Monthly Archives: June 2012

Something new (maybe) from the IRS for taxpayers residing outside the U.S. and who have NOT been filing tax returns and FBARs

Whatever this means was announced on June 26, 2012 under the title of New Filing Compliance Procedures for Non-Resident U.S. Taxpayers. Those interested in this topic should check back frequently for more specifics. The specifics should be available no later than September 1, 2012. I am certain that the “cross border professionals” will say that this is “nothing new”. After all the statute of limitations for FBARs is six years. This is a message from the IRS and therefore it needs to be read carefully. It also needs to be read in the context of:

1. OVDI – You are all criminals

2. The December 2011 FS – well maybe “reasonable cause” does really exist

3. Voluntary disclosure in general – always been there anway

You can be sure that the IRS chooses its words carefully. Therefore, we must read the words of the IRS carefully. 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

Use this election to draw awareness to the unfairness of U.S. citizenship-based taxation


Here is a comment I made to my own post at the Isaac Brock Society – Yes we can!! – Change we can believe in – Organizing the community of U.S. citizens abroad – One community at a time! This is my attempt to explain why I see the election as an opportunity to begin a public discussion about citizenship-based taxation and the problems of U.S. ExPat Compliance. The complexity of U.S. tax and information return compliance is causing people to renounce U.S. citizenship.



Thanks for all the great thoughts/comments. With the greatest respect to all, I would like to express my view that the real issue is:

That the election is the only forum that we have to educate Obama and Romney. It is the only opportunity we have to get this issue on the table. I agree it is hard. I agree that expats are not liked. I agree that it is frustrating. But, is the only chance we have.

Now, as I am sure you have figured out, I have a very low opinion of Obama. But, that is not even the issue. Nor is the issue whether Romney would be better. The approach – they are both bad candidates, – so who cares is off the mark.

Because Obama is the President and because he has been the architect of so much misery: I remind you again that our problems fall squarely on his administration. This is the first administration that has launched a public and frightening assault on U.S. citizens abroad. Obama is 100% accountable for this – he controls, Geithner, the IRS, etc.

The problem is that we have not and will not (in the general scheme of things) be heard. We have no voice. Not even ACA (in spite of all it’s great work) has been able to make even one bit of difference to the government. They have done a good job of educating expats and we owe them a great debt for this remarkable achievement.

The only – and I repeat only – weapon at our disposable is the fact that this is an election year. This means far more than that we can vote. It means that we can get this issue on the table. It means that Obama will be under the microscope. He himself (with all his social media stuff) has opened up channels of communication. The goal is to get citizenship-based taxation and the gross unfairness that results from it on the radar. In a practical sense this can be done in at least two ways both of which should be done at the same time and with equal conviction.

1. Attack all things Obama – keep the attacks coming and coming – every tweet of lies that his people send should be replied to and questioned. The only thing that Obama understands is votes.

2. Support Mitt Romney – Even if you don’t like Romney (and I can see that most of you don’t) the principle is simple: “The enemy of my enemy is my friend.” Let’s get some organized support. Let’s make that phone call. For God’s sake let’s try.

It is no more complicated than that. We must use the fact of this election to use the only opportunity we have to GET THE ISSUE OF CITIZENSHIP-BASED TAXATION ON THE RADAR!

Attacking Obama and supporting Romney is the only way to do this.

Therefore, with the greatest respect, to consider this question is terms of “Well, I don’t Romney or Romney is no better” or something like that is (IMHO) irrelevant and misguided.

What we do know about Obama is that all the world is political stage. If he perceives the negativity from this as a problem that could gather momentum, I believe he is likely to respond. Now, holding Obama to a promise may be difficult. His website “promises kept” is the greatest Freudian slip of all time.

What we know about Romney is that he needs to get votes and support from all places. If he perceives this as an issue that could generate votes for him he will respond.

Let me try this another way: We need to use the election to create conditions so that these people will see that ignoring U.S. citizens abroad will be costly to them.

