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Archive for July 2013

2013 July 22 – Residence

Residence-based taxation? Interview with Bill Yates
Angloinfo (22 July 2013)


This Part II (see 1 July 2013 for Part I) interview by Virginia La Torre Jeker with former high-level IRS employee Bill Yates demonstrates that U.S. persons resident abroad have little good to hope for. “The Treasury and IRS have too much invested in FATCA to turn back now. … FATCA is inevitable.” Form 8938 was seen by even its drafters as nothing anyone would want to have to fill out.

Written by usxcanada

22 July 2013 at 6:00 am

2013 July 4 – Marino

Alexander Marino
Renouncing your US citizenship: failed amendment may signal that now is the time to get out!
Moodys Gartner (4 July 2013)


14 footnotes. Recent failed legislative attempt to bar “covered” expatriates from entering the United States indicates that “the issue of renouncing one’s US citizenship is again front and center on Congress’s radar and the only guarantee moving forward is that any potential changes will not make things any easier to get out.”

Written by usxcanada

4 July 2013 at 6:00 am

2013 July 2 – Curry

Bill Curry
Privacy debate looms as Canada prepares to share bank data with U.S.
Globe and Mail (2 July 2013)


“Canada and the U.S. are negotiating whether Ottawa or the financial institutions will send the information” that the U.S. seeks to collect from Canada under FATCA implementation.

Written by usxcanada

2 July 2013 at 7:00 am

2013 July 2 – Roseman

Ellen Roseman
Man gets relief from tax debt he didn’t owe: Roseman
TheStar.com (2 July 2013)


David Gauci worked in the United States 1999-2003. CRA compounded an error made by IRS and was garnishing much of Gauci’s income for unwarranted interest and penalties.

Written by usxcanada

2 July 2013 at 6:00 am

2013 July 1 – FATCA

FATCA interview with Bill Yates
Angloinfo (1 July 2013)


This Part I (see 22 July 2013 for Part II) interview by Virginia La Torre Jeker with former high-level IRS employee Bill Yates reveals insider perspective on IRS development of Form 8938.

Section 6038D was enacted in order to put the kind of foreign bank account reporting required by Form 90-22.1, Foreign Bank Account Report (FBAR), under Title 26, the Internal Revenue Code. FBAR reporting is required pursuant Title 31, the Bank Secrecy Act. Because of this, IRS could not initiate an audit of a taxpayer based solely on an FBAR filing. The taxpayer being examined had to have an underlying Title 26 issue. Only with a Title 26 issue could IRS use account information found on an FBAR in furtherance of an audit or exam of the taxpayer. Hence, Congress gave IRS section 6038D, Title 26 of the Internal Revenue Code. In short, Congress gave IRS its own FBAR.

Written by usxcanada

1 July 2013 at 7:00 am

2013 July 1 – Waltersperger

Laurina Waltersperger
Amerikanische Bürger: Herkunft als Hürde
Handelszeitung (1 July 2013)


“Laut Schätzungen der ­amerikanischen Gemeinschaft haben letztes Jahr 700 bis 900 US-Bürger in der Schweiz ihren Pass abgegeben. Die Botschaft in Bern will diese Zahl nicht kommentieren.”

Written by usxcanada

1 July 2013 at 6:00 am