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Archive for June 2012

2012 June 29 – Feldman

 
Amy Feldman
New IRS rules for disclosure of foreign assets
Reuters U.S. (29 June 2012)

http://www.reuters.com/article/2012/06/29/us-taxes-foreign-fbar-idUSBRE85S1DA20120629

A competent but uncritical rehash of the new IRS rules. How those rules will “help distinguish between true tax cheats and American citizens abroad” remains far less clear than this article proposes.
 

Written by usxcanada

29 June 2012 at 6:00 am

2012 June 28 – Berg

 
Roy A. Berg
IRS offers partial tax amnesty for Canadians with “low compliance risk,” though questions remain
Moody’s Tax Advisors (28 June 2012)

http://www.moodystax.com/blog/21-us-taxation-services/185-irs-offers-partial-tax-amnesty-for-canadians-with-qlow-compliance-riskq-though-questions-remain.html

“The terms of the new procedures, and the determination of who may qualify make it unclear as to the actual number of Canadians who may be able to qualify.”
 

Written by usxcanada

28 June 2012 at 7:00 am

Posted in Canada, Legal, Uncategorized

2012 June 28 – Cayo

 
Don Cayo
U.S. taxman finally eases pressure on American citizens in Canada
Vancouver Sun (28 June 2012)

http://www.vancouversun.com/business/taxman+finally+eases+pressure+American+citizens+Canada/6853117/story.html

Cayo makes clear that the new IRS announcement leaves much uncertainty in its wake. Comment from two tax specialists indicates that IRS tough talk already has been accompanied by some restraint in exacting penalties. Many Canadian residents will still face difficulties. Those “onerous filing obligations” remain in place for all US persons.
 

Written by usxcanada

28 June 2012 at 6:00 am

2012 June 27 – Finance Minister

 
Finance Minister applauds U.S. government decision to help dual citizens with their foreign tax obligations
Department of Finance Canada (27 June 2012)

http://www.fin.gc.ca/n12/12-072-eng.asp

“I am happy the U.S. government has listened to our concerns,” says Jim Flaherty, Minister of Finance.

Comment: Too much praise. Partial and uncertain mitigation of some of the concerns.
 

Written by usxcanada

27 June 2012 at 6:00 am

2012 June 26 – IRS Announces

 
IRS announces efforts to help U. S. citizens overseas including dual citizens and those with foreign retirement plans
IRS (26 June 2012)

http://www.irs.gov/uac/IRS-Announces-Efforts-to-Help-U.-S.-Citizens-Overseas-Including-Dual-Citizens-and-Those-with-Foreign-Retirement-Plans

IRS announces new procedures effective 1 September 2012 to (1) “Allow taxpayers who are low compliance risks to get current with their tax requirements without facing penalties or additional enforcement action” (simple tax returns owing $1,500 or less in tax for any of the covered years) (2) “Allow resolution of certain issues related to certain foreign retirement plans (such as Canadian Registered Retirement Savings Plans).” The basic requirement is “to file delinquent tax returns along with appropriate related information returns for the past three years, and to file delinquent FBARs for the past six years.”

Comment: This “help” with compliance could cost many affected individuals thousands of dollars for the specialized paperwork required to demonstrate that no tax is owing.
 

Written by usxcanada

26 June 2012 at 9:00 am

2012 June 26 – IRS Says

 
IRS says offshore effort tops $5 billion, announces new details on the voluntary disclosure program and closing of offshore loophole
IRS (26 June 2012)

http://www.irs.gov/uac/IRS-Says-Offshore-Effort-Tops-$5-Billion,-Announces-New-Details-on-the-Voluntary-Disclosure-Program-and-Closing-of-Offshore-Loophole

IRS Commissioner Shulman updates on OVDI income and disclosures, reporting “the collection of more than $5 billion in back taxes, interest and penalties from 33,000 voluntary disclosures made under the first two programs. In addition, another 1,500 disclosures have been made under the new program announced in January.”
 

Written by usxcanada

26 June 2012 at 8:00 am

2012 June 26 – McKenna

 
Brian McKenna
Tax amnesty offered to Americans in Canada
Globe and Mail (26 June 2012)

http://www.theglobeandmail.com/report-on-business/tax-amnesty-offered-to-americans-in-canada/article4372266/

The first part of the article retails material from the IRS news release. The reporter’s use of derogatory innuendo — “to come clean” — is highly offensive. A Toronto “professional” who stands to profit guesses that “about 90 per cent of Americans in Canada … will fall into the low risk category” and qualify for participation. According to McKenna, “U.S. officials have struggled internally over whether people who haven’t filed for years deserve any special leniency.” The situation of an unnamed “56-year-old Ottawa woman who has lived in Canada since her family moved here when she was nine” is outlined.
 

