Archive for July 2011
Americans among us
Financial Post (30 July 2011)
US tax filing requirements are described in more than usual detail. Cross-border tax lawyer Christine Perry says, “This focus on offshore disclosure and compliance is only gathering momentum.” An appended list of numbers provides a “base estimate” of $15,000 in “legal and accounting charges” to cover the eight years required by OVDI.
Truth, justice and becoming un-American
Globe and Mail (28 July 2011)
“A series of tough new U.S. tax laws [has] put many of the roughly one million Americans living in Canada in a strange limbo — afraid of breaking the law, but even more fearful of the potentially enormous cost of coming out of the shadows.” Dave in mid-50s came to Canada in the 1970s and became a Canadian citizen in the 1990s. Dennis moved to Canada in 1995. Both have been told at the border that they need to travel on a US passport. Janet Selby 47 “spent the first four days of her life in the United States.” The story concludes with the difficulties that the United States puts in the way of giving up citizenship.
Standing up to IRS “bait and switch” tactics
Rubinstein and Rubinstein (22 July 2011)
“Suddenly, two years into the  OVDP process, the IRS changed the very terms by which it attracted taxpayers to come forward and disclose their foreign accounts and declared that change to be retroactive.”
The Great White tax haven
Macleans (19 July 2011)
“Last year, nearly 12,000 people moved here under the federal government’s Immigrant Investor Program, up from 4,950 a decade ago, according to Citizenship and Immigration Canada. … Canada’s appeal to the world’s wealthy is compelling.”
Information Reporting With Respect to Foreign Financial Assets and Certain Interests in a PFIC
IRS (18 July 2011)
“Any individual who during the taxable year [beginning after March 18, 2010] holds an interest in any specified foreign financial asset is required to attach to his or her income tax return for the taxable year certain required information with respect to each specified foreign financial asset if the aggregate value of all of the individual’s specified foreign financial assets exceeds $50,000.”
U.S. delay in tax-evasion crackdown heartens Ottawa
Globe and Mail (15 July 2011)
On July 14 the IRS announced delay of FATCA enforcement for one year, with postponement to the start of 2014.
Robert W. Wood
Some foreign account penalties unfair, says Taxpayer Advocate
Forbes (8 July 2011)
Wood outlines the FBAR filing requirement, mentions 2011 OVDI, and reports on Taxpayer Advocate criticism of the IRS.