I wanted to post that a fairly prominent US tax law professor and new blogger Allison Christians is becoming the H. Heward Stikeman Chair in Tax Law at McGill University. From reading her blog she appears to be moderately pro FATCA although perhaps not as strongly as some other US tax profs I have seen out there(She is more pro information sharing citing the current US Canada agreement as an example). She has three blog posts I suggest you might want comment on. I have put links below:

http://taxpol.blogspot.com/2012/03/countries-dont-help-each-other-to-tax.html

She discusses the current US Canada information sharing arrangement in the above post and discusses DATCA

http://taxpol.blogspot.com/2012/03/international-tax-gangsters.html

General post on offshore evasion

http://taxpol.blogspot.com/2012/03/netherlands-to-share-more-tax-info-with.html

Discussion on the Netherlands joining the FATCA five agreement

Prof. Christians is almost certainly a US Person. Hopefully she will be enjoying filling out all those FBAR forms upon her arrival in Canada. Note: lets not get too nasty. Who knows Prof. Christians might be a Canadian citizen in a few years time.

Our own Ladybug sent me the following 1980 document from the US Consulate in Calgary.  It has this don’t-die-of-laughing-they-really-did-say-it line:  ” … a person who has already lost U.S. citizenship by that date [Oct. 10, 1978] may not have it restored.”  Oh that the rules were what they were.  Now, no matter whether you lost it back then or not, you have it whether you want it or not.  One line, however, is still all too true:  “Did you know … That U.S. laws, regulations and procedures are always changing, and what was true some years ago may not be true now?”

Continue reading →

 
A new 15 March 2012 issue of Wealth and Tax Matters from PriceWaterhouseCoopers appears to have just been released. The first separate article is “Stricter new U.S. investment reporting rules” and the second article is “Act now, save later – Gifts made in 2012 may lead to substantial estate tax savings for U.S. citizens” [ … not to mention reduction of net worth ].

http://www.pwc.com/en_CA/ca/high-net-worth/publications/pwc-wealth-matters-2012-03-en.pdf
 

A reader sent me the following e-mail and eventually gave me the permission to publish it earlier this week.  The IRS is hammering Canadian residents who they deem to be US persons.  All Canadians should be aware of the hazard–that if we allow the IRS to shake down our people who happened to be “United States persons” it makes all the rest of us poorer because (1) it decreases our taxable base; (2) it reduces the total investment in the Canadian economy (destroying jobs); (3) it will increase the total tax burden on workers who have to pay the Old Age security for people impoverished by United States taxation of Canadians; (4) it is a very real threat to Canadian sovereignty because it is the exaction of tribute from Canadian taxpayers.  We should all be very alarmed about United States extraterritorial taxation!  We must put pressure on our politicians to nip this in the bud. Here is the story of one Canadian couple who the Godfather Douglas Shulman Barack Obama is shaking down:

Dear Mr Dunn,

Continue reading →

 The Ontario Legislature this week passed a bill proclaiming October 13^th  as General Isaac Brock Day.  The bill was sponsored by Steve Clark (Conservative), co-sponsored by Kim Craitor (Liberal) and Cindy Forster (NDP).  Mr. Clark, former mayor of Brockville,  represents the riding of Leeds-Grenville in the Ontario Legislature.  Speaking of the successful defence against US invasion of our country, Mr. Clark points out that, “The Battle of Queenston Heights was really a pivotal battle because Canadian troops were outnumbered but Brock was able to lead them effectively.”

Further information is on the Ontario Legislature’s website at: http://www.ontla.on.ca/web/bills/bills_detail.do?locale=en&Intranet=&BillID=2578

A newspaper article, quoting one of General Brock’s descendants, Windsor City Councillor Ron Jones, is at: http://www2.canada.com/windsorstar/news/story.html?id=b0140af2-93b6-4301-a7a2-b1fdca85599d

Continue reading →

Busy night here at Isaac Brock Society but we have a response up from Government/CRA on their position on FBAR. Somewhat legalistic language and a lot of information we already know but I want everyone to take a look at it. Key points: IRS ADMITS FBAR is NOT a tax and IS UNCOLLECTABLE in Canada and CRA has NO obligation under the tax treaty to help the US enforce it against anyone on Canadian territory.

Ba481782

Some of the regulars over Jack Townsend’s blog may want to pass this along

Just saw this. Congresswoman Carolyn Maloney of New York City sent a letter to Tim Geithner requesting he start a FATCA and FBAR education campaign for expats. For some reason I don’t see this happening either and I think Maloney knows that too. I will note Maloney is becoming pretty powerful among House Democrats only a few ranks below(and supposedly a close personal friend) of Nancy Pelosi. I think perhaps pressure could be more successfully applied to US House members than Senators who are imbeciles led by Reid and Levin.

us_tax_CongresswomanMaloney_031412

Read this —

Ronald L. Brekke, 55, helped prepare phony tax forms for nearly 1,000 people, most of them Canadians, claiming more than $763 million in fraudulent refunds … Brekke told clients to cash their fraudulent checks as soon as they received them and take the money back to Canada.

http://www.latimes.com/business/money/la-fi-mo-tax-fraud-20120316,0,4261032.story

                 — and then ask yourself how big the red flag is that now flies over the word Canada at the IRS.

$14 million … all but impossible to recover.
 

I found this Financial Times article about the Swiss parliamentary vote, you will have to register for free at Financial Times to retreive it (8 articles per day for free or something like that [Editor’s Note:  Try this link instead, routed through Google news]).   Financial Times : Swiss parliament backs tax amendment   The article seems to twist the whole affair around and as far as I am concerned it is negative press for us.

Here is a link to my original rant on the parliamentary vote