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Archive for March 2013

2013 Mar 19 – Marino

Alexander Marino
Renouncing your U.S. citizenship: Is divorcing Uncle Sam right for you?
Moodys Tax Advisors (19 Mar 2013)


[40 footnotes] This summary of renunciation considerations pulls together a variety of aspects and is worth a read. Bear in mind that the writer and his outfit want to generate revenue from “assisting” you. Once the tax aspects are understood, the process of obtaining severance from the United States usually should not require “professional” services. Cast a cautious and jaundiced eye on the listing of US citizenship “benefits” in Section B. The only one of substance seems to be (d), the dubious “freedom” to seek employment in the United States.

Written by usxcanada

19 March 2013 at 6:00 am

Posted in Legal, Uncategorized

2013 Mar 12 – Whiteley

Don Whiteley
Compliance with U.S. tax law may violate Charter of Rights
Vancouver Sun (12 Mar 2013)


Peter Hogg, “Canada’s leading constitutional legal expert,” is saying that negotiations on FATCA “risks major violations of Canada’s Charter of Rights and Freedoms.” A five-page letter to the Finance Department details the unavoidability of discrimination based on “national or ethnic origin.”

Written by usxcanada

12 March 2013 at 6:00 am

2013 Mar 8 – Shecter

Barbara Shecter
TFSAs a new tax risk for Americans living in Canada?
Financial Post (8 Mar 2013)


Canadian tax lawyer Dick Pound has just published Tax Guide for American Citizens in Canada. An attempt to have the IRS clarify on “intended tax treatment for TFSAs” brought no response. It seems likely that TFSA income would result in a taxation mismatch for Canada-resident U.S. persons.

Written by usxcanada

8 March 2013 at 6:00 am

2013 Mar 7 – Novack

Janet Novack
IRS yanks criminal amnesty deal from taxpayers with secret Bank Leumi accounts
Forbes (7 Mar 2013)


Dozens of Americans with undisclosed accounts at Bank Leumi have “upon further review” been disqualified from participation in the IRS offshore disclosure program. Bank Leumi has announced that it will take a charge of $91 million to cover “investigations that are being conducted by the U.S. authorities concerning customers who are U.S. taxpayers.”

Written by usxcanada

7 March 2013 at 7:00 am

2013 Mar 7 – Temple-West

Patrick Temple-West / Kim Dixon
U.S. IRS boots Israeli bank clients from amnesty program — lawyers
Reuters UK (7 Mar 2013)


In multiple cases, the IRS has “disqualified” clients of Israeli banks who were participating in the “offshore disclosure” program.

Written by usxcanada

7 March 2013 at 6:00 am

2013 Mar 6 – Saunders

Laura Saunders
Offshore tax probe picks up
Wall Street Journal (6 Mar 2013)


Print: (7 Mar 2013) C1

In the past four years, US officials have derived $5.5 billion in taxes and penalties from offshore accounts of 38,000 persons. Pursuit is widening from first two Swiss banks to other Swiss banks, HSBC, and Israeli banks. Nine countries have signed or initialed FATCA agreements, and 40 others are in negotiations. It is unlikely that China will comply.

Written by usxcanada

6 March 2013 at 6:00 am

2013 Mar 2 – Barrett

David Barrett
Americans renouncing citizenship to become British thanks to tax rise
Telegraph (2 Mar 2013)


Two specialist lawyers in London “report a threefold increase over the last five year in the number of American citizens who are giving up their citizenship.” Costs for five years of filing and immigration paperwork can add up to £7500.

Written by usxcanada

2 March 2013 at 6:00 am

2013 Mar # – Miller

Michael J. Miller / Ellen S. Brody
Expats live in fear of malevolent time machine
International Tax Journal (March 2013?)


This article reviews how US citizenship may be lost; outlines expatriation rules set out in key legislation of 1966, 1996, 2004, and 2008; and explores implications of a 2003 document issued by Joint Committee on Taxation. In view of the absurdities generated by “a poorly drafted statute,” the authors call on the IRS to issue clarifying written guidance. [23 endnotes]

Written by usxcanada

1 March 2013 at 6:00 am

Posted in Academic, Uncategorized