U.S. Citizens in Canada InfoShop

Archive for February 2012

2012 Feb 29 – Orem

Tina Orem
How the IRS plans to track down secret offshore accounts
InvestingAnswers (29 Feb 2012)


Orem offers a practical and contextual account of the implications of FATCA implementation and filing requirements for Form 8938.

Written by usxcanada

29 February 2012 at 6:00 am

2012 Feb 25 – Wood

Robert W. Wood
Expats lobby for tax on residence, not worldwide income
Forbes (25 Feb 2012)


American Citizens Abroad representatives have met with House and Senate tax staffs and with staff from the Joint Committee on Taxation. Wood sees their proposal for residence-based taxation as “a long shot.”

Written by usxcanada

25 February 2012 at 6:00 am

2012 Feb 17 – Mackie

John Mackie
SOPA, FATCA and the Volcker Rule: the border busters
Reuters U.S. (17 Feb 2012)


Canadian opposition to new U.S. financial trading restrictions is among the “most vocal” of countries outside the United States. “Canada and other nations do not appreciate the unilateral expansion of U.S. jurisdiction beyond the country’s borders. After all, the financial industry in several nations came out of the financial crisis in much better shape than the U.S. industry.”

Written by usxcanada

17 February 2012 at 6:00 am

2012 Feb 14 – Dacey

Jessica Dacey
Ambassador believes worst may be over in tax row
swissinfo.ch (14 Feb 2012)


Interview with US ambassador Donald Beyer, who says: “My sense is that we’ve already hit the low point” — and mentions “around 100 Americans in Switzerland” giving up citizenship in the past year. [Flash forward: 411 more reported for first 9 months of 2012.]

Written by usxcanada

14 February 2012 at 8:00 am

2012 Feb 14 – Hodgen

Phil Hodgen
FBARs and delays in Detroit
Hodgen Law Group (14 Feb 2012)


A correspondent reports a telephone inquiry about delinquent FBARs for 2005-2009 that elicited this information: current processing was dealing with July 2011 and the system has millions of documents in backlog.

Written by usxcanada

14 February 2012 at 7:00 am

2012 Feb 14 – Wood

Robert W. Wood
Celebrity leavings: bidding stars adieu
Forbes (14 Feb 2012)


Wood comments on the increasing rate of renunciation and on aspects of the associated exit tax.

Written by usxcanada

14 February 2012 at 6:00 am

2012 Feb 12 – Chavez

Jon Chavez
Most tax rules stay same, but don’t bet on it
toledoBlade.com (12 Feb 2012)


The article has a separate section for offshore assets. “Some IRS agents from the Toledo office were used to do initial examination of such data [information retrieved from offshore programs] from February through September, 2011, said Jennifer Jenkins, an IRS spokesman.” Toledo tax preparer Chuck Mira says “the foreign-asset issue could affect a lot more Toledo area tax filers than most people think.” He suspects “a lot of high net-worth people” have been “pushing their money offshore and not paying taxes on it.” Specific mentioned destinations are Canada and Switzerland.

Written by usxcanada

12 February 2012 at 6:00 am

2012 Feb 9 – McKenna

Barrie McKenna
U.S. eases moves on offshore tax crackdown
Globe and Mail (9 Feb 2012) B5


Five European Union countries have issued a statement that they have agreed to set up a “government-to-government framework” for FATCA implementation with the United States. “Conspicuously absent from the statement was Canada.” Canadian Minister of Finance Jim Flaherty has said the agreement “appears to demonstrate an interest in greater joint government collaboration to address such concerns,” and that Canada will “continue to work with our American counterparts toward an approach acceptable to both our countries.” The IRS now says it will (1) delay some reporting requirements to 2016 (2) double the account value threshhold for exhaustive manual checks on suspected U.S. account holders to U.S. $1 million.

Written by usxcanada

9 February 2012 at 6:00 am

2012 Feb 8 – Browning

Lynnley Browning
U.S. enlists 5 EU nations in offshore tax crackdown
Reuters U.S. (8 Feb 2012)


The U.S. Treasury announces “a new multilateral approach” with five European countries (France, Germany, Italy, Spain, United Kingdom) to discuss a revised framework for FATCA implementation. “Noticeably absent from the new framework were major international banking nations such as Canada, Switzerland and the Netherlands.”

