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Archive for October 2012

2012 Oct 26 – Lee

Justin Lee
FATCA delay simply “smoke and mirrors”
Risk.net (26 Oct 2012)


One representative from a major Hong Kong accounting firm notes that recently announced start date delays leave “the timetable for imposing penalties for non-compliance … relatively unchanged.” Another representative from another firm sees the US as only shifting gears: “Charles Kinsley, tax principal at KPMG in Hong Kong, views the delay as a result of the IRS looking to frame agreements at country level, rather than with FFIs.”

Written by usxcanada

26 October 2012 at 7:00 am

2012 Oct 26 – More

More Americans give up passports over tax
swissinfo.ch (26 Oct 2012)


“The US embassy to Switzerland told swissinfo.ch that it had processed 411 renunciations in the first nine months of this year. This compares to 180 Americans giving up their passports in 2011.” On a monthly basis, therefore, the rate has tripled from 2011 to 2012.

Written by usxcanada

26 October 2012 at 6:00 am

2012 Oct 24 – U.S. IRS

U.S. IRS delays key start dates for global tax evasion law
Reuters US (24 Oct 2012)


Foreign financial institutions now have an additional year (start date 1 Jan 2014) “to have procedures in place to meet FATCA reporting requirements.” Withholding of U.S. tax from clients’ investment gains is moved forward two years to 1 Jan 2017.

Written by usxcanada

24 October 2012 at 6:00 am

2012 Oct 19 – Greil

Anita Greil
Wary Swiss banks shun Yanks
Wall Street Journal (19 Oct 2012)


“In Switzerland, banks are scouring their client lists and dividing clients into Americans, possible Americans and those who aren’t, according to Thomas Brotzer, a Zurich-based tax partner at Ernst & Young.” The article includes personal stories of two Swiss residents, one having renounced U.S. citizenship and the other “seriously considering” taking the same step.

Written by usxcanada

19 October 2012 at 6:00 am

2012 Oct 14 – Chen

Lulu Chen
Tax bills prompt Chinese to ditch US passports
South China Morning Post (14 Oct 2012)


“Many wealthy people are deterred from giving up their citizenship halfway through the process when they learn the IRS will inspect their income globally looking for evidence of tax evasion, said Timmas Deng, a Hong Kong lawyer who specialises in immigration.” Deng says the renunciation process typically takes one to two years, and fees for legal advice can run up to US$30,000. The story of a 31-year-old housewife identified as Wu is provided as illustration.

Written by usxcanada

14 October 2012 at 6:00 am

2012 Oct 7 – Berg

Roy A. Berg
Do not get out of IRS’s tax amnesty programs without knowing the facts
Moodys Tax Advisors (7 Oct 2012)


The relationship of existing voluntary disclosure programs to “the new streamlined procedure” is explored at length.

Written by usxcanada

7 October 2012 at 6:00 am

Posted in Legal, Uncategorized

2012 Oct 5 – Whiteley

Don Whiteley
U.S. tax laws: the long arm of Uncle Sam
B.C. Business (5 Oct 2012)


This is the first general-interest article in a Canadian publication to dig into what FATCA means for Canadian banks and credit unions who must also comply with Canadian privacy legislation. The story is personalized with an account of the difficulties encountered by B.C. resident Maury Williams. “The number of expatriate U.S. citizens renouncing their citizenship, while still very small, is growing rapidly. Lawyer [Ron] Zisman confirms that his business is booming and traffic at the Vancouver consulate is getting higher.”

Written by usxcanada

5 October 2012 at 6:00 am

2012 Oct 2 – Baker&McKenzie

Baker&McKenzie-Anwalt gibt seinen US-Pass ab
Inside Paradeplatz (2 Oct 2012)


Marnin Michaels, a leading Zurich-based lawyer dealing with U.S. taxation issues, is in the process of terminating his U.S. citizenship — and refuses to make public comment on his action. “Nächsten Januar gibt Michaels nämlich seinen US-Pass zurück. Das bestätigen mehrere Quellen unabhängig voneinander. … Michaels wollte gestern am Telefon keine Stellung zu seiner Passrückgabe nehmen.”

Written by usxcanada

2 October 2012 at 6:00 am

2012 Oct 1 – Schneider

Bernard Schneider
The end of taxation without end: a new tax regime for U.S. expatriates
Virginia Tax Review 32:1 (1 Oct 2012) 1-76


Among other things, this comprehensive article with 392 footnotes will serve as a bibliography to previous literature on the topic. Schneider concludes that the obvious resolution, cessation of extraterritorial taxation of U.S. person, is not “politically viable,” and then moves to propose an exit tax. Review of the existing situation covers (1) history of citizenship-based taxation (2) numbers of persons affected and tax involved (3) types of expatriates (4) current tax treatment of nonresidents (5) increasing compliance cost of being a U.S. taxpayer abroad (6) arguments for and against worldwide taxation of expatriates (7) compliance and enforcement (8) current exit tax regime.

Written by usxcanada

1 October 2012 at 6:00 am