. Citizen Abroad (@USCitizenAbroad) June 30, 2012
If I am right on this consider the following scenario:
You own a Canadian Controlled Private Corporation that would pay tax on dividend income at a rate of about 45% – this in inside the corporation. Subpart F would deem the dividend income to have been received by the the U.S. shareholder. What this means is that it goes on the citizen’s individual return (1040) and is about to be taxed at 44%. So this means means that the dividend income is subjected to tax on two levels (it may be that the U.S. citizen can get a credit for some tax paid by the corporation). First on the corporate level (at least the corporation received the income) and then on the individual level (income the individual never received). But, the bottom line appears to be: a total of 90% tax on dividends. The individual must pay a 44% tax on dividends that were never received.
Now, I hope that somebody jumps in and explains why I am wrong.
If I am not wrong, those of you with Subpart F income better make sure that your corporation does not make any more investment income.
Summary of all the taxes resulting form the decision of the #SCOTUS upholding #Obamacare http://t.co/I2Q5pZYE U.S. citizenship too complex
— U.S. Citizen Abroad (@USCitizenAbroad) June 30, 2012
HR Block excited: #obamacare will have "enormous ramifications for how Americans file taxes each year going forward" http://t.co/ShQsMkvi
— U.S. Citizen Abroad (@USCitizenAbroad) July 1, 2012
Oh my God. How is such bureaucracy possible? Run.
Cross-posted from the Flophouse. Just can’t get over some of the strange results of U.S. citizenship law. The more I think about it neither jus soli or jus sanguinis are good fits in a globalized world. So I had some fun writing this post and pointing out two rather famous Accidental Americans: Boris Johnson and Anne Sinclair. If you have a chance go read Boris Johnson’s 2006 post – as one of the Flophouse readers said, “I didn’t know Mr Johnson’s prose could be so entertaining to read.”
The United States of America allows for two methods for acquiring U.S. citizenship at birth: jus sanguinis (through an American citizen parent) and jus soli (through being born on U.S. soil). For the latter the U.S. has one of the most open-ended and generous terms around – the mere fact of being born on U.S. soil makes someone a U.S. citizen under almost all circumstances. (The only exceptions appear to be children of diplomats.)
I wonder if the US government ever considered the possibility that 6+ million snail mail letters from around the world and addressed to the “United States Department of the Treasury”, containing the sensitive whereabouts and financial data of targets of terrorism, would fall into the wrong hands while being passed around from one foreign stranger to another during its long global travel to Detroit.
“U.S. citizens are reminded to maintain a high level of vigilance and to take appropriate steps to increase their security awareness… The Department of State remains concerned about the continued threat of terrorist attacks, demonstrations, and other violent actions against U.S. citizens and interests overseas… The threat of attacks against U.S. citizens, including kidnapping and terrorist violence, is expected to continue…”
U.S. Department of State – Worldwide Caution“In today’s society, the old mailbox needs to go away,” he said. “I think you need to be real careful now and get a secured mailbox.”
200 in county recent victims of mail theft
SC upholds Obamacare because it is a tax – Homelanders join #americansabroad in paying tax on "unearned income" http://t.co/y5u0SkkD #FATCA
— U.S. Citizen Abroad (@USCitizenAbroad) June 28, 2012
In the fall I wrote a post describing how Obamacare is to be funded by taxing “unearned income”. This is one of many examples where the US taxes income that people have never earned. I am cross-posting this post from the RenounceUScitizenship blog. After publishing this post, I noted some very interesting comments, including some based on “technicalities” from Shadow Raider and Eric. These comments raised questions, about what would be included in, and what was meant by “unearned income”. Interesting comments. I have updated this post to acknowledge your comments. But, I will leave it to you to sort out the details. Suffice it to say that Obamacare is a massive tax increase that will make U.S. tax compliance even more difficult. In addition, Obamacare will certainly increase the role of the IRS in your life in a more supervisory way.
Note the following comments of Commissioner Shulman in this regard:
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The situation is indeed dismal. I don’t understand everything in the following article, but I can see that this is going to:
1. Add more bureaucracy and cost to filing your U.S. tax return – it is not clear how this is intended to impact expats (if they are considered at all);
2. Clearly interfere with your ability to invest and plan for retirement. The U.S. has become a nation of forms and bureaucracy. Continue reading
