Strata corporations of townhouses and condominiums exist all over Canada to maintain and operate common interests of the owners of the individual units. Some of these strata corporations have dozens of members. It would not be uncommon for such corporations to have funds that may need to be invested in order to maintain buying power in an inflationary environment. But no more, if the following comment by Michael is true:

I’m on a board of directors for a non-profit corporation (condominium corporation). We are a Canadian corporation, Canadian-owned, and can only invest in GIC’s that are CDIC-covered. Our investment institution (our bank – as well as all other Canadian Banks as I am lead to understand) is requiring us to fill out form W-8BEN-E, which seems to make no sense whatsoever since it is impossible for us to have exposure to US withholding tax. On top of that, it appears (although the full requirements too confusing for me to understand on 1st reading) that I need to list condo owners who may fit one or more of the following requirements: US citizens, have substantial US holdings, spend a significant amount of time in the US, have substantial US dealings through their corporations, etc. In my position, I don’t believe that I can gather that information.

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The official link for Keith Redmond on Fox Radio is here: http://radio.foxnews.com/2015/01/26/american-expat-keith-redmond-on-why-some-americans-abroad-renounce-us-citizenship/

Please stop using the other link that has a pirated recording of the interview. It is bugging the hell out of Fox.

For those who don’t know Keith, he lives in France and is the moderator and creator of the American Expatriates group on Facebook.

I have no comments on the interview. I will listen to it later.

Cross-posted from ADCS-ADSC blog

First, congratulations are in order. Once again your donations have allowed the Alliance For The Defence of Canadian Sovereignty to achieve your funding goals. The third $100,000 cheque is on its way to your lawyer. There are some (mainly in the compliance industry) who had hoped for a failure of funding. You have not been deterred. Your funding of this lawsuit has been an “island of positive hope” in a “sea of negativity”.  You have also sent a message that your lawsuit will not fail because of a lack of funding. Congratulations!

I want to reemphasize that your funding goals have been achieved because you have focused on what YOU want to achieve. You have not focused on the obstacles or on your detractors. We are in a marathon and not a sprint. We need to stay focused on OUR GOALS. We must not focus on those who want us to fail.

Your FATCA lawsuit is historic and is setting an example for people in other countries. I predict that organized opposition to FATCA will begin in Europe. Organized opposition to FATCA is essential. But, we cannot let our focus on FATCA obscure the need to bring an end to U.S. citizenship-based (AKA “place of birth”) taxation. After all:

FATCA is the tool to enforce U.S. citizenship-based “place of birth taxation”. Therefore, a separate goal is to bring an end to “place of birth” taxation. Think of how unfair it is to levy taxes on people based on their “place of birth” (and this is going on the 21st century).

“It’s unjust. It’s inhumane. I never chose where I was born!”

Meanwhile, back in the Homeland …

In previous posts, I have drawn attention to the fact that tax reform is under serious consideration. It is necessary. It is going to happen.  I have noted that Senator Orrin Hatch is now the Chair of the Senate Finance Committee and that the “tax reform train is leaving the station“. I remind you that an earlier report by the Republican wing of the Senate Finance Committee stated that Americans abroad should be taxed according to the principles of  “residence based taxation”. On January 25, 2013 Senator Hatch in a speech at the Brookings Institution stated that U.S. corporations should be subjected to “territorial taxation”.  How could the environment be better than this? To date, Americans abroad feel they have not been heard. To date, Americans abroad feel they have been victimized by Homeland politicians who neither understand nor care about the difficulties they face.  Senator Hatch has divided the Senate Finance Committee into various sub-committees.

Update: @GOPSenFinance Forms Tax Reform Working Groups http://t.co/TxK2sBeemf – #Americansabroad get chance to educate @SenSchumer

— John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) January 17, 2015

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Comment a short while ago from Haydon Perryman:

Forgive me, I’m sure I should start a new thread but I don’t know how.

I had a look at the Canadian IGA.

FATCA Agreement – Canada, February 5, 2014 “Agreement Between the Government of the United States of America and the Government of Canada to Improve International Tax Compliance through Enhanced Exchange of Information under the Convention Between the United States of America and Canada with Respect to Taxes on Income and on Capital “

It is up for review as of December 31, 2016. P18.

It references Article 6 commitments.

The first item in Article 6 is US reciprocity*. (Which looks unlikely to say the least.)

