Americans abroad — frustrated by the uncertainty of what FATCA will do to their financial lives, and facing repeated delays of the IRS’ promises to bring some clarity through proposed regulations — are increasingly turning to the politicians of the places where they live in an effort to get some answers. In the past week several government officials at the national or supranational level have brought up the issue of FATCA, in response to concerns expressed by constituents — both dual citizens who elected them, and banks and other institutions for whom FATCA amounts to yet another extra-territorial unfunded mandate by the US. A number of scholars have also released draft papers about FATCA and FBAR. Here’s the roundup for the past week or so. If you see any more, leave them in the comments:
Ratio for FBAR Noncompliance
“Five to six million Americans living abroad, along with 39 million immigrants in the U.S., should theoretically be filing an FBAR. Yet in 2009, only 534,043 were filed, according to the Treasury Inspector General for Tax Administration.”
This nugget extracted from:
http://frontpagemag.com/2012/02/06/the-1-percent-exodus/
Among extraterritorials and immigrants to the United States …
100 to 1? 50 to 1? Who knows?
In cosmology, scale shifts to order of magnitude. Here on a chunk of planet Earth, navigation falls back on magnitude of disorder.
ET, the new alien scaring global markets (ExtraTerritoriality)
http://www.reuters.com/article/2012/02/06/financial-regulation-et-idUSL2E8D68E220120206
I thought the headline in the Reuters article I linked to below was good for a blog post heading. A couple of quotes:
The United States is coming to be seen as a global threat, acting unilaterally with aggressive new market rules that critics say will hurt U.S. firms, foreign banks, and international markets in one swoop.
The new buzzword in the financial world is “extraterritoriality”, or ET. The idea that a government can exercise its authority beyond its borders.
Letter from the IRS
For those of you thinking about filing US income taxes for the first time, I suggest you read the following letter that I received from the IRS in the mail today. I sent my zero return for 2009 last week with a letter explaining why it was late (evidently it did not arrive on time to prevent this mail out). I am on the IRS radar, because I was compliant for about the previous ten years. Moreover, they are apparently aware of certain securities I traded in the US. But I didn’t owe anything on my income tax return. So this is the trouble that they will go to harass Canadian residents who are late filing.
New Debate on Swiss TV
Again for those of you that understand French or that do not mind making sense of translation tool outputs, please find here a link for tomorrow night’s live debate on Swiss bank secrecy and US attempts to weaken it: http://www.infrarouge.ch/ir/1887-banquiers-suisses-tricheurs The debate will be available for view on the tsr.ch website by at least Wednesday night. Please feel free to enroll on the site and post your comments straightaway, (even in English— I have seen at least one comment in English accepted and displayed on the site).
Sweeter than Honey II: The purpose of man according to the law
See the first installment of this series: Sweeter than Honey I: Introduction
Petros continues the series of posts comparing the law code of ancient Israel, the United States Constitution, and the Internal Revenue Code. This post considers what the law implies about the purpose of man.
Ex
X marks the spot. The spot where the ex has to take a stand. Perhaps even the spot where the ex eventually gets buried.
The Isaac Brock narratives turn on many different themes. How the ex came to be — and how the ex came to be even more subjected than the peculiar majority that remains encircled by the geographic borders that define such a singular nation as the United States.
The foremost word in this tangle is expatriation. The IRS offers Guidance for Expatriates Under Section 877A and Expatriation Tax. That is the you-can’t-go-home-again (if home it ever was) expatriation of an irrevocably redefined status.
American Citizens Abroad (ACA) recommendations for fundamental tax reform has been posted.
ACA recommendations for fundamental reform of U.S. tax laws affecting bona fide overseas residents has been posted on its website. They will be discussing these in DC this week.
http://www.aca.ch/joomla/index.php?option=com_content&task=view&id=504&Itemid=97
Cover sheet is here…
Position paper _ No. 1: An alternative to citizenship-based taxation with major economic advantages for the United States
Position paper _No. 2: Eleven proposals for tax reforms required and applicable within the framework of citizenship-based taxation.
Comments of support can be emailed to info.aca@gmail.com
Also, I will be sure to point ACA Directors attention to this web site for any comments that might be made here.
Re: 30 Year IRS Lawyer and 2012 OVDI – What about the December 2011 FS?
I wanted to make this a separate post so that it doesn’t get lost in the long line of comments.”
First, thanks to Mr. Mopsick for willing to post on this blog. He is the only lawyer (as far as I know) who has written complete posts. I thank him for sharing his perspectives. After reading the comments: it is worth remembering that his central message is that he is willing to talk to people – everybody has a different situation. Furthermore, the members of the Isaac Brock Society have proven that they are very knowledgeable about this issue and are perfectly capable of evaluating the value (or not) of specific legal advice.
But, the main purpose of this post is as follows:
How many Americans naturalise in European Union countries each year?
Along with the U.S. government-reported number of Americans who lose U.S. citizenship each year, various foreign governments report another number that might make American homelanders uncomfortable: the number of Americans who applied for naturalisation in other countries each year. Not all of them necessarily lose U.S. citizenship, but some certainly do.