For anyone who might be interested.
I understand the January presentation in Calgary over-subscribed immediately.
Category Archives: Issues regarding US persons abroad
Life, liberty and property: Why is a person's principle dwelling part of the OVDP?
To my knowledge there is no Foreign House Report (FHR). Did the IRS just make this up?
Dear Mr. Flaherty: A 2011 voluntary disclosure story from a late loyalist
A reader submitted this letter to me (UPDATE: Late Loyalist has now renounced his United States citizenship):
Dear Mr. Flaherty
I’m one of those Canadians with dual US Citizenship. My family moved from Minnesota to Manitoba in 1975. I was 13 years old at that time. My Dad had been an unemployed teacher for the previous 4 years. As a last resort he decided to apply for a teaching job in Manitoba. After all Manitoba is lot like Minnesota right–well the snow and -40 maybe. Wouldn’t you know, he got the job right away. We drove to Winnipeg in a snowstorm and he had the job 20 minutes after we got there. He taught for another 15 years and retired in Dauphin. My parents left everything and the result was a better life. In 1980 all our family member became Canadians, no question.
Continue reading
What facts will NOT support reasonable cause arguments for FBAR?
Penalty abatement, reasonable cause, and the facts that support reasonable cause
The Isaac Brock is a wonderful forum for discussion. It is also a wonderful resource. A resource that will alert you to issues that may be relevant to your compliance. Some readers are clearly grappling with the best way to come into compliance . This involves tax or information returns or both. The Isaac Brock Society has been fortunate to have had contributions from two lawyers: Roy Berg in Alberta and Steven Mopsick in California. Their thoughts and contributions have been greatly appreciated.
In the December 2011 FS the IRS made it clear that penalties could be abated if the taxpayer were able to show “reasonable cause”. Continue reading
Politicians all around the world discuss FATCA
Americans abroad — frustrated by the uncertainty of what FATCA will do to their financial lives, and facing repeated delays of the IRS’ promises to bring some clarity through proposed regulations — are increasingly turning to the politicians of the places where they live in an effort to get some answers. In the past week several government officials at the national or supranational level have brought up the issue of FATCA, in response to concerns expressed by constituents — both dual citizens who elected them, and banks and other institutions for whom FATCA amounts to yet another extra-territorial unfunded mandate by the US. A number of scholars have also released draft papers about FATCA and FBAR. Here’s the roundup for the past week or so. If you see any more, leave them in the comments:
Ratio for FBAR Noncompliance
“Five to six million Americans living abroad, along with 39 million immigrants in the U.S., should theoretically be filing an FBAR. Yet in 2009, only 534,043 were filed, according to the Treasury Inspector General for Tax Administration.”
This nugget extracted from:
http://frontpagemag.com/2012/02/06/the-1-percent-exodus/
Among extraterritorials and immigrants to the United States …
100 to 1? 50 to 1? Who knows?
In cosmology, scale shifts to order of magnitude. Here on a chunk of planet Earth, navigation falls back on magnitude of disorder.
ET, the new alien scaring global markets (ExtraTerritoriality)
http://www.reuters.com/article/2012/02/06/financial-regulation-et-idUSL2E8D68E220120206
I thought the headline in the Reuters article I linked to below was good for a blog post heading. A couple of quotes:
The United States is coming to be seen as a global threat, acting unilaterally with aggressive new market rules that critics say will hurt U.S. firms, foreign banks, and international markets in one swoop.
The new buzzword in the financial world is “extraterritoriality”, or ET. The idea that a government can exercise its authority beyond its borders.
Letter from the IRS
For those of you thinking about filing US income taxes for the first time, I suggest you read the following letter that I received from the IRS in the mail today. I sent my zero return for 2009 last week with a letter explaining why it was late (evidently it did not arrive on time to prevent this mail out). I am on the IRS radar, because I was compliant for about the previous ten years. Moreover, they are apparently aware of certain securities I traded in the US. But I didn’t owe anything on my income tax return. So this is the trouble that they will go to harass Canadian residents who are late filing.
New Debate on Swiss TV
Again for those of you that understand French or that do not mind making sense of translation tool outputs, please find here a link for tomorrow night’s live debate on Swiss bank secrecy and US attempts to weaken it: http://www.infrarouge.ch/ir/1887-banquiers-suisses-tricheurs The debate will be available for view on the tsr.ch website by at least Wednesday night. Please feel free to enroll on the site and post your comments straightaway, (even in English— I have seen at least one comment in English accepted and displayed on the site).
Sweeter than Honey II: The purpose of man according to the law
See the first installment of this series: Sweeter than Honey I: Introduction
Petros continues the series of posts comparing the law code of ancient Israel, the United States Constitution, and the Internal Revenue Code. This post considers what the law implies about the purpose of man.