Category Archives: Issues regarding US persons abroad

Phoenix rises: Canadians still buying properties despite price hike

I published a letter that I sent with my 2009 tax, which was late because of sheer frustration about what to do.  In the letter, I explained that I had relinquished my US citizenship.  Yet the IRS seems to think that I do not qualify for the Foreign Earned Income Exclusion.  If you will recall, they sent me a threatening letter asking for more information, to which I replied about a month ago, possibly with insufficient time for them to take it into account (though I don’t see how they could not have received it before June 12, as it was sent in early May).  The original 2555, filled out by my cheap tax preparer (no longer qualified according to the new rules), did not include the dates of my residence abroad.  Thus, I amended that form and resent it.  This shows the problem of finding a good tax preparer.  If one is cheap, he will make mistakes.  If a tax preparer makes no mistakes, expect to pay over a thousand dollars for a simple return.  In any case, I will appeal this decision within the 60 days.

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Plenty of Brockers will be old enough to remember Steve McQueen trekking his way through the weekly TV series Wanted: Dead or Alive as bounty hunter Josh Randall toting a sawed-off rifle. So American. No doubt a childhood hero of the Dubya flyboy who famously went MIA in Texas airspace during the Vietnam era — already on his way to accomplishing his mission!

Today zuludogm mentioned in passing that some British banks are incorporating IRS snitch activity into their business planning as a new profit center.
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A poke around in the FAQs at the admirable website of http://www.renunciationguide.com/ brought up this tidbit that never seems to have surfaced or been kicked around at Brock — memory of nothing on the topic has further tested out against a no-result word search on “Carlton”:
 

An interesting question would be whether the IRS would attempt to retroactively apply the potential Congressional law change. Retroactive law is against the constitutions of most countries of the world. Nonetheless, in a 1994 case, U.S. vs. Carlton, the U.S. Supreme Court held in an unanimous decision that changes in tax law — and only tax law — can be applied retroactively if the law has a rational legislative purpose and is not arbitrary, and the period of retroactivity is not excessive. These criteria are extremely broad; as Justice Scalia wrote in a concurring opinion, the Court’s vague criteria effectively “guarantee[] that all retroactive tax laws will henceforth be valid.”

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I found some rather interesting industry comment letters on the US Department of Treasury FINCEN website related to one of the rulemakings they have outstanding regarding their intent to impose sometype of FATCA recipriciocity on Domestic US Banks. (Note: There idea of recipriciocity is still nothing compared to what they are demanding of foreign banks under FATCA). I find it remarkable the extent to which the US Banking industry is opposed to even these limited new regulations(They aren’t even being asked yet to collect citizenship information from their domestic US customers. I can’t wait to see their response when that is proposed).

http://www.regulations.gov/#!docketDetail;dct=PS;rpp=25;po=0;D=FINCEN-2012-0001

Hello everyone.  Today my son picked up his CLN from the post office.  It has actually been waiting there for him for over a week but he just didn’t have the time to go get it.  He expatriated on May 3rd of this year so he got his CLN in record time.

I just picked this up on the internet !

Reuters , Forbes , WSJ