Archive for May 2012
2012 May 28 – Sankey
Derek Sankey
Taxes create cross-border issues
Calgary Herald (28 May 2012)
http://www.calgaryherald.com/business/Taxes+create+cross+border+issues/6690233/story.html
Cross-border tax specialist Roy A. Berg in Calgary offers multiple examples of “income that’s taxed more favourably in Canada versus the U.S. … contributions to RRSPs, capital dividends, stock options and flow-through shares, charitable deductions and the sale of a principal residence.” He claims “very few people” can provide the advice needed by the hundreds of thousands of deemed U.S. persons in Canada. “The penalty regime in the U.S. tends to be much harsher than in Canada and more onerous.”
2012 May 28 – Whiteley
Don Whiteley
The accidental Kenyan: What would happen if the African nation copied U.S. tax policy?
Vancouver Sun (28 May 2012)
The plight of some seven million extraterritorial US citizens, with around one million in Canada, is dramatized by imagining that similar measures are applied to Barack Obama because of “accidental” Kenyan citizenship stemming from his father. The conditions seem too preposterous to be true — but unfortunately they are.
2012 May 25 – Saunders
Laura Saunders
New taxes for “renouncers”?
Wall Street Journal (25 May 2012)
http://online.wsj.com/article/SB20001424052702304065704577424370739381862.html
Passage of the Schumer-Casey exit tax proposal is seen as much less likely than approval of a measure — already passed by the US Senate — to link passport revocation/denial to tax delinquency.
2012 May 18 – Christianson
David Christianson
Snowbirds, Americans living in Canada read on …
Winnipeg Free Press (18 May 2012)
Republished from the Winnipeg Free Press print edition May 18, 2012 B12
Financial planner Christianson outlines the substantial presence test for snowbirds, and reports on recent changes in Canada regarding “import” of funds from 401K or IRA retirement plans.
2012 May 18 – Haineault
Roger Haineault
U.S. taxman extending reach abroad
Halifax Chronicle-Herald (18 May 2012)
http://thechronicleherald.ca/business/97835-us-taxman-extending-reach-abroad
A columnist connects a recent Canadian delegation to Washington with FATCA, up to one million residents of Canada, and the potential concerns of Canada’s privacy commissioner.
2012 May 18 – Lewis
Al Lewis
Tax man makes it hard to be an American
MarketWatch (18 May 2012)
Lewis uses Canadian Peter Dunn as a case study in why extraterritorial US citizens are giving up that citizenship. Information from American Citizens Abroad supplements the account.
2012 May 18 – Saunders
Laura Saunders
Should you renounce your U.S. citizenship?
Wall Street Journal (18 May 2012)
http://online.wsj.com/article/SB10001424052702303879604577410021186373802.html
Saunders provides a substantial, tight, well-organized summary of the circumstances and issues and history associated with renunciation of US citizenship. A New York immigration lawyer reports “twice as many inquiries.” The new enforcement regime reflects “worries about capital flows and terrorism” in the wake of 9/11.
2012 May 17 – Tsukayama
Hayley Tsukayama
Facebook co-founder Saverin targeted by U.S. senators for tax ‘avoidance scheme’
Washington Post (17 May 2012)
In response to the recent Savarin renunciation of US citizenship, Senators Schumer and Casey say they will propose an Ex-PATRIOT Act to reimpose avoided taxation and to bar reentry to the United States. “Under the proposal, ‘any expatriate with either a net worth of $2 million or an average income tax liability of at least $148,000 over the last five years will be presumed to have renounced their citizenship for tax avoidance purposes,’ according to a release from Schumer’s office.”
2012 May 16 – McBride
Laura Harrison McBride
Me and Eduardo Saverin: The major difference is money
Blog at Smirking Chimp (16 May 2012)
McBride offers a useful and entertaining personal account of her 2 Feb 2012 renunciation of US citizenship in London England and the history and circumstances of the decision and action. “Not taxes that pushed my buttons, but the tax collector.”
2012 May 16 – Scott
Kevin Scott
US expatriates urged to seek tax advice
Gulf News (16 May 2012)
http://gulfnews.com/business/features/us-expatriates-urged-to-seek-tax-advice-1.1023585
Dateline Dubai. Much of the content derives from “Dubai-based tax specialist” lawyer Virginia La Torre Jeker. Coverage includes FATCA, Form 8938, and renunciation. “According to Jeker, claiming ignorance of US tax obligations will not be deemed a sufficient excuse to avoid penalties as Fatca has been well publicised in recent months.”
2012 May 15 – Shechter
Barbara Shechter
Canadian bankers head to Washington to object to U.S. tax regulations
Financial Post (15 May 2012)
The title says it all, regulations meaning FATCA and the Volcker rule.
