Monthly Archives: May 2014

Kelly McParland: Obama explains his world view. Five years into his mandate it may be a little late.

National Post | Full Comment

If you are among the many who puzzle over Barrack Obama’s approach to foreign policy – and whether he has a coherent one — the U.S. President did his best to spell it out this week in a speech at West Point.

The full remarks are here, but the White House helpfully posted a summary of the message on its web site:

 The President spent most of his speech outlining his vision for how the United States, and our military, should lead in the years to come. The four elements of American leadership included:

  1. Using military force when our core interests are at stake or our people are threatened

  2. Shifting our counter-terrorism strategy by more effectively partnering with countries where terrorist networks seek a foothold

  3. Continuing to strengthen and enforce international order through evolving our institutions, such as NATO and the United Nations

  4. Supporting democracy and human rights around the…

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Charles Krauthammer: The only enemies Obama knows how to fight are straw men

National Post | Full Comment

It is fitting that the day before U.S. President Barack Obama gave his grand West Point address defending the wisdom and prudence of his foreign policy, his government was urging Americans to evacuate Libya.

[np_storybar title=”Barack Obama defends U.S. foreign policy at West Point speech but calls for military restraint in the future” link=”http://news.nationalpost.com/2014/05/28/barack-obama-defends-u-s-foreign-policy-at-west-point-speech-but-calls-for-military-restraint-in-the-future/”]WEST POINT, N.Y. — President Barack Obama declared Wednesday the U.S. remains the world’s most indispensable nation, but in a major speech defending his foreign policy, he called for restraint before embarking on more military adventures.

Mr. Obama’s address signalled a concerted effort by the White House to push back against critics who contend his approach to global problems has been too cautious and has emboldened adversaries in Syria, Russia and China. It’s a criticism that deeply frustrates the president and his advisors, who say his efforts to keep the U.S. out of more military conflicts are…

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John Ivison: Keystone decision looms over new U.S. ambassador to Canada

No discussion of FATCA. But, of course there is no one issue that’s important enough to destabilize the relationship between Canada an and the U.S.

National Post | Full Comment

Bruce Heyman may be new to politics but he is savvy enough not to answer a hypothetical question.

The U.S. ambassador left a lucrative career as an investment banker in Chicago to come to Ottawa in April and is set to make his first major policy speech to Canadians this Monday at an event hosted by Canada 2020.

In an interview with the National Post and Ottawa Citizen, I suggested many Canadian policy-makers believe the Obama Administration is set to reject the Keystone XL pipeline to pander to the environmental lobby. “How will you keep relations harmonious if that happens?” I wondered.

“I’m not going to assume any outcome here,” said the 56-year-old former Goldman Sachs veteran. “I think we need to move away from headlines and look at trend-lines. And if we look at the trend-lines of the relations between our two countries and highlight the good things…

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Nice Overview of all the IRS Issues for EXPATS

““We’ve seen people relinquish their citizenship in the past, so it’s not that these are extremely large numbers,” said Sabates. “What’s startling is that it’s happening at all. It’s not necessarily the expat that moves to Switzerland for a job, gets married, and ends up staying longer than they were thinking. It’s the children of that expat who have acquired citizenship by birth through their parents, and they may have no connections with the United States. They’re finding out that they have these tax-filing requirements at the same time that they’re finding out what being a U.S. citizen means. We’ve seen a lot of family-based citizenship abandonment where you’ve got a couple of kids who have gotten citizenship through their parents. Before they start getting into the working world and developing their wealth, the U.S. tax issues crop up and they’re relinquishing their citizenship.”

IