Monthly Archives: June 2012

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.

The Isaac Brock Society

Updated with the following additional paragraph June 4/12

I have been following the comments to this thread with great interest. I believe that this Obama social media initiative is a great opportunity for us. This post needs to be linked to the “Just Me” post of April 22/12 where he talks about the stupid form letter that somebody received after writing Obama about OVDI. I reference the following helpful comment from Steven where he says:

30 Year IRS Vet


I have a slightly different view and perhaps an idea worth pursuing.

The fact that the White House responded at all gives the IBS an opportunity to use the response as a vehicle to further publicize the issues facing expats and the inequity of citizenship based taxation in general. You now have a letter from the President dated April 18, 2012. It is in…

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