Although I have always had a low opinion of Obama (he is nothing but a media creation) and a fairly high opinion of Romney (hey at least he has accomplishments), at the end of the day:

They are responsive only to votes. It is this fact that we must take advantage of.

So, for those of you who are thinking:

1. Who cares, Romney is no better; or

2. Well, I can’t make a difference anyway

You have surrendered the battle. And that is of course your right. But, you have spent a lot of time suffering from oppression and persecution, you continue to be treated unjustly. You have nothing to lose by simply transferring some of your emotional energy (that is gong to spent on this anyway) to something that could be productive.

Thanks for reading this – I respect you matter what your views.

and because he has forced so many people to renounce as an act of self defense, he needs to go. We don’t know where Romney would be on these issues. But, it is inconceivable that he could be worse.

U.S. citizenship-based taxation has made U.S. citizenship second class citizenship the world over!

There is a reason why renunciations of U.S. citizenship are soaring under Obama.


Yes we can!! – Change we can believe in – Organizing the community of U.S. citizens abroad – One community at a time!

Last night the Economist Magazine ran an online debate on the issue of whether Barack Obama should be re-elected president. The debate allowed live comments. There were a total of 92 “registered” comments. Of the 92, approximately 7 were attempts to comment that never became comments (unless the absence of a comment was intended to be the comment). In any case, of the 85 substantive comments approximately 7 were from U.S. citizens abroad. The agony of U.S. citizens abroad is real. Their pain can be heard. The simple fact is that the Obama administration has made life for U.S. citizens abroad a life of agony. In order to spread the word, I created a number of tweets which link to the cries of anguish. Here they are: Continue reading

How citizenship-based taxation steals from the treasury of other countries: PFIC Edition

The following comment was on the ACA Facebook page:

I say with every ounce of facetiousness I can muster up: Every government of the world should stop letting Americans come to reside in their country. Eventually the ones that have slipped in before the draw bridge was raised will die off, leaving each country sanitized of these toxic elements. No more punishment for leaving the homeland, no more drain on anyone’s resources trying to hunt us down. Citizenship based taxation, the sacred cow of stupidity.

The author is correct. U.S. citizens should be banned from immigrating to any other country. U.S. citizens are a threat to the fiscal stability and sovereignty of any country. There are a number of reasons: including the inability of U.S. citizens to participate in normal financial planning and other vehicles of self reliance. I intend to do a series of posts exploring this theme. Today (as we get to the June 15 tax filing deadline) I offer you the “PFIC Edition”. Continue reading

Fareed Zakaria – Immigration lessons for the U.S. from around the world – Getting them in and keeping them in!

Last night I watched Fareed Zakria host a very interesting show:

Immigration lessons for the U.S. from around the world

Mr. Zakaria – Thank’s for a job well done! I assume the Podcast will be available soon. 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.

Phil Hodgen – “Why people expatriate” – A Comment on his post – What about those who cannot certify 5 years of tax compliance?

“Get out while the getting is semi-good.  Don’t wait for more time.  More time means more laws.”

– Phil Hodgen – “Why people expatriate”

Anybody who reads this blog is surely familiar with Phil Hodgen’s blog. Mr. Hodgen is California based tax lawyer who appears to have moved firmly into the practice of “Expatriation Law” – AKA helping people to renounce U.S. citizenship or  get rid of that green card. Mr. Hodgen’s latest blog post about “Why people expatriate” is proof that good things can come from long flights. Speaking of “good things”: one commentator wrote that:

This the best, even-handed analysis I’ve seen of the pros and cons of a US citizen bailing out. It should be required reading for every congressman and senator  in the US — as well as the president.

Sadly, it’s clear that Phil has little hope for an improvement. As he points out, it is the citizenship-based taxation that is the root of all this evil, and he sees very little chance of that ever changing.

When great powers begin their decline into eventual irrelevancy, it is rarely just one thing that historians finger as a root cause. But for the US, this may well be it.

In any case: Continue reading

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:


Found you from a pingback on an article I wrote.

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

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.