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.

The Shape of Tax to Come

In I.R.S. News Release 2012-65, the IRS announced a new procedure for US taxpayers living outside of the USA to correct existing failures to file tax returns, information returns, and FBARs. You’ll need to pay your back taxes and interest. The details are not yet finalized, and the procedure will not start until September 1 4, 2012.   The intensity of the review will depend on the compliance risk posed by each taxpayer’s situation (i.e., more attention will be paid to “whales” than will be paid to “minnows”). Participating in this new procedure will not necessarily prevent criminal prosecution by the IRS or DOJ.


  • The IRS finally gets around to recognizing that citizenship-based taxation (which also covers non-citizen green-card holders) creates a problem for people who have left. As long as U.S. taxpayers are required to file full tax returns, plus extra information returns to report their foreign accounts…

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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.

The Shape of Tax to Come

TL; DR. A soon-to-be released Private Letter Ruling holds that a fideicomiso is not a trust for federal tax purposes. As a result (though not stated in the PLR), the taxpayer does not need to file Forms 3520 and 3520-A to report his interest in the fideicomiso. Because this is a PLR, it may only be cited as precedent by the taxpayer who requested it. YMMV.

Each year, American taxpayers with assets held outside of the USA must file more and more forms with the IRS to disclose those assets. In many cases, these disclosures do not result in more tax, but will result in additional penalties if those forms are not filed. Given that the IRS wants to know everything about everyone, it was a bit surprising to see the IRS issue a Private Letter Ruling holding that a fideicomiso isn’t a trust.


  • The IRS will publish…

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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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