 

* Article 6
Mutual Commitment to Continue to Enhance the Effectiveness of Information Exchange and Transparency

1. Reciprocity. The Government of the United States acknowledges the need to achieve equivalent levels of reciprocal automatic information exchange with Canada. The Government of the United States is committed to further improve transparency and enhance the exchange relationship with Canada by pursuing the adoption of regulations and advocating and supporting relevant legislation to achieve such equivalent levels of reciprocal automatic information exchange.

Article 10
Term of Agreement

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UPDATE January 24, 2015: THIRD OF FIVE LEGAL BILLS PAID

[We now have a NEW POST taking us up to May 1, 2015. This post will be retired from service.]

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Cross-posted from Alliance for the Defence of Canadian Sovereignty

#Americansabroad and U.S. corporations have a lot in common bc they are both taxed on earnings outside the U.S. http://t.co/AOeUqIQ76T

— John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) October 9, 2014

In a guest post published in Forbes Magazine, I argued that the tax treatment of U.S. citizens abroad is similar to to the tax treatment of U.S. corporations abroad (although the treatment of corporations is much less destructive). The tax treatment of both corporations and U.S. citizens abroad is based on the same destructive assumption that the U.S. can and should tax profits and incomes earned in other countries. The United States regards both it corporations and its DNA citizens as “citizens”. This suggests that the case for the tax reform in relation to U.S. citizens abroad, can be linked to the case for tax reform of U.S. corporations doing business abroad.

I concluded with:

The question is NOT whether U.S. corporate tax rates should be lowered (although they obviously should) to combat inversions, the question is whether the U.S. should:

Continue its destructive and anti-competitive policies of being the only country in the world which attempts to levy taxes on profits earned in other countries by people (in the case of Americans abroad) who do NOT live in the U.S.; or
Join the rest of the world by taxing ONLY the profits and property that are within its jurisdiction. This is called “territorial taxation”.

The answer to this question depends on whether the U.S. believes that it is PART of the world or whether the U.S. believes that it is THE world.

In previous posts, I have emphasized the importance of making the case for tax reform directly to the Senate Finance Committee. In my next post, I intend to provide a framework for how this may be most effectively organized.

On January 23, 2015, Senator Orrin Hatch addressed the Brookings Institution on the need for tax reform to address the problem of corporate inversions.

Hatch of @GOPSenFinance makes case for territorial tax to combat corporate inversions http://t.co/kzI4MxGZFY – Why not for #Americansabroad?

— Citizenship Lawyer (@ExpatriationLaw) January 25, 2015

Senator Hatch is clearly and convincingly making the case for a move to “territorial taxation” for corporations. The same rationale applies to “territorial taxation” for individuals. “Territorial taxation” for individuals is:

Residence-based taxation!

Read Senator Hatch’s speech. In fact, read it more than once.

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The following nuggets extracted from a singular academic essay may help to further inform persistent Brocker campaignist tendencies toward LTA (lobbying the authorities) and DTM (doing the media).

Americans in Canada are not loved by their vassal state, and never will be. When the empire claims its own, the emotional juices of schadenfreude have to overwhelm narrow rational self-interest.

Just watch those Americans get what they deserve. What a delightful spectacle. The increase in my Canadian banking fees due to FATCA is less than I spend on watching hockey goons smash each other up, and the show is way more fun.

Sauve qui peut.

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Per requests by “i2” and George to highlight this Opinion article in a post…

Estonia Public Broadcasting, January — FATCA sows discrimination, unconstitutionality in banking

The Foreign Account Tax Compliance Act, the attempt by the US government to reel in money from its citizens living abroad (including people who may not know they are citizens) has been in the news for at least five years. Now, some six months after implementation, banks are getting serious about enforcement, causing tempers to rise and, in some cases, violating the Estonian Constitution.
…
Estonian citizens are affected, too, and it’s here that some of Estonia’s biggest banks have begun acting in an unconstitutional manner.

What has long been considered one of the biggest blessings – American by birth – has in this one case become an onerous burden. At most of Estonia’s banks, tellers have been instructed to check customer files for any sign of a connection to the US, such as place of birth. If a customer is flagged, then without preamble or explanation, the teller initiates a series of questions, such as “what is your taxpayer number” – by which they mean the US social security number.
…
But there are quite a few folks with no actual connection with the US besides a place of birth. If they want to avoid the wrangle, the burden is on them to sort it all out. That is wrong.

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