Liberty and justice for all United States persons abroad

The Isaac Brock Society

Media and Blog Articles Open for Comments – Part 4 of 11 (Year 2017)

You can access all years at this link: Media and Blog Articles – Links for All Years

 If clicking on a comment link brings you to the wrong comment, click here  to get on the most recent page of comments.(alternatively, to reach the most recent comment page, go to  the url in the bar at the top of your browser and delete everything after http://isaacbrocksociety.ca/media-and-blog-articles-open-for-comments-part-4-of-4)

Media and Blog Articles

EmBee suggested that it would be good if there was a thread for new articles, so that people would be aware of where to comment.   So, I created this permanent page.   I’ll make a permanent list of links posted here and keep adding to it,  but not deleting, so we’ll end up having sort of a  “bibliography” of FATCA/CBT articles.  [Note:  Some articles are not open for comments]

For more articles on FATCA, enter FATCA into Google then click on the link “more news for fatca” just below the most recent featured article.

Notes:

From JC:   To see #FATCA on Twitter for latest breaking news.  JC finds that is quite a good source and there even are some international articles that one may read using Google Translate.   Others may help certain tweets and articles remain in elevated position by retweeting them.

From Badger:   On an important archival note, please use the Internet Archive Wayback machine https://archive.org/web/ (see bottom right ‘Save Page Now’ box to enter URLs of webpages you want saved for posterity, and try to save backup copies of articles and other items of interest in some other form – such as a datastick or external drive. Some important and very significant webpages and the fulltexts of articles are no longer available (although some can be retrieved if someone using the Wayback machine saved them).

Be sure to read the comment stream for this thread — there are usually very recent articles mentioned there that aren’t on this list yet.

2017.12.28
It’s time to address the double standard about tax havens, Angela Wrights, Macleans, Canada.
The US Is Becoming the World’s New Tax Haven, The Editors, Bloomberg View, US.
2017.12.21
Rep. Dina Titus Supports Americans Abroad Tax Reform, Democrats Abroad, US. 
Now That The GOP Tax Bill Is Approved, The IRS Gets Busy, Brian Naylor, NPR, US.
2017.12.20
Taxpayers will have to wait to find out how they fare under new legislation , Renae Merle and Aaron Gregg, Denver Post (reprint from Washington Post), US.
U.S. Shareholders –Take Action by December 31, KPMG.
2017.12.18
Have You Ever Felt Sorry for the I.R.S? Now Might Be the Time, Patricia Cohen, New York Times, US.
2017.12.12
EU finance ministers issue warning to Trump over tax reforms, RTÉ, Ireland.
2017.12.11
Banque: les consequences étonnantes de l’accord FATCA, Edouard Lederer, Les Echos, France.
2017.12.10
As Australia ousts MPs with dual citizenship, Canada’s Parliament embraces many in its ranks, Kathleen Harris, Canada. (mentions MP who “assumed his U.S. citizenship was automatically rescinded because he did not meet several requirements for continued citizenship. [But when travelling to Washington] was told he was ineligible to enter the U.S. on a Canadian passport because he was a U.S. citizen. He was . . . allowed in on a one-time basis . . . it cost him $3,000 to later sort out the administrative requirements.”)
2017.12.09
The American Diaspora: Outreach and Organization, Victoria Ferauge, The Franco-American Flophouse, Japan.
2017.12.08
Foreign-owned banks to be hit by US tax rules, Financial Times, UK.
Trump Tax Plan Worries Europe, Christian Reiermann, Der Spiegel, Germany.

For articles earlier in 2017, click here.

1,720 thoughts on “Media and Blog Articles Open for Comments – Part 4 of 11 (Year 2017)”

  1. RE: That Newsweek article … Karen may have finally given second thoughts to Ted Bauman about who is on the Liberty List. Others (myself included) never could. Good stuff!

    Ted Baumann · University of Chicago
    Karen Alpert – tank you for pointing an inaccuracy in my earlier post. I shall research and revert.

