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Archive for September 2012

2012 Sept 11 – UBS

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


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.”

Written by usxcanada

11 September 2012 at 7:00 am

2012 Sept 11 – Wood

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


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

Written by usxcanada

11 September 2012 at 6:00 am

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)


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.”

Written by usxcanada

7 September 2012 at 6:00 am

Posted in Legal, Uncategorized

2012 Sept 4 – Ritchie

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


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.”

Written by usxcanada

4 September 2012 at 6:00 am

2012 Sept 1 – Chisti

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


“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.”

Written by usxcanada

1 September 2012 at 8:00 am

Posted in Academic, Uncategorized

2012 Sept 1 – Townsend

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


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).

Written by usxcanada

1 September 2012 at 7:00 am

Posted in Legal, Uncategorized

2012 Sept 1 – Wood

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


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.”

Written by usxcanada

1 September 2012 at 6:00 am