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Archive for May 2011

2011 May 30 – McKenna

 
Barrie McKenna
U.S. plan to hunt tax cheats picks poor targets abroad
Globe and Mail (30 May 2011) B2

No link available.

FATCA means “the long arm of U.S. law is poised to reach deep into the lives of millions of Canadians.”
At present Canadian financial institutions have no legal basis for reporting about their clients to the IRS. The mutual fund industry hopes for “exemptions for RRSPs and other registered plans, as well as accounts worth less than $500,000.” A European Banking Federation estimate concluded that “tracking Americans could cost large financial institutions as much as a quarter of a billion dollars apiece.”
 

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Written by usxcanada

30 May 2011 at 6:00 am

2011 May # – Zelinsky

 
Edward A. Zelinsky
Citizenship and worldwide taxation: citizenship as an administrable proxy for domicile
Iowa Law Review 96:4 (May 2011) 1289-1350

http://www.uiowa.edu/~ilr/issues/ILR_96-4_Zelinsky.pdf

[281 footnotes] Zelinsky astonishingly concludes that ease of administration by the federal government justifies U.S. taxation based on citizenship rather than domicile — even though the asserted benefits of such citizenship are found to fail to withstand scrutiny under three separate models:

In the final analysis, the benefits rationale for citizenship-based taxation is unpersuasive. That rationale has been part of our constitutional tradition since Cook. However, it does not survive scrutiny in light of the minimal legal benefits associated with U.S. citizenship; the absence of a convincing link between the psychological utility of citizenship and worldwide taxation; the lack of mobility among nations, which precludes active shopping among alternative citizenships; and the divergent tax prices the Code currently assesses different citizens for the same benefits of citizenship. (1320)
 

Written by usxcanada

1 May 2011 at 5:00 am

Posted in Academic, Uncategorized