  2. Perhaps of interest to those seeking compliance:

    IRS LB&I Division Announces Eleven Additional Compliance Campaigns: Today, the IRS Large Business and International (LB&I) Division announced the identification and selection of 11 additional compliance campaigns. The 11 campaigns selected for this rollout are:

    * Form 1120-F Chapter 3 and Chapter 4 Withholding Campaign
    * Swiss Bank Program Campaign
    * Foreign Earned Income Exclusion Campaign
    * Verification of Form 1042-S Credit Claimed on Form 1040NR
    * Agricultural Chemicals Security Credit Campaign
    * Deferral of Cancellation of Indebtedness Income Campaign
    * Energy Efficient Commercial Building Property Campaign
    * Corporate Direct (Section 901) Foreign Tax Credit
    * Section 956 Avoidance
    *Economic Development Incentives Campaign
    * Individual Foreign Tax Credit (Form 1116)

    https://www.lexology.com/library/detail.aspx?g=cac0ae83-56fa-4be1-95f2-0015ade5e6b3

  9. Wait til those people whose lawyers told them not to renounce hear that things are likely going to get worse for them under tax reform.

  11. The Matt Welch piece was great, though he could have added one small sentence about how tax treaties don’t always protect against double taxation (plus maybe another sentence about the prevalence and virtues of non-compliance for accidentals).

    As for the comments, once you wade past the long screaming match about leftist violence and Rand Paul, you find this utter gem:

    “You mean to tell me the GOP campaigns on a small-government platform and governs on the same greedy-pig platform as the Democrats? God help me, I hope they’ve got a program for subsidizing fainting couches and clutching pearls because I’m gonna need a shitload of both.”

    Best thing ever.

  14. email from Republicans Overseas from Michael DeSombre from @LadyOh60 received yesterday.

    Asks to keep signing the petition. http://ttfi.info/

    House Republicans introduced the tax reform bill (H.R. 1 – Tax Cuts and Jobs Act) on November 2, 2017, and overseas Americans immediately reviewed it to see if Territorial Taxation for Individuals was included in it. After Chairman Brady mentioned TTFI in a press conference and stated that his committee was seriously considering it, expectations were high. Unfortunately, this first version of the bill did not propose TTFI. While we are disappointed, this is not entirely unexpected. The process of getting a bill introduced and then voted into law is a complicated process that balances many competing requirements.

    The tax bill does support a move to territorial taxation for corporations, and this is a positive development for overseas Americans. Moving away from a corporate version of CBT paves the way for moving away from CBT for individuals as well. Nothing in the tax reform bill’s language regarding territorial taxation for corporations would negatively influence or prevent a change to territorial taxation for individuals.

    While not yet included in the bill, our TTFI proposal is currently in the Joint Committee on Taxation.

    Furthermore, the complicated nature of marking up a bill and reconciling it between the House and Senate also means that there are still several points where TTFI could be introduced.

    “We are confident that our friends of the House Ways and Means Committee will do their best to get our TTFI included in Chairman Brady’s mark-up. When we started fighting for TTFI in January of this year, nobody on Capitol Hill said that TTFI inclusion would be an easy fight,” said Solomon Yue, Jr., CEO and Vice Chairman of Republicans Overseas. “We’ve made progress and have gotten senior officials talking about TTFI. Now we need to get those words put into writing in the tax reform bill. We are committed to fight and win this uphill battle.”

    If Chairman Brady’s mark-up does not contain any language on TTFI, then the next opportunity for including TTFI in tax reform will be in the Senate’s version of the bill. We may have an additional opportunity to lobby in person for inclusion of TTFI in the Senate bill, and we will let you know when that happens.

    The fight to end double taxation is not over—we are still fighting for TTFI inclusion, and we will keep you updated on developments. The strongest weapon we have to fight for TTFI is grassroots support. As a result, please keep gathering signatures on the petition: http://ttfi.info/ .

