I found a pretty good research paper back from 1997 describing the old Filipino system of of citizenship based taxation and the impact of the Canada Philippines Tax Treaty. Like the US Canada Treaty the Filipino treaty had/has a “savings clause” allowing the Philippines to tax its citizens living in Canada on Canadian source income. The paper suggests a route to bringing a charter challenge to get the treaty thrown out on the basis of equality of citizenship (something we have talked a lot about here). This is big very big. I am going to try to track down the author of this paper.

Double taxation: Riding on the backs of Filipino export labour, by Genevieve Hamada-Plank , Ottawa Law Review / Revue de droit d’Ottawa 29 (1997-98) 395-423.

A reader sent me the following link:

Clooney to visit Geneva for Obama fundraiser

Clooney is set to visit the Swiss city for fundraising events on August 27th, according to Charles Adams, an American lawyer and a representative of the Democratic Party.

The movie actor plans to speak at a reception for 150 supporters paying $1,000 each, Adams told the Tribune de Genève newspaper.

The event will be followed by a dinner for 50 people coughing up $20,000 each ($30,000 for couples) for the privilege of breaking bread with Clooney.

Dem bill would require candidates, elected officials to disclose offshore accounts

“The American people might be surprised to know that we don’t already ask those running for office and Congress members whether they’re hiding money offshore,” Durbin said. “Without this bill the American people won’t know if a candidate is avoiding paying their fair share … which costs American taxpayers $100 billion a year.”

“There are only two reasons why a person has Swiss bank account,” Durbin said. “Number one: to hide their level of wealth … and two, if they think the Swiss franc is stronger than American dollar.”

Top Dems Push Bill Requiring Candidates To Disclose Offshore Tax Havens

“This is not a new issue,” said Levin, who has fought it for more than a decade. “When a crooked business or a shameless individual does not pay its fair share, the burden gets shifted to others, usually to ordinary taxpayers and working Americans. … Tax dodgers and tax avoiders have continued to exploit every offshore loophole and tax haven that they can find.”

Durbin and Levin said efforts to crack down on offshore tax havens once had bipartisan support, positing that the only plausible reason an American would have a Swiss bank account is to hide or conceal their wealth. Durbin said he intends to propose the legislation as an amendment to an unrelated bill, arguing that bringing it up separately would eat up a week’s worth of Senate time. He admitted has hasn’t spoken to Republicans about it yet.

While enjoying veggie lasagna at the Drugstore Steakhouse on the Champs-Elysées near l’Arc de Triomphe, I couldn’t help but to wonder how related patriotism is to renunciations. As I cleaned up my dish, I came to the conclusion that American politicians are generally not qualified to judge the patriotism of (former) Americans abroad. This is a unique topic of interest these days, since 8,000 American patriots are expected to renounce this year, as reported in the New York Post, which is more than ever before in US history. The demand is now so strong, that American patriots may have to wait year(s) simply to renounce.

Naturally, it is normal and understandable that so many American patriots are renouncing under the given the circumstances, understood by many Americans abroad. With some politicians directly or indirectly accusing Americans abroad of being “traitors“, “despicable” or even “unpatriotic” since they don’t want to be accused of being “unseemly and disgusting” or even “tax evaders” for banking offshore at their local bank while being denied banking services in America or abroad due to the latest US policy, or refused the ability to vote in US elections, or financially penalized for working abroad, one can only expect for more American patriots to be renouncing their US citizenship in the near future, even without mentioning the many problems related to citizenship-based taxation that some critics of renunciations like to base their misled arguments on.

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Have a peak at this screen shot from the ING Direct (France) website:

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Here is what Congresswoman Schakowsky had to say vocally in support of Carl Levin’s son of FATCA legislation:

http://capitolwords.org/date/2012/06/06/H3505_motions-to-instruct-conferees-on-hr-4348-surface-t/

I would hope that everyone would support this motion to instruct because I think you probably know that nothing annoys American taxpayers more than the notion that offshore tax havens is a place for tax cheats to go so that they don’t have to pay their taxes that normal Americans, everyday Americans, have to pay to the government.

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I thought it might be interesting to post a transcript of one of the few limited debates the US Congress has ever had on anti expat legislation.

http://capitolwords.org/date/2012/06/06/H3505_motions-to-instruct-conferees-on-hr-4348-surface-t/

You have to scroll a little bit to get to the part where son of FATCA and passport confiscation gets discussed. The debate is very partisan with New York Republican Congressman Mike Grimm doing an admirably job of holding of holding off the socialist hordes so to speak.

Here is the most interesting quote from Texas Democratic Congressman Lloyd Doggett:

My little company down there in San Antonio that changes tires all day, they’ve probably never been to Switzerland, much less considered hiring a bank in Switzerland to help them hide their revenues that they worked so hard to earn and which some of these companies involved in these abusive transactions just consider to be rather routine.

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Jet Li is easily the fourth most famous recent renunciant of US citizenship, after Eduardo Saverin, Denise Rich, and Superman. Details regarding his reasons and motives are scarce.  But I doubt that anyone should be surprised or dismayed by Li’s choice to expatriate.  He must be fabulously wealthy.  Does his renunciation make him “despicable“. Did the United States make Jet Li a great actor and martial artist?  Does he owe the United States perpetual allegiance?

Perhaps a little effort to understand is in order.

Last weekend, I watched the film Fearless  in the original Mandarin with English subtitles. Jet Li plays the part of Huo Yuanjia, the historical founder of Jinwu Sports Federation.  Early in the film, after the Huo Yuanjia wins a match, he celebrates with his friend and financier, Nong Jinsun.  They are drinking from tea cups and Huo makes a face and says:

Huo: This tastes terrible.

Nong:  It’s coffee. It comes from the West. It’s robust. Our country has grown very weak now. We are living in dangerous times. We need to regain our power and our strength. We have to learn from them, learn from the West. Otherwise, I am afraid our country shall continue its course. Continue reading →