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Archive for January 2013

2013 Jan 31 – Townsend

Jack Townsend
Warnings on continued government patience for offshore account ostriches
Federal Tax Crimes (31 Jan 2013)


Townsend extracts from and comments on an article from Tax Notes Today which reports that Kathy Keneally (Assistant Attorney General for the Tax Division) “has warned that amnesty for offshore account evasion will not last forever. … Persons with offshore accounts who continue their noncompliance are indeed dumb.”

Written by usxcanada

31 January 2013 at 7:00 am

2013 Jan 31 – Bachmann

Helena Bachmann
Mister Taxman: why some Americans working abroad are ditching their citizenships
Time World (31 Jan 2013)


Tina Turner’s recent abandonment of U.S. citizenship sets the stage for this article. The sharp increase in renunciation is foregrounded. FATCA gets two paragraphs. Aspects of individual stories are provided for three individuals who have already made the news: Peter Dunn in Canada, Genette Eysselinck in France, Amy Webster in Switzerland.

Written by usxcanada

31 January 2013 at 6:00 am

2013 Jan 29 – Wallace

Ellen Wallace
Packing up, going home: one US citizen in Switzerland vents his anger
Geneva Lunch (29 Jan 2013)


Swiss resident William Olenik publishes an email about his plan to move back to the United States because of the untenable status being imposed on U.S. persons living abroad. Comment — Olenik reaps the harvest of this bonehead attitude: “I refuse to give up my citizenship, as I am 100% American, to my bone marrow.” It sounds like he really does belong back in the homeland.

Written by usxcanada

29 January 2013 at 6:00 am

2013 Jan 28 – Feldman

Amy Feldman
The perils of overseas tax disclosure: an immigrant’s story
Reuters U.S. (28 Jan 2013)


Andrew Winfield, a British immigrant to the United States, entered OVDI 2011, filed amended returns for 2003-2010 to cover foreign accounts, paid an additional $2800 in tax, and now faces FBAR penalties of $28,000. According to Feldman, there are “some 39 million immigrants in the United States.” Annual FBAR filing is said to run at a level of 500,000.

Written by usxcanada

28 January 2013 at 6:00 am

2013 Jan 25 – Allentuck

Andrew Allentuck
Dual Canadian-U.S. citizens can conquer tax challenges
Financial Post (25 Jan 2013)


A Toronto family with income of up to $218,000 per year is said to face no serious problems in remaining compliant with two tax systems. The fatuous closing sentence says of the primary wage earner: “In the end, careful observance of rules of both countries will keep his tax bill to no more than what it would be in Canada without exposure to American taxes.” RESPs are mentioned, but not the excessively burdensome and expensive reporting requirements. Despite the couple’s intention to remain in Canada, no mention is made of their perhaps considering renunciation of U.S. citizenship.

Written by usxcanada

25 January 2013 at 6:00 am

2013 Jan 20 – Christians

Allison Christians
Why FATCA is a tax treaty override
Tax, Society & Culture (20 Jan 2013)


“FATCA overrides the existing [Canada-U.S.] tax treaty by significantly limiting a material benefit thereunder, and the only valid way to fix that override is to change the treaty itself, by entering into a new protocol.”

Written by usxcanada

20 January 2013 at 6:00 am

Posted in Legal, Uncategorized

2013 Jan 17 – Cohn

Michael Cohn
Treasury releases final FATCA regulations to fight offshore tax evasion
Accounting Today (17 Jan 2013)


“A long-awaited set of final regulations [will have] far-reaching implications for U.S.-born taxpayers abroad.” Much of this article seems to embed the Treasury/IRS press release, with added history and context.

Written by usxcanada

17 January 2013 at 8:00 am