Monthly Archives: March 2013

Salvation lies in becoming a whistle blower



The Prophetic George Orwell – Winston Smith – 1948

George Orwell’s “1984” is a book that I reread every ten years. The more times I read the book, the more prophetic I see that it was.

Here are the final few paragraphs of George Orwell’s 1984

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Anti #FATCA BRIC nations building political clout and alliance

Earlier this year I wrote that “Peaceful resistance to FATCA will result in a new financial order“. An article by Geoffrey York of the Globe and Mail suggests this may be starting to happen.

The article is well worth reading.  Note the following commentary and excerpts:

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When law becomes a substitute for morality

The following tweet appeared as a post at the Isaac Brock Society and generated a collection of rich comments.
@MopsickTaxLaw Great post on “FATCA Feast” think you salivating people mean “stakeholders” – not “steakholders” …
To provide some context:
Steven J. Mopsick wrote a post which was a report of his experience at a recent FATCA conference. He was impressed by how the attendees were exploiting the business opportunity (inadvertently referring to them as “steakholders”) that FATCA has created for the compliance industry. Interestingly, Mr. Mopsick specifically makes the point that:
The focus of the conference was strictly on FATCA from the standpoint of complying financial institutions.  Most of the participants did not even know about and individual’s duty to file FBAR’s, Foreign Asset Statements (form 8938) and there was very little talk about privacy concerns, fears about the dangers of an emerging international banking data base system, or how Canadian politicians were doing in shaking their lap dog image as pawns of the US government.

Government confiscation of assets/savings: Let me count the ways!

On March 24, 2013 it was announced that Cyprus will indeed confiscate deposits in private bank accounts to save Cyprus. In other words, the saves will pay for the sins of the debtors.

Making the virtue of “saving” pay for the sin of “borrowing”

Confiscation of assets is a direct attack on the principle of saving!

If you haven’t heard by now, Cyprus has announced the direct confiscation of money in its citizens bank accounts. The announcement was made on a Saturday when the banks were closed. The banks remain closed for a bank “holiday” and the only issue is how and what percent of people’s “after tax” savings will be confiscated from them. As one commentator has suggested Cyprus appears to employing a (contextually) clever “divide and conquer” technique – turning citizens against each other. Those with fewer savings will have less stolen from them and those with more savings will have more stolen from them. What could be more just than that?

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Michael Miller on the 877A Exit Tax – Applies Prospectively

Expats Live in Fear of Malevolent Time Machine

Of relevance is the following:

It should be self-evident, however, that such a result is absurd, and cannot have been intended.

Congress cannot possibly have meant to treat individuals who had long since relinquished their U.S. citizenship, and whose expatriations had always been respected for federal tax purposes, as if they had been citizens all along.

Undoubtedly, Code Sec. 877A was meant to apply solely to individuals that, on (or after) the date of enactment, were otherwise treated as citizens (or long-term residents) for federal tax purposes.

Any individual who took all steps required to successfully terminate citizenship for federal tax purposes, under the tax laws as in effect immediately prior to enactment of the 2008 Act, would not again need to relinquish U.S. citizenship and thus could not be within the intended scope of Code Sec 877A(g)(4).

A government of laws and not of men – John Adams

“A Government of laws and not of men”

Growing up in the United States I remember hearing this phrase “time after time”. I don’t recall ever:

– thinking about it

– asking about

I just accepted it. Surely (like all great ideas) it must have been invented in the United States and it has been attributed to John Adams.

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Possible Canadian tax relief for US persons in Canada

Will the 2013 Canadian Federal Budget include some references to Canadians who the IRS defines as U.S. persons? As we all know the US is currently trying to get Canada to surrender part of its sovereignty by signing a FATCA IGA.

In its prognostications on the 2013 Budget, Moodys Tax Advisors considers:

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