    Sincerely,
    Michael DeSombre
    Worldwide President, Republicans Overseas

  17. We need Brock SWAT to go to Tax Connections and comment on John’s article-we need to let the tax compliance community know what we think of this atrocity.We all know how the IRS will not clarify issues such as 877A and Retroactivity and the result is that the tax community ends up “establishing” the law. We cannot let this happen with this hideous 12% tax on expat corporations. It needs to be out in the open that this is not going to be complied with. Please!

    https://www.taxconnections.com/taxblog/us-tax-reform-bill-appears-to-confiscate-12-of-retained-earnings-of-certain-canadian-controlled-private-corporations/#.WgNup2iPKM9

  18. @ Patricia Moon
    That’s one straight shootin’ comment you made there.
    @ Brock SWAT
    We need more of you to take aim at this 12% atrocity, even if you are not a USC involved with a CFC, like me.

  19. Part of thsi you will have read already but here an email I just sent to Solomon Yue (Republicans Overseas) seeking clarification on TTFI and whether it could eliminate the onerous new rules on US persons abroad owning a business:

    Do you think that lobbying for TTFI to be included in the tax bill will have any ameliorating effect on the current proposals that worsen US tax for US persons who own a business abroad where they reside?

    A large number of US persons in Canada may be facing the following according to Mr Reed, a cross-border tax specialist who finds that:

    “* Currently, most US citizens who own a Canadian corporation that is an active business don’t pay tax on the company’s profits until they take the money out. The House plan changes this. It imposes a new, very complicated, set of rules on US citizens that own the majority of a foreign corporation. The proposal would tax the US citizen owner personally on 50% of the entire income of the Canadian corporation that is above the amount set by an extremely complex formula. At best, this will make the compliance requirements for US citizens that own a business extremely complicated and expensive. At worst, this will cause double tax exposure for US citizens who own a Canadian business on 50% of the profits of that business.

    * Imposition of a 12% one-time tax on deferred profits. Under the new rules, the US corporate tax system is transitioning to a territorial model. As part of this transition, the new rules impose a one-time 12% tax on income that was deferred in a foreign corporation. Although perhaps unintentional, since US citizens will not benefit from a territorial model, the new rules impose a 12% tax on any cash that has been deferred since 1986. Take a simple example to illustrate the enormity of the problem. A US citizen doctor moved to Canada in 1987. She has been deferring income from personal tax in her medical corporation and investing it. Now, 12% of the total deferred income since 1986 would be subject to a one-time tax in the US. That may be a significant US tax bill.

    If TTFI can be included in the tax bill, would the above new taxes on “foreign” corporations still be applied to non-resident Americans owning a business in their country of residence?

    I am puzzled about what TTFI would mean. In your previous email you said “.. the US would only tax earnings in the US, and France would only tax earnings in France etc….” . If a US citizen does not pay tax on income from France, does this exclusion apply to passive income such as a company pension or interest and dividends from France, or is it only earned income from France that’s excluded. Would the US really agree to let US residents receive passive income from other countries free of US tax, and risk homelanders legally moving all their savings to low tax jurisdictions? If tax on passive foreign income received in the US stays, and the RO position remains “we will not advocate preferential tax treatments for overseas Americans”, then taxes on “foreign” passive income will remain for overseas Americans. How would this be different from today’s extra-territorial regime that makes US taxation so much more onerous and limiting for overseas folks compared to homelanders?

  20. Good questions @ fn0.
    If a road doesn’t lead to renunciation, it might lead to resistance. After this repatriation tax debacle I have to hope so anyway.

  22. fn0 I believe it has been established that those entities that already would attract PFIC would not attract this new tax.

  25. It seems that the big corporations have been lobbying against the excise tax; Brady made some changes which didn’t appease the corporations but did kick a big hole in the budget; so repeal of the ACA individual mandate may be duct-taped over the hole.

    https://www.ft.com/content/98a92024-c3e5-11e7-a1d2-6786f39ef675

    http://uk.businessinsider.com/trump-gop-tax-plan-excise-tax-foreign-earnings-2017-11?r=US&IR=T

    http://edition.cnn.com/2017/11/08/politics/tax-reform-state-of-play/index.html

    I don’t understand why this ACA repeal, which they couldn’t get through before on its own, would not have the same difficulties as before. This is a very strange way to make laws. It’s as if they’re all going through the ritual motions of a dance, with no real expectation that there will be a result.

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