This is pretty pathetic but I wanted to post it.
http://www.fco.gov.uk/resources/en/pdf/3706546/594588382/716347982/TrEmUSANo12012FACTA
I don’t know if I can say anything else at the moment it is a very poorly written document basically competely focused on the problems facing financial institutions.
ACA: “SHE’S DONE IT AGAIN! Nina Olson, Taxpayer Advocate within the IRS, has issued her semi-annual report to Congress. Lucidly written and comprehensible by laypeople, it’s an eye-opening read. Significant space is given to problems of Americans
Received via email from ACA:
American Citizens Abroad (ACA) Welcomes Treasury Department’s Latest Step on FATCA
In its ongoing efforts to implement the Foreign Account Tax Compliance Act (FATCA), the U.S. Treasury Department has just released an updated version of the Model Intergovernmental Agreement (IGA), on November 14th. FATCA requires foreign financial institutions to report the accounts of American citizens and those considered US persons, to the U.S. government, or risk incurring a withholding tax of 30% on all U.S. transactions. This new version of the Intergovernmental Agreement contains provisions that require a Foreign Financial Institution (FFI) that wishes to take advantage of certain favorable provisions to avoid policies or practices that discriminate against opening or maintaining accounts for Americans residing in the foreign country covered by the IGA. This “loosener” is aimed at small financial institutions with essentially a local client base.
US and China could play “fiscal chicken” under FATCA
This month the IRS released a list of 50 countries that are on the road to signing an IGA – either finalising models for IGAs, engaged in dialogue for pursuing an IGA or conducting initial negotiations. China was not on the list as being at any level of negotiation with the IRS. This is significant, according to Dan Niedle, a London-based tax partner at law firm Clifford Chance.
“The interesting question about the list is who’s not on it at all. And China is the obvious one,” he says. “There are lots of rumours. Early on it was reported that China might just ban its financial institutions from taking part and dare the US to impose withholding taxes.”
Again this re-iterates the need for Canada and other countries not to enter into IGA’s.
How bad is it?
In case you hadn’t already figured it out, this is the shape of things to come for U.S. Persons abroad: relentless bipartisan attacks on the Foreign Earned Income Exclusion in the name of “simplifying the tax code” and “cutting subsidies to favoured groups”, because the “non-partisan” Joint Committee on Taxation (which is composed entirely of Homelanders) classifies it as a “tax expenditure”. The latest effort in this direction: Dennis Ross (R-FL)’s HR 6474, which purports to implement the recommendations of the Simpson-Bowles Commission regarding territorial taxation. It contains provisions to phase out 20% of the FEIE every year until it is fully eliminated in 2017:
SEC. 271. FIVE-YEAR PHASEOUT OF CERTAIN TAX EXPENDITURES.
(a) In General- Effective for taxable years beginning after December 31, 2012, the amount allowable as a credit, exclusion from gross income, exemption from taxation, or deduction for the taxable year under the tax provisions specified in subsection (c) (determined without regard to this section) shall be reduced by the applicable percentage of the amount so allowable …
(c) Specified Provisions-For purposes of this section, the tax provisions specified in this subsection are as follows:
(1) Section 911 of the Internal Revenue Code of 1986 (relating to citizens or residents of the United States living abroad).
Boom! Right there on top in pole position, the very first “tax expenditure” they propose to cut. That in itself should tell you volumes about Congress’ attitude towards U.S. Persons abroad.
Continue reading
Alberta to recruit American war vets to work in oilsands
The question is — with working in Canada for long periods of time, what are tax return and reporting responsibilities for these workers — both for Canada CRA and US IRS?
CALGARY— Alberta is seeking to recruit an army of oilsands workers — literally.
The province is on the march to attract thousands of demobilized U.S. military personnel to help develop what’s been touted as Canada’s economic engine for coming decades, the oilsands.
The project’s success would also act as a goodwill gesture for Canada’s controversial oilsands, said Alberta Energy Minister Ken Hughes.
“We’re trying to understand how we could produce employment opportunities for American service people returning from overseas,” Hughes said Friday. “I’ve detected some interest in the States.”
The mission has attracted the attention of U.S. Ambassador to Canada David Jacobson and the encouragement of the U.S.’s former consul general in Calgary, Laura Lochman, said Hughes.
Hughes said there are a half-million unemployed or underemployed younger military veterans in the U.S. — a force that could be tapped to satisfy a chronically-hungry energy industry in Alberta.
. . .
Twenty ways the IRS can locate US expatriates, some of them no doubt new to you!
I am temporarily suspending wall of shame inductions but I think the following blog post is rather interesting. Ann Hollingshead and the Task Force for Financial Integrity & Economic Development have been big FATCA supporters for many years whom I sparred with back in the early days of Brock. At one time she was also critic of Jim Flaherty for as she put it interferring with the soveriegn right of the US to make its own tax policies. Clearly she knows about our criticism and has been stung by it(She in fact singles out American Citizens Abroad for as she puts it hyperbole). I think this might be a wonderful opportunity to bring our criticism back home to her and let her know about our latest activities. (The actually point of the blog post is to say how great the IGA’s are).
A Strong, Sustainable, Future for FATCA and Tax Compliance.
Note: as in other cases, so far this is only talk…
“Russia and the US are reportedly going to sign an account information sharing agreement by 2013. The step is expected to improve international tax compliance under the US Foreign Account Tax Compliance Act (FATCA)…
“The authorities have to agree on the mechanism of information sharing and there are several options on the table, including banks signing individual agreements with the IRS or reporting through the national regulator. Russia supports the scenario where banks report to the Federal Tax Service, the Russian tax authority, and it provides information to the IRS, Izvestia daily reported. A similar mechanism is implemented in France, Germany, Japan and Switzerland…
“Deputy PM Igor Shuvalov reportedly plans to discuss the issue with the US authorities during his upcoming visit to Washington, according to the newspaper.”
Full article: http://rt.com/business/news/russia-us-account-share-749/