Written by usxcanada

8 February 2012 at 10:00 am

2012 Feb 8 – Jolly

David Jolly / Brian Knowlton
5 European nations agree to help U.S.crack down on tax evasion
New York Times (8 Feb 2012)
Print: International Herald Tribune (9 Feb 2012)


The United States, France, Germany, Italy, Spain, and United Kingdom, have issued a “joint statement” expressing desire to cooperate in “combating international tax evasion.” In substance, this “agreement” appears to mean further talk on the topic. “U.S. Treasury officials say privately that they hope other countries that have raised objections to FATCA, including Canada, Switzerland, China and Japan, will see the benefits of the approach.” New IRS implementation rules are said to allow “greater use of computerized searches of existing accounts for signs of American connections.”

Written by usxcanada

8 February 2012 at 9:00 am

2012 Feb 8 – Jost

Cyril Jost
Pourchassés, des américains rendent leur passeport
L’Hebdo (8 Feb 2012)


In French. “Hounded Americans Give Up Their Passports.” The story opens with the case of Denise, Swiss resident, on the verge of forfeiting her U.S. passport. Her entrepreneurial son has already abandoned U.S. citizenship. The expatriate community has undergone a sea change in its willingness to talk about renunciation. A spokesperson for the embassy in Berne confirms that resources have had to be reallocated in recent months to deal with increase in renunciation. The costs of filing complex paperwork to pay no tax are a factor. The article closes with sketches of the three voluntary disclosure programs and of FATCA implementation. The case of Premier David Alward of New Brunswick is mentioned. [Also see the Quotations section of InfoShop for a choice comment from Jackie Bugnion of American Citizens Abroad.]

Written by usxcanada

8 February 2012 at 8:00 am

2012 Feb 8 – Van Hasselt

Caroline Van Hasselt
Canada Seeks US Compromise Over Tax-Dodger Law
Wall Street Journal (8 Feb 2012)


Canadian Minister of Finance Jim Flaherty is reported to have said this in an email to the WSJ reporter: “We have been working closely with the U.S. to find a solution, and we are glad they have been receptive to addressing our concerns. … Today’s announcement appears to demonstrate an interest in greater joint-government collaboration to address such concerns. We will continue to work with our American counterparts towards an approach acceptable to both our countries.”

Written by usxcanada

8 February 2012 at 6:00 am

2012 Feb 6 – Ahlert

Arnold Ahlert
The “1 percent” exodus
frontpagemag.com (6 Feb 2012)


The article opens with the story of James Cameron’s departure for New Zealand, followed by sketch of a consistent sharp upward trend in statistics on departures from the United States. Ahlert derives two prevailing theories from lawyers associated with relocation. (1) Taxes and reporting requirements (2) Fears about the future financial direction of the United States. A tax attorney puts it bluntly: “There is a price to being a citizen of the U.S. and at a certain point the price may not be worth it.” A paragraph covers the case of Marvin Van Horn. “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.”

Written by usxcanada

6 February 2012 at 6:00 am

2012 Feb 3 – Adelmann

Bob Adelmann
Rich Americans are fleeing the country
New American (3 Feb 2012)


This story is built on a gathering of other reports and blog postings, with links provided.

Written by usxcanada

3 February 2012 at 6:00 am

2012 Feb 2 – Kennedy

Patrick F. Kennedy
Schedule of fees for consular services, Department of State and overseas embassies and consulates
U.S. Federal Register — Rules and Regulations 77:22 (2 Feb 2012) 5177-5178


“The Department [of State] has decided that the renunciant should pay this fee at the visit during which he or she swears the oath of renunciation.” The Notice itself is dated 23 Jan 2012.

Written by usxcanada

2 February 2012 at 7:00 am

2012 Feb 2 – Mitchel

Andrew Mitchel
Number of expatriates for 2011
International Tax Blog (2 Feb 2012)


Mitchel reports on data just released through the Federal Register. “In 2011, the total number of expatriates was 1,781, a 16% increase from 2010.” Includes two charts.

Written by usxcanada

2 February 2012 at 6:00 am

Posted in Legal, Uncategorized