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Archive for April 2012

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