“Preserving our individual freedoms ultimately requires collective action.”
Thank you, Mr. President, for providing the clearest rationale yet for the necessary existence of The Isaac Brock Society. As you begin your second term in office, may you spare even a nanosecond of thought for U.S. Persons worldwide untainted by the assumption that we are all rich tax cheats like your outgoing Treasury Secretary. Have a nice day.
The majority of RBC clients are not U.S. persons and, in most cases, FATCA should have little impact. If you have an existing account and there is an indication that you may be a U.S. person, or if you are opening a new account, RBC may ask you to provide additional information or documentation to demonstrate that you are not a U.S. person. (link mine)
From the RBC’s FATCA page.
Hat tip: Suki
It appears to me that our strongest card — besides the 1,000,000 of us in Canada — is the support of the Canadian Civil Liberties Association. It is a wonderful organization — recall the fine work done on the G20 in Toronto. I suggest we all join and support its ongoing work — especially in regards to us! http://ccla.org/
As you know the IRS wants to require a license, issued by the IRS, in order to charge money to prepare tax returns. For the moment this requirement has been struck down by the courts.
https://twitter.com/FATCA_Fallout/status/292905409373683712
I believe that the discussion on this is missing the most important point which is captured in this exchange:
My comment on "IRS Stopped 'Dead In Its Tracks' In Efforts To Regulate Tax Preparers" @Forbes: http://t.co/8v7RKRz0
— Alvin S. Brown, Esq. (@USTaxAttorney) January 20, 2013
@USTaxAttorney @Forbes Big difference between the regulation of preparers and preparers being regulated by the IRS. Latter is the problem!
— U.S. Citizen Abroad (@USCitizenAbroad) January 20, 2013
The problem is that that if it is the IRS that is issuing the license, then tax preparers will think that they must please the IRS instead of being fair to the client. It is like the problem of the lawyer who wants to put everybody into OVDP and the lawyer who considers a number of compliance options.
This case is likely to go to the Supreme Court. I suspect that the decision that the IRS can’t regulate will stand.
This is an interesting topic to solicit comments on. I am increasingly of he opinion that the manner in which the U.S. imposes citizenship-based taxation may be a human rights violation. The reporting rules, threats, intrusion into the family finances, keeping the non-US spouse out of the family finances, disallowing a child deduction for children who are NOT U.S. citizens, making it difficult for the non-citizen spouse to inherit …
Does U.S. citizenship-based taxation interfere in marriages?
Subject to your comments, I think this would be worth a more comprehensive post.
I don’t know much about the show or the radio station in NYC but it should be available online both live and via archive. It looks this show which is fairly new has covered expat issues in the past such as interviewing Mark Nestmann. Interview air time looks to be 7:00PM Eastern.
Overall impression of the conference:
Tax policy is simply to important to allow the discussion to be shaped and dominated by tax professionals! Perhaps they should not even be included in the discussion.
Advice:
Enjoy the video!
______________________________________________
Missed Tax Advice for the 2nd Obama Admin? Check out the video here: http://bit.ly/Zwo8qV #ObamaTaxAdvice @TaxAnalysts@SoCalTaxProf
Live webcast available.
http://new.livestream.com/pepperdinesol/lawreviewsymposium
Familar names attending:
Business/International Tax #2
Moderator: Khrista McCarden (Pepperdine)
Papers: Reuven Avi-Yonah (Michigan), Corporate and International Tax Reform: Proposals for the Second Obama Administration
Allison Christians (McGill), Putting the Reign Back in Sovereign: Advice for the Second Obama Administration
Susan Morse (UC-Hastings), The Transfer Pricing Regs Need a Good Edit
Commentary: Robert Goulder (Tax Analysts)
I am not sure what time they will get to this last segment. Probably in the afternoon for those of you in the Eastern Time Zone
US Department of the Treasury News Release
Treasury and IRS Issue Final Regulations to Combat Offshore Tax Evasion
1/17/2013
NOTE: This document is scheduled to be published in the Federal Register on 01/28/2013 and available online at http://federalregister.gov/a/2013-01025, and on FDsys.gov
Treasury Advances Efforts to Secure International Participation, Streamline Compliance, and Prepare for Implementation of the Foreign Account Tax Compliance Act
WASHINGTON – The U.S. Department of the Treasury and the Internal Revenue Service (IRS) today issued comprehensive final regulations implementing the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target non-compliance by U.S. taxpayers using foreign accounts. The issuance of the final regulations marks a key step in establishing a common intergovernmental approach to combating tax evasion.
These regulations provide additional certainty for financial institutions and government counterparts by finalizing the step-by-step process for U.S. account identification, information reporting, and withholding requirements for foreign financial institutions (FFIs), other foreign entities, and U.S. withholding agents.
The stories keep coming now, so while I have posted in several threads, thought I would headline it.
American FATCA punishes law-abiding Canadians
Last time the United States tried to rule us, we sent them packing.
Yet 200 years later, our government is about to surrender without a fight.
The assault comes under America’s new Foreign Account Tax Compliance Act (FATCA).
Aimed at those using foreign havens to dodge taxes, this law will punish law-abiding Canadian citizens and residents.
When I taught and paid tax in Korea, I notified Canada Revenue about my move and didn’t need to file or pay Canadian taxes while away.
But my American teaching colleagues faced a double burden, still paying U.S. taxes, even if they’d been away for years and weren’t planning to return any time soon.
Now they’re putting the squeeze on Canadians, too.
Eric can be followed on Twitter @ErichTheGreen
Pepperdine Law Rev. 
