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Archive for October 2011

2011 Oct 24 – Wood

Robert W. Wood
Oh Canada! Hating FBARs and FATCA
Forbes (24 Oct 2011)


Tax lawyer Wood sketches FATCA requirements and reports on Minister of Finance Jim Flaherty’s Sept 16 letter of complaint about US expectations on financial reporting for US citizens resident in Canada.

Written by usxcanada

24 October 2011 at 6:00 am

2011 Oct 22 – Lakritz

Naomi Lakritz
Keep your nose out of my personal finances, America
Calgary Herald (22 Oct 2011)


Dual citizen Lakritz devotes a column to declaring the US attitude toward its citizens “outrageous” because of laws that are “oppressive … unreasonable, irresponsible and unsympathetic.” She mentions her own tax compliance, and goes on to complain further in detail about US passport requirements.

Written by usxcanada

22 October 2011 at 6:00 am

2011 Oct 18 – Americans

Americans in Canada told not to fear IRS
CBC News / Canadian Press (18 Oct 2011)


This report on the content of the Oct 18 speech by U.S. ambassador to Canada David Jacobson concludes: “Uncle Sam will likely show some leniency for U.S. citizens living in Canada.”

Written by usxcanada

18 October 2011 at 8:00 am

2011 Oct 18 – Jacobson

David Jacobson
U.S.-Canada relations: issues and opportunities [Ambassador Jacobson’s remarks to the Canadian Club]
Embassy of the United States, Ottawa, Canada (18 Oct 2011)


Much of this speech by the US ambassador to Canada addresses “three unrelated events” of “the last few weeks.” The third of these “arises from recent media coverage of an issue [taxation of nonresident citizens] that has been around for about 100 years. … This is different from the way Canada — and some other countries — do it.” {{“some” here should read “almost no other”}} Jacobson mentions “two particular problems”: (1) “There are so many dual citizens, typically by birth, probably more than a million” (2) “The penalties — at least in a theoretical sense — can be quite severe.” Then Jacobson offered up a platitude that resulted in nothing more than a Dec 7 unreassuring IRS restatement of existing policy. “My message on this one is to sit tight. We are not unreasonable. We are not unsympathetic. We are not irresponsible.”

Written by usxcanada

18 October 2011 at 7:00 am

2011 Oct 18 – McKenna

Barrie McKenna
Ottawa seeks leniency for Canadians in U.S. tax hunt
Globe and Mail (18 Oct 2011)


The Oct 18 speech by U.S. ambassador to Canada David Jacobson are “the first acknowledgment from the U.S. government that the tax crackdown is a problem that has caused unintended consequences in Canada, and needs fixing.” After the speech Jacobson told reporters: “The trick is that we come up with something that deals with the legitimate concerns of law-abiding Canadian citizens and on the other hand doesn’t release people — American citizens — who go to tax havens in an effort to try to avoid taxes. We have got to collect all the taxes due and owing us because we’ve got quite a revenue shortfall and this is one of the ways to make sure we get it.”

Written by usxcanada

18 October 2011 at 6:00 am

2011 Oct 17 – Michel

Scott D. Michel / Mark E. Matthews
OVDI is over — What’s next for voluntary disclosures?
Tax Notes 133 (17 Oct 2011) 369-378


“The essence of OVDI was to leverage a civil penalties deal into the VDP.” In the OVDI programs, “stereotypical offshore tax cheats” were few in number. A large group in OVDI 2009 had accounts gifted by or inherited from parents or other relatives. A large group in OVDI 2011 had lived abroad for many years, had routine foreign financial accounts, and complied with taxation in country of residence. Unwillingness to become US tax compliant manifests “most dramatically in Canada, with its hundreds of thousands of U.S. citizens.” [Footnote 5 details a “significant increase” in persons seeking to expatriate.] The article closes with eight specific recommendations for future disclosure, and recognizes that implementation of FATCA may render the issue irrelevant. Nine footnotes.

Written by usxcanada

17 October 2011 at 6:00 am

2011 Oct 14 – NDP BC

NDP British Columbia Caucus
Re: United States Internal Revenue Service; Enforcement policy against dual Canadian-US citizens
Letter (14 Oct 2011)


Twelve NDP Members of Parliament co-sign a three-page letter addressed to Minister of Finance Jim Flaherty and Minister of Foreign Affairs John Baird. The letter concludes with five action points, a call for (1) exemption for Canadian citizens (2) true amnesty without penalty or forfeiture (3) noncompliance with FATCA (4) US focus on tax evasion only (5) formal defense of Canadians against unacceptable US threats. A closing sentence: “The potential of forfeiture of Canadian assets to the US threatens many Canadians’ income security and amounts to an unacceptable and unjustified transfer of wealth from Canada to the US.”

Written by usxcanada

14 October 2011 at 6:00 am

Posted in Canada, Government, Letter