2012 Sept 30 – Kaiser

 
Mike Kaiser
What taxes taught me about the power of the asterisk
Globe and Mail (30 Sept 2012)

http://www.theglobeandmail.com/life/facts-and-arguments/what-taxes-taught-me-about-the-power-of-the-asterisk/article4574698/

Essay by ill-advised “US person” in Canada who goes through hell to obtain Social Security number in order to enter second hell of filing tax paperwork.
 

2012 Sept 27 – Hinchberger

 
Bill Hinchberger
European banks shut Americans out over U.S. tax rules
USA Today (27 Sept 2012)

http://usatoday30.usatoday.com/money/business/story/2012/09/27/european-banks-oust-americans/57849014/1

“FBAR and FATCA seem to be tipping points,” says Mike Heimos, an American attorney based in Uruguay who specializes in cross-border issues.”
 

2012 Sept 21 – Christianson

 
David Christianson
Taxing move could end “quiet disclosure”
Winnipeg Free Press (21 Sept 2012)

http://www.winnipegfreepress.com/business/taxing-move-could-end-quiet-disclosure-170641656.html

Comment is based on attendance at a recent presentation “put on by Terry Ritchie, whom I consider to be the best-informed adviser in Canada on such matters. … A harsh reality is the IRS is getting more sophisticated and aggressive in going after the billions in taxes that are unpaid by U.S. citizens.” Christianson seems to believe that the 31 August 2012 IRS guidelines in some sense signal the end of quiet disclosure.
 

2012 Sept 20 – Jordan

 
Ruth Jordan
Uncle Sam unleashes tax hounds to hunt a Canadian citizen [featured letter]
Edmonton Journal (20 Sept 2012)

http://www.edmontonjournal.com/business/Featured+letter+Uncle+unleashes+hounds+hunt+Canadian+citizen/7275320/story.html

A Canadian-born woman in Edmonton reports filing a 2011 US tax return after about 20 years of non-compliance as a returned-to-Canada resident, and then receiving a no-detail IRS demand for immediate payment of $2,616.95 US. One factor was denial of claim for 14-year-old daughter as dependent.
 

2012 Sept 19 – Houlder

 
Vanessa Houlder
US tax net closes on Americans living in Britain
Financial Times (19 Sept 2012)

http://www.ft.com/cms/s/0/c2b09b66-0272-11e2-9e53-00144feabdc0.html

“Banks will have to identify all their US customers by 2015.” Advisory costs for an individual to come into tax compliance with the US can reach £20,000 to £30,000. One tax accountant reports a five-fold increase in that portion of their business.
 

2012 Sept 18 – Temple-West

 
Patrick Temple-West
Overseas tax dragnet refocuses on country partnerships
Reuters US (18 Sept 2012)

http://www.reuters.com/article/2012/09/18/us-usa-tax-facta-idUSBRE88H15X20120918

“The UK on Friday became the first country to finalize a tax information-sharing pact with the United States under FATCA.”
 

2012 Sept 17 – Schmid

 
Valentin Schmid
Swiss banks stand to lose hundreds of billions
Epoch Times (17 Sept 2012)

http://www.theepochtimes.com/n2/business/swiss-banks-stand-to-lose-hundreds-of-billions-293340.html

“U.S. citizens will face repercussions, as banks worldwide will deem it too expensive to cater to U.S. clients due to the high regulatory costs.”
 

2012 Sept 11 – UBS

 
UBS whistleblower gets $104M from IRS
CBCNews (11 Sept 2012)

http://www.cbc.ca/news/business/story/2012/09/11/birkenfeld-award.html

The IRS announces payment of $104 million to a former Swiss banker who whistleblew. “The Canada Revenue Agency is also investigating how much undeclared income is being held in offshore bank accounts by those who owe on Canadian taxes.”
 

2012 Sept 11 – Wood

 
Robert W. Wood
Got IRS amnesty lite?
Forbes (11 Sept 2012)

http://www.forbes.com/sites/robertwood/2012/09/11/got-irs-amnesty-lite/

Regarding the 31 August 2012 IRS Instructions for noncompliant extraterritorial U.S. persons, Wood concludes: “Obviously, most people don’t qualify.”
 

2012 Sept 7 – Berg

 
Roy A. Berg / James Gifford
Do you qualify for IRS’s new streamlined procedure to bring US tax returns current?
Moodys Tax Advisors (7 Sept 2012)

http://www.moodystax.com/moodystax-blog/21-us-taxation-services/202-do-you-qualify-for-irss-new-streamlined-procedure-to-bring-us-tax-returns-current.html

Extensive analysis of the IRS instructions of 31 August 2012 leads to this basic conclusion: “There is great uncertainty as to who will qualify for the procedure and the questions asked in the questionnaire pose serious risks to the uninformed taxpayer.”
 

2012 Sept 4 – Ritchie

 
Terry F. Ritchie
IRS issues guidelines for tax compliance
Advisor.ca (4 Sept 2012)

http://www.advisor.ca/tax/tax-news/irs-issues-guidelines-for-tax-compliance-88702

This review of the 31 August 2012 IRS guidelines concludes with the following speculation: “In all, it appears the days of quiet disclosure with respect to the past filing of US tax returns are over. … It would appear the eyes of the IRS will look closely at each submission for opportunities to poke and prod a little more. … The days of cutting corners and keeping your head in the sand will soon [Jan 2014] be coming to a close.”
 

2012 Sept 1 – Chisti

 
Muzaffar Chisti / Faye Hipsman
Renouncing US citizenship: a new trend?
Migration Information Source (Sept 2012)

http://www.migrationinformation.org/Feature/display.cfm?ID=905

“The trend of [increasing] citizenship renunciation is evident. … Many lawyers and interest groups who represent US expatriates believe that the combination of the scaled-up IRS enforcement and legislative and regulatory changes are providing the impetus for increased renunciation of US citizenship.”
 

2012 Sept 1 – Townsend

 
Jack Townsend
IRS instructions for streamlined procedure for U.S. nonresidents
Federal Tax Crimes [blog] (1 Sept 2012)

http://federaltaxcrimes.blogspot.ca/2012/09/irs-instructions-for-streamlined.html

Lawyer Jack Townsend’s relative brief and well-informed comment sees the newly announced IRS provisions for US nonresidents as likely to find very limited take-up because of compliance cost and unresolved applicant uncertainty. One category that may benefit are otherwise compliant Canadian residents who wish to rectify previous Form 8891 noncompliance (RRSP treaty election to defer income).
 

2012 Sept 1 – Wood

 
Robert W. Wood
Newest Offshore IRS Amnesty Not for Everyone
Forbes (1 Sept 2012)

http://www.forbes.com/sites/robertwood/2012/09/01/newest-offshore-irs-amnesty-not-for-everyone/

Wood provides a basic summary with relevant links, focusing most attention on uncertainties surrounding what constitutes low risk. Nine disqualifications are itemized. “If you make a submission but are judged to be high risk, you don’t qualify and will be examined.”
 

2012 Sept # – Stiller

 
Martin Stiller
Statelessness in international law: a historic overview
DAJV Newsletter 37:3 (Sept 2012) 94-99

http://www.dajv.de/aktuelles-reader/items/online-zugriff-auf-alle-dajv-newsletter.html

[99 footnotes] This article includes the following distinction between nationality and citizenship: “At the international level, the concept of nationality is the only important criterion constituting an international affiliation between individual and state. It should be noted that the question of citizenship does not bear on the issue, as citizenship is only a qualified status of nationality, a status designed to confer rights – mostly political – to the citizen.” (II.1, page 95)