Written by usxcanada

26 June 2012 at 7:00 am

2012 June 26 – Rubin

 
Richard Rubin
IRS says offshore tax disclosures have yielded $5 billion
Bloomberg (26 June 2012)

http://www.bloomberg.com/news/2012-06-26/irs-says-offshore-tax-disclosures-have-yielded-5-billion.html

This article covers U.S. announcement of additional new procedures for extraterritorials subject to their taxation, and updates the total amount brought in under the OVDI programs to $5 billion (based on “almost 35,000 disclosures”). IRS Commissioner Douglas Shulman wants people to “get back in the system in a seamless way,” and he mentions a “broader goal [of upping] the risk calculus for the next generation of taxpayers.”
 

Written by usxcanada

26 June 2012 at 6:00 am

2012 June 25 – Americans

 
Americans Renouncing Citizenship at Record Levels to Protect Wealth
Fox News Latino (25 June 2012)

http://latino.foxnews.com/latino/news/2012/06/25/americans-renouncing-citizenship-at-record-levels-to-protect-wealth/

“As many as 8,000 US citizens are projected by immigration officials to renounce in 2012, or about 154 a week, versus 3,805 in 2011, or about 73 per week.” Data source not specified.
 

Written by usxcanada

25 June 2012 at 8:00 am

2012 June 25 – Jobin

 
Marc-Henri Jobin
Les Américano-Suisses renoncent au passeport bleu
Tribune de Genève (25 June 2012)

http://www.tdg.ch/suisse/americanosuisses-renoncent-passeport-bleu/story/15259344

This story draws content from the Venutti piece of the same date. Additional is report from Ryan Larson, tax specialist in Zurich, who says his firm alone (U.S. Tax Services) handled 50 American expatriations in 2011, doubling the cases from 2010.
 

Written by usxcanada

25 June 2012 at 7:00 am

2012 june 25 – Venutti

 
Dario Venutti
Vom Nachteil, ein Amerikaner zu sein
Tages Anzeiger (25 June 2012)

http://www.tagesanzeiger.ch/wirtschaft/geld/Vom-Nachteil-ein-Amerikaner-zu-sein/story/13668921

Out of about 2000 reported voluntary terminations of US citizenship worldwide in 2011, 500 are attributed to Switzerland alone. Included are accounts of the personal situations of Richard Bloomfield and Amy Webster in Switzerland.
 

Written by usxcanada

25 June 2012 at 6:00 am

2012 June 23 – Tharp

 
Paul Tharp
US citizens leaving the country to avoid stiff tax bills
New York Post (23 June 2012)

http://www.nypost.com/p/news/business/more_citizens_vote_with_their_feet_CTshpQumBXMZmUXsfw6OTM

Tharp reports interestingly high figures for renunciation — “As many as 8,000 US citizens are projected by immigration officials to renounce in 2012, or about 154 a week, versus 3,805 in 2011, or about 73 per week” — as “startling new data from Uncle Sam,” but a more specific data source is not provided. Most of the article is built on comment from “Jim Duggan, a lawyer at Duggan Bertsch, which specializes in protecting assets of the wealthy.” Duggan identifies “popular spots” for wealth expatriation as Australia, Norway, Singapore, Cayman Islands, Costa Rica, Guernsey and Antigua. Canada not included!
 

Written by usxcanada

23 June 2012 at 6:00 am

2012 June 22 – Futrelle

 
David Futrelle
Renouncing your citizenship to stick it to the tax man? Not as easy as it looks
Time (22 June 2012)

http://business.time.com/2012/06/22/renouncing-your-citizenship-to-stick-it-to-the-tax-man-not-as-easy-as-it-looks/

The only useful feature of this cobbled-together diatribe is public reiteration that getting free of US citizenship is not straightforward. Stupidities include: (1) Assumption that most renouncers are driven by taxation rather than insane reporting requirements (2) Manipulation of statistics to downplay the skyrocketing acceleration in rate of renunciation (3) Citation of a dubious source.
 

Written by usxcanada

22 June 2012 at 6:00 am

2012 June 21 – Rubenfeld

 
Samuel Rubenfeld
Treasury gets Japanese and Swiss banks to agree on FATCA compliance method
Wall Street Journal (21 June 2012)

http://blogs.wsj.com/corruption-currents/2012/06/21/treasury-gets-japanese-and-swiss-banks-to-agree-on-fatca-compliance-method/

Unlike a previous understanding reached with five European countries, “the framework agreed to Thursday would allow banks in Japan and Switzerland to report directly to the Internal Revenue Service.” This “second model for implementing FATCA … addresses domestic legal impediments and reduces burdens on financial institutions.”
 

