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Archive for April 2012

2012 Apr 23 – Erb

Kelly Phillips Erb
Mammoth bill makes IRS play border control
Forbes (23 Apr 2012)


“So let me summarize for you: if the IRS liens or levies you, the Department of State can choose to restrict your right to travel without a judicial hearing.”

Written by usxcanada

23 April 2012 at 7:00 am

2012 Apr 23 – McGurn

William McGurn
What’s U.S. citizenship worth?
Wall Street Journal (23 Apr 2012)


The 1788 renunciations of US citizenship officially reported for 2011 show a skyrocketing rate of increase. McGurn ruminates on these “canaries in the coal mine.” He concludes by deploring the US tax code’s punitive “Berlin Wall approach” toward extraterritorial citizens.

Written by usxcanada

23 April 2012 at 6:00 am

2012 Apr 17 – Ritchie

Terry Ritchie / Brian Wruk
Tax cheats beware
Advisor.ca (17 Apr 2012)


Despite the unfortunate and misleading title, this article packs a lot of information into a few words, with focus on the Canadian situation. A rightly identified crux is requirements entailing “the additional level of tax compliance and reporting on foreign assets and accounts.”

Written by usxcanada

17 April 2012 at 7:00 am

2012 Apr 17 – Urist

Jacoba Urist
No taxes, no travel: why the IRS wants the right to seize your passport
Atlantic (17 Apr 2012)


Legal experts conclude that legislation now proposed to “deny, revoke, or limit” passport rights for taxpayers with serious delinquency could withstand constitutional challenge.

Written by usxcanada

17 April 2012 at 6:00 am

2012 Apr 16 – Abrahamian

Atossa Araxia Abrahamian
Special Report: Tax time pushes some Americans to take a hike
Reuters U.S. (16 Apr 2012)


This extensive report provides an overview of main issues and current situation, together with perspectives from Canada and Europe. A broad shift toward renunciation of U.S. citizenship is made clear. The experience of Peter Dunn in Canada is offered as a case study. This is perhaps the best account so far of the pressures faced by U.S. women married to citizens of other countries.

Written by usxcanada

16 April 2012 at 6:00 am

2012 Apr 15 – Jolly

David Jolly
For Americans abroad, taxes just got more complicated
New York Times (15 Apr 2012)

Print version: International Herald Tribune (16 Apr 2012)


This article details the requirements and penalties of the new IRS Form 8938 in the context of FBAR and FATCA. “Not even the I.R.S. is certain how many of the estimated four million to six million Americans living abroad will be affected. … Congress’s new focus on Americans abroad suggests it soon will not be possible to just ignore the I.R.S. and hope no one notices.”

Written by usxcanada

15 April 2012 at 6:00 am

2012 Apr 5 – Dwoskin

Elizabeth Dwoskin
The People vs the IRS
Bloomberg Businessweek (5 Apr 2012)


The history and work of Taxpayer Advocate Service director Nina Olson are described at length. At her behest, a social anthropologist and tax lawyer has categorized tax evaders into eight categories of noncompliance: procedural, asocial, habitual, symbolic, brokered, economic, lazy, and normalized. The article in no way intersects with the particular difficulties faced by extraterritorial persons.

Written by usxcanada

5 April 2012 at 6:00 am

2012 Apr 2 – Johnston

Nigel Johnston
More on FATCA … and more to come: the Internal Revenue Service and Treasury Department release proposed regulations
McCarthy Tetrault (2 Apr 2012)


The introduction closes with a useful summary of “ongoing discussions between Canada and the United States relating to the application of FATCA.” The broad scope description of FATCA includes a five-point summary of how a “foreign financial institution” must relate to a “US person.”

Written by usxcanada

2 April 2012 at 6:00 am

Posted in Legal, Uncategorized

2012 April # – Dentino

William L. Dentino / Christine Manolakas
The exit tax: a move in the right direction
William & Mary Business Law Review 3:2 (Apr 2012) 341-418


[619 footnotes] This article aims to follow “the history and evolution of IR.C. section 877.” Seven sections cover: (1) How the U.S. taxes (2) History of U.S. taxation based on citizenship (3) Foreign Investors Tax Act of 1966 (4) Health Insurance Portability and Accountability Act of 1996 (5) American Jobs Creation Act of 2004 (6) Heroes Earning Assistance and Relief Tax Act of 2008 (7) Continuing Problems. A major conclusion is that “the [current] mark-to-market regime still violates the tax equity objectives of horizontal and vertical equity.”

Written by usxcanada

1 April 2012 at 6:00 am

Posted in Academic, Uncategorized