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Archive for July 2012

2012 July 31 – Wood

Robert W. Wood
IRS streamlines foreign account amnesty
Forbes (31 July 2012)


Wood speculates on new IRS procedures, and relays views obtained from an Agent. “But details are scant.”

Written by usxcanada

31 July 2012 at 6:00 am

2012 July 27 – Saunders

Laura Saunders
U.S.: Taxpayers who renounced citizenship fell sharply
Wall Street Journal (27 July 2012)


Print: Renunciations by U.S. citizens fall (30 July 2012) C3

“The number of Americans renouncing their citizenship fell sharply in the second quarter, to 189 from 520 for the same period in 2011. … The sharp decrease in the second quarter took some experts by surprise.” It is astonishing that “experts” would accord that dubious data source such a degree of credibility.

Written by usxcanada

27 July 2012 at 6:00 am

2012 July 16 – McGurn

William McGurn
Obama’s IRS snoops abroad
Wall Street Journal (16 July 2012)


FATCA seems to be “only the first step toward an IRS that will be far more expansive, aggressive and intrusive than most Americans can imagine. … In a paper called Leveling the Playing Field, the White House says ‘the IRS will hire nearly 800 new employees devoted to international enforcement’.”

Written by usxcanada

16 July 2012 at 6:00 am

2012 July 10 – Steyn

Mark Steyn
Re Re: Goodbye and good luck
National Review Online (10 July 2012)


A conservative reviews the notion of US taxation of nonresident citizens and concludes: “U.S. tax law makes U.S. citizens second-class citizens in their own country.”

Written by usxcanada

10 July 2012 at 6:00 am

2012 July 9 – Mopsick

Steven J. Mopsick
Tax justice for Americans abroad
Tax Notes (9 July 2012) 189-196


A federal tax attorney with long experience within the IRS details the problems currently faced by U.S. persons living outside the United States. He usefully categorizes the options — “few good”! — available to “those with reasonable cause arguments” and reduces them from an apparent six to three that he sees as “realistically viable.” He illustrates difficulties with a substantial hypothetical case study of an extended family that has generations of history in Vancouver, British Columbia. “Responsible people in the government must see the absurdity of how citizenship-based taxation affects expatriates and the bizarre fact that the United States is the only country that taxes its citizens on their worldwide income.” Mopsick proposes a “facts and circumstances test” as a potentially useful “commensense approach” (p. 193), but irrationally persists in privileging the fact of birth abroad in designating persons who have had “no meaningful economic connection to the United States” over a period of many years. [14 footnotes]

Written by usxcanada

9 July 2012 at 6:00 am

2012 July 3 – Krishna

Vern Krishna
An unnecessary overreaching of U.S. tax law into Canada
Financial Post (3 July 2012)


A Canadian tax lawyer offers a commendably critical assessment of recent moves by U.S. taxation and reporting authorities. “In light of the galloping U.S. deficit, however, the IRS has awakened and is hunting for tax dollars under every rock to finance its government’s profligate spending. Canadian-Americans are now in the IRS’s headlights.” The article touches on the nature of U.S. taxation, the border-passport factor, the uncertainty of “reasonable cause,” the latest IRS policy adjustment, the implementation of FATCA, and the convolutions of citizenship renunciation.

Written by usxcanada

3 July 2012 at 6:00 am

2012 July 2 – Knowlton

Brian Knowlton
Pentagon reverses course on American voters living abroad
New York Times (2 July 2012)


“The Pentagon agency responsible for overseas voting has agreed not to enforce a requirement for voters requesting absentee ballots to state categorically that they either intend to stay abroad indefinitely or not.” The article also mentions the recent additional IRS pronouncements on tax and information filing by extraterritorial US persons.

Print version: International Herald Tribune (3 July 2012)

Written by usxcanada

2 July 2012 at 6:00 am

2012 July 1 – Marlin

Megan Marlin / Kevin Curran
Homeland Security may contact U.S. persons living abroad who owe back taxes
Tax Adviser (1 July 2012)


“A U.S. or non-U.S. person whom the IRS has been unable to contact may be unaware of an assessed but unpaid federal tax liability until the person goes through U.S. Customs and is detained by Immigration and Customs Enforcement.”

Written by usxcanada

1 July 2012 at 6:00 am

Posted in Legal, Uncategorized