Tag Archives: FATCA

The Government of Canada: Toward a #FATCA IGA – Mass renunciation as a solution

There are risks and cost to a program of action. But they are far less than the risks and costs of comfortable inaction. – John F. Kennedy

I always love the song “One Tin Soldier” by the Original Caste (which incidentally was a Canadian band). The article describing the song notes that:

“One Tin Soldier” tells the abstract story of a hidden treasure and two neighboring peoples, the Mountain People (portrayed as peaceful) and the Valley People (portrayed as warlike).

The Mountain People possess a treasure on the mountain, buried under a stone. The Valley People send a message to the Mountain People demanding it.

The Mountain People reply with an offer: they are willing to share the treasure with the Valley People. However, the Valley People instead decided to take it all by force, and in doing so kill all the Mountain People. The Valley People then move the stone and find only a simple message: “Peace on Earth“.

There is an analogy here: Canada = “The Mountain People” and the United States = “The Valley People”

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ACA on #FATCA and Citizenship-based taxation

 

 

Grover Norquist and Dan Mitchell argue for territorial taxation – “IRS Discount” associated with U.S. entities or persons

Introduction – Territorial vs. Worldwide Taxation or Global Taxation – It’s becoming topical!

July 15, 2012 – the Financial Times ran a front page article called “China eases taxes for foreign companies” The article included the following:

China will cut taxes on the profits that foreign companies take out of the country by up to 50 per cent after rules on withholding taxes were relaxed to encourage more overseas investment.

The move will also apply to dividends paid by Chinese listed companies to foreign shareholders through the Qualified Foreign Institutional Investor scheme . In both cases, the lower tax rates will apply only to companies and shareholders based in countries, such as the UK, that have double taxation agreements with China.

The changes could save companies billions of dollars worth of tax payments, which might initially lead them to repatriate more profits, but ultimately should provide incentives for more investments, according to experts at KPMG. US companies, however, cannot benefit as they are taxed on a global basis by US authorities. Continue reading

June 18, 2012 – The Trojan Horse, U.S. citizenship-based taxation, and other less expensive ways to wage war

“War is failure”
- Once heard Colin Powell requote this truism

Today is an important day in Canadian History. Exactly 200 years ago today, the United States under President Madison attacked what was then British North America. The outcome of the war depends on which country’s historians you listen to. But what is clear is that – after three years, the United States failed in its military invasion of it’s British neighbour to the North.  In other words U.S. expansion stopped at the 49th parallel – making the existence of Canada possible. Continue reading

U.S. Narcissism and it’s impact on the sovereignty of other nations – Introduction

Hot off the press from Phil Hodgen!! – Is this what one would expect from a narcissist?

The Internal Revenue Code uses the word “expatriate” to specifically refer to someone who goes through a process of terminating U.S. citizenship or permanent resident status. This is what you will find in Sections 877 and 877A of the Internal Revenue Code. Yes, it is a lazy and ego-centric way for the U.S. government to approach the world: “A word means only what we say it means.”

 

 

 

In an early post: Nationalistic Narcissism and U.S. citizenship – Being a U.S. citizen is like having a narcissist for a parent – I suggested  that the United States is a narcissist. On the most minimal level, narcissism includes the belief that everything and everybody should revolve around the narcissist. Anybody who has ever known a narcissist knows that narcissists do not recognize personal boundaries. To put it another way, a narcissist sees everybody as an extension of the narcissist – i.e cannot accept that other people are autonomous individuals. Although I am not suggesting that Wikipedia is extremely authoritative, I note the following comment: Continue reading

FATCA and employment for U.S. citizens abroad

Here is a comment on an earlier post I wrote:

The IRS should be made to answer certain questions before FATCA can be enacted. Here are just a few. Other readers please add more.

1) How many Americans are affected by FATCA?
2) How many of them do the IRS consider to be criminals?
3) If there is no change in the behavior of American citizens how much extra tax will FATCA generate?
4) What percentage of Americans change their behavior if FATCA is enacted to reduce their taxes?
5) How many FFI are there in the world?
6) What is the total cost born by the FFIs to become compliant, and the annual cost thereafter?
7) How many FFIs will choose not to do business with Americans living abroad, just terminate their accounts?

In business we have failure criteria. The IRS must make a statement in advance that FATCA will be considered a failure if it fails to raise a defined amount of new taxes. Considered a failure if a certain percentage of FFIs withdraw funds from the US rather than bear the cost of compliance. Etc. etc.

For our company we are sending all the ex-pat Americans home to the US. For one reason only. FATCA.

What “Form Nation” does to U.S. citizens living outside the United States

I came across a great post which I tweeted:

I then left the author the following comment:

Hello:

Found you from a pingback on an article I wrote.

A very well done article. Thought I would spread the word a bit:

https://twitter.com/USCitizenAbroad/status/210362763225202689

See that you have an interest in human rights. Here is a post that I
wrote a while ago:

Do you think that the U.S. practice of citizenship-based taxation is in 
 violation of International law?

Could citizenship-based taxation evolve into a crime against humanity?

U.S. citizens abroad are suffering and being forced to 
renounce U.S. citizenship as defensive measure.

“Hitching a ride” – FATCA – The Trojan Horse of the Hire Act – Updated with Roger Conklin comment

Hitching A Ride – Is A “Trojan Horse” Provision Legitimate?

 

 

In order for legislation to have “moral force”, it should at a minimum:

1. Be read by legislators prior to it becoming law; and

2. Not contain provisions that are unrelated to the main purpose of the legislation – i.e. NOT “hitch a ride”

“Hitching a ride”** is especially easy if the Congressmen don’t read the legislation.  Nancy Pelosi commenting in relation to Obamacare, noted that it was important for Congress to pass the bill, so that the American people (and presumably Congress) could learn what was in it.

FATCA is unrelated to the  purpose of the HIRE Act. It simply “hitched a ride” into the Hire Act. Who knows how many Congressmen read and understood the Hire Act prior to voting in favor of it? Provisions that “hitch a ride” into legislation are analagous to  soldiers left inside a Trojan Horse*. Once the primary legislation takes effect, the “hitchhiker provisions” will be unleashed on an unsuspecting public.

FATCA has been referred to as the “neutron bomb” of international finance. It is the most dangerous act of American Imperialism ever.  It will  hasten the demise of the U.S. as a world power. Continue reading

Citizenship renunciations soar under Obama – Renouncing As An Act Of Self Defense

To Be, Or Not To Be: That Is The Question: – Whether tis nobler in the mind to suffer The slings and arrows of outrageous fortune … Continue reading