2012 May 14 – Badkar
Mamta Badkar
Jim Rogers: The media is getting Eduardo Saverin all wrong — It’s very expensive to give up your citizenship
Business Insider (14 May 2012)
Famous investor Jim Rogers, also a resident of Singapore, comments on the renunciation of US citizenship by Eduardo Saverin. “When you give up your American citizenship, it’s not fair as far as I’m concerned, but the rules are that you have to pay everything, you have to pay taxes on everything you own and then you can leave. I mean no other country in the world does that, we’ve got our own Berlin Wall, it’s very expensive to leave, to give up your citizenship. Iran, North Korea and Cuba, and some countries it’s impossible, very expensive to give up your citizenship.”
2012 May 14 – Bandow
Doug Bandow
Eduardo Saverin, not the U.S. government, is entitled to the wealth he earned
Forbes (14 May 2012)
This fairly lengthy op-ed includes a lot of links and thus offers a kind of literature review on the topic of U.S. citizenship-based taxation and the current situation of increasing renunciations.
2012 May 11 – Lewis
Michael Lewis
Facebook co-founder Eduardo Saverin’s taxing connection to U.S.-Canadian dual citizens
Toronto Star (11 May 2012)
The renunciation of US citizenship by a Facebook cofounder sparks extension reporting on Canadian resistance to US imposition of FATCA and on recent loss of US citizenship by Canadian Peter Dunn.
2012 May 10 – Knowlton
Brian Knowlton
Many Americans abroad surprised by tax code’s nasty bite
New York Times (10 May 2012)
http://www.nytimes.com/2012/05/11/us/11iht-expats11.html
A version of this article appeared in print on May 11, 2012, in The International Herald Tribune.
Knowlton’s report concentrates on “accidental” second-generation Americans, and sketches three cases, two Canadian and one European. “The numbers of Americans filing the Report of Foreign Bank and Financial Accounts, or FBAR, soared from 276,386 in 2009 to 618,134 in 2011. … By 2011, [IRS agents numbered] 71 for global high wealth — and 856 for international operations, up from 259 just a year before … [with] plans to hire 300 more international agents.”
2012 May 9 – Ferauge
Victoria Ferauge
American citizenship — a cost-benefit analysis
Franco-American Flophouse [blog] (9 May 2012)
http://thefranco-americanflophouse.blogspot.fr/2012/05/american-citizenship-cost-benefit.html
This personalized and measured assessment demonstrates effectively and readably that the United States has made its citizenship untenable for ordinary permanent extraterritorial residents.
2012 May 8 – McKenna
Barrie McKenna
Ottawa, U.S. negotiating change to tax reporting
Globe and Mail (8 May 2012)
The Canadian government is negotiating with the United States about the implementation of FATCA. This has been the state of affairs for some time, so the availability of current quotations from Canadian officials must be the only reason for publication of this supposed news. “It is not clear how a FATCA compromise will make life any easier for the many Americans and dual citizens in Canada — many of whom don’t regularly file U.S. taxes, as required.” Ex-US citizen Peter Dunn of Toronto is quoted.
2012 May 8 – Vallikappen
Sanat Vallikappen
U.S. millionaires told go away as tax evasion rule looms
Bloomberg (8 May 2012)
This Singapore-based journalist reports at length and in detail on how a range of foreign financial institutions are severing all relationship with US citizens regardless of the assets they may possess. Anticipation of FATCA enforcement lies at the root of this discrimination. Sections of the story include these headings: Too Complex, Collateral Damage, Compliance Costs, and Renouncing Citizenship.
2012 May 1 – Broom
Giles Broom
Wealthy Americans queue to give up their passports
Bloomberg BusinessWeek (1 May 2012)
http://www.businessweek.com/news/2012-05-01/wealthy-americans-give-up-passports-in-swiss-capital
A report based mainly in Switzerland exaggerates the wealth factor in the increased worldwide renunciation of US citizenship. Beyond renunciation, highlight is given to FATCA and Form 8938. Story subheadings are more accurate than main title: Absurd Tax Laws, Imperial Overreach.
2012 May 1 – Matthews
C.M. Matthews
FATCA creating a compliance gold rush
Wall Street Journal (1 May 2012)
http://blogs.wsj.com/corruption-currents/2012/05/01/fatca-creating-a-compliance-gold-rush/
“Foreign banks have frantically begun to prepare for the new Foreign Account Tax Compliance Act, which comes into force in 2014 [by] relying on updates to internal computer systems and external consultants, creating a wave of new business for compliance professionals.” The banking industry estimates a cost of $250 million for a bank with 25 million accounts, a total of $7.5 billion for the top 30 foreign banks.
2012 May # – Sheppard
Hale E. Sheppard
The new duty to report foreign financial assets on Form 8938: demystifying the complex rules and severe consequences of noncompliance
International Tax Journal 38:3 (May-June 2012) 11-32
http://www.chamberlainlaw.com/assets/attachments/Form 8938 Article.pdf
“Confusion about Code Sec. 6038D and Form 8938 can trigger a series of negative results for taxpayers, including new information-reporting penalties, increased accuracy-related penalties, criminal charges, extended assessment periods, and a fight with the U.S. government on three fronts simultaneously.” [160 endnotes]