Monthly Archives: December 2013

Offshore Tax Havens – Hey Obama Delaware Must be First to Go

“President Obama, given that Delaware is the United States of America’s “First State” we in the offshore services sector are positive that you will make it the “First Offshore Tax Haven” you destroy. Regardless of the trillions of dollars that will undoubtedly be divested from the U.S. markets and the economic consequences your actions will cause.”

Too Big to Fail Will Again – HNW Cover Your Own ASSets

Interesting article:
“HNW Cover Your Own ASSets:

High-Net-Worth Individuals must become more involved in protecting what is theirs and not depend on others to do it for them. If you believe that your government won’t confiscate a large portion of your wealth; then do nothing more than what you are doing now.”

IRS offers new procedure for US expats to correct their failures to file

the IRS today announced a new procedure for obvious tax cheats U.S. taxpayers living abroad who haven’t filed all of their returns.

Fideicomisos! A Private Letter Ruling for the Taxpayer

This post from this Texas lawyer is significant because it underscores that even if something is called a “trust” outside the U.S. it may not meet the definition of “trust” under U.S. law. If something is not a “trust” under U.S. law, it can’t be a “foreign trust” under U.S. law. See also this interesting Phil Hodgen post.

US residents avoid tax using trusts located in “Tax Haven USA” while #Americansabroad evade tax through #TFSA

Do as I say! Not as I do!

It’s official. As we end 2013 and begin 2014 it’s clear that the administration of Barack Obama  has distinguished itself as becoming the most hypocritical joke in the world. For those seeking additional insight on this point, I recommend “Sangeeta Richard is proof of failed American reciprocity“. Although this article is written in the context of the recent U.S. arrest of an Indian diplomat in New York, the implications spread far and wide.

The fallout over the Indian consular officer,  Devyani Khobragade, whom the US Marshals humiliated through strip and cavity searching her despite her immunity (we learn now that it is full UN immunity!), has much greater interest for the Isaac Brock Society than perhaps we realize.  It demonstrates the US’s stance towards other nations as being one of, “Do as I say, not as I do.”  I.e., the US has become monstrous bully and hypocrite.   When citing diplomatic protocols in his defense of accused murderer Raymond Allen Davis (see video of Obama’s plea), President Obama emphasized the concept of reciprocity.  Yet now his administration violates the very principles that he iterated in that press conference by treating Devyani Khobragade with disrespect and by indicting her for Form Crime.

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IRS Publicizes FATCA As Jan 1st Draws Near

Looks like all the banks are “Whistleblowers” now.

IRS vs expats

This is from the FATCA Home Page on IRS web site

FATCA FFI List Resources and Support Information

Under the Foreign Account Tax Compliance Act (FATCA), withholding agents must withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree to report certain information to the IRS about their U.S. accounts or accounts of certain foreign entities with substantial U.S. owners.
An FFI may agree to report certain information about its account holders by registering to be FATCA compliant. An FFI that has registered and that has been issued a global intermediary identification number (GIIN) will appear on a published FFI List. The FFI List can be downloaded in its entirety or
searched for specific information (FI name, GIIN or country). Search results can also be downloaded.
Withholding agents may rely on an FFI’s claim of FATCA status based on checking the payee’s GIIN…

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FATCA Headed For Catastrophic Collision

IRS vs expats

This is absolutely the BEST article that I have ever read compiling all the implications and consequences of FATCA. It comes from:
Webcpa News
which can be accessed at:
and is called,

FATCA Losing Its Way

Written by Victoria Ferauge and Lynne Swanson

Awareness of the implications of the Foreign Account Tax Compliance Act, also known as FATCA, is growing.Passed by Congress in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act, this extraterritorial law has sparked global fear, confusion, anger and controversy.

Now that controversy has come home. There is growing domestic opposition to FATCA implementation. U.S. lawmakers and banks are fighting reciprocal information exchange promised to other nations like Mexico and Germany. Yet another delay in implementation was announced recently by the U.S. Treasury.

The road to FATCA began with a simple premise: Force foreign banks to disclose income held by Americans in offshore tax havens. In…

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