Written by usxcanada

21 June 2012 at 7:00 am

2012 June 21 – Webster

 
Amy Webster
Swiss banks step up efforts to identify, quarantine or avoid US citizens
genevalunch.com (21 June 2012)

http://genevalunch.com/blog/2012/06/21/swiss-banks-step-up-efforts-to-identify-quarantine-or-avoid-us-citizens/

A first-person narrative details the difficulties faced by a U.S. citizen married to a Swiss national. The author’s husband is experiencing discrimination, has been advised to resolve his situation through divorce, and has transmitted pressures to his wife. In consequence, Amy Webster says: “I am seriously considering giving up my US citizenship which I had always been so proud of and which I so carefully looked after. I have duly filed a US income tax return every year.”
 

Written by usxcanada

21 June 2012 at 6:00 am

2012 June 13 – Suter

 
Martin Suter
Immer mehr US-Expats geben ihren Pass ab
20 Minuten (13 June 2012)

http://www.20min.ch/finance/news/story/16330497

This account of US citizenship renunciation includes recent official statistics, sketch of the peculiarity of citizenship-based taxation, and outline of the effects of FATCA. Two years ago, Julia Schmitz-Leuffen paid $600 an hour for the unhappy advice that she could not afford to expatriate because of punitive provisions, which also affect her sons.
 

Written by usxcanada

13 June 2012 at 6:00 am

2012 June 12 – Palazzolo

 
Joe Palazzolo
It’s hard to become a non-citizen, too
Wall Street Journal (12 June 2012)

http://blogs.wsj.com/law/2012/06/12/its-hard-to-become-a-non-citizen-too/

Israeli Kenneth Fox got a US appellate court to agree that the Department of State did not have grounds to deny him a Certificate of Loss of Nationality.
 

Written by usxcanada

12 June 2012 at 6:00 am

2012 June 10 – Pulvers

 
Roger Pulvers
The self-styled ‘Land of the Free’ nurtures yet another facet of hypocrisy
Japan Times (10 June 2012)

http://www.japantimes.co.jp/text/fl20120610rp.html

Pulvers compares current and proposed U.S. policies on extraterritorial citizens with North Korean treatment of all citizens and with USSR treatment of emigrant Jews. Interwoven are a few personal experiences of this Australian who abandoned US citizenship 36 years ago.
 

Written by usxcanada

10 June 2012 at 9:29 pm

Posted in Uncategorized

2012 June 9 – Golombek

 
Jamie Golombek
The double jeopardy of a U.S. citizen
Financial Post (9 June 2012)

http://business.financialpost.com/2012/06/09/the-double-jeopardy-of-a-u-s-citizen/

The title may be the best thing about this piece occasioned by a deadline date for U.S. tax filing. Coverage of the potential linkage of passport to tax filing status is useful. Reference to “fessing up to the IRS” exhibits callous bias. Assertion of “a more relaxed IRS position announced last December” displays outright and astonishing ignorance.
 

Written by usxcanada

9 June 2012 at 6:00 am

2012 June 5 – Hodgen

 
Phil Hodgen
Why people expatriate
Hodgen Law [blog] (5 June 2012)

http://hodgen.com/why-people-expatriate/

Tax and expatriation lawyer Phil Hodgen operates at the eye of the storm. This lengthy summation amounts to a very useful mini-manual on expatriation from the United States. As a forecaster, Hodgen says: “Political signals from the United States show that expatriation and tax policies are likely to get harsher. … The cost of expatriation now is less than the expected future cost of expatriation. Better to take the medicine now rather than later. … Expect the same exit tax rules, but more of them, and worse. Expect more expatriations. … Get out while the getting is semi-good. Don’t wait for more time. More time means more laws.”
 

Written by usxcanada

5 June 2012 at 6:00 am

Posted in Legal, Uncategorized

2012 June 1 – Christianson

 
David Christianson
U.S. citizens living here: do your tax duty
Winnipeg Free Press (1 June 2012)

http://www.winnipegfreepress.com/business/us-citizens-living-here-do-your-tax-duty-156202125.html

This partial and uneven article contains some information, but the primary purpose seems to be to scare unwary readers into expensive knee-jerk compliance and thus to provide even more income for “professional” advisors.
 

Written by usxcanada

1 June 2012 at 7:00 am

2012 June 1 – Poe

 
Curtis Poe
1997 renunciation data anomaly explained
Overseas Exile [blog] (1 June 2012)

http://www.overseas-exile.com/2012/06/1997-renunciation-data-anomaly.html

Data for US citizenship renunciation 1991-2011 is graphed, and the nature and sources and anomalies of the data described.
 

Written by usxcanada

1 June 2012 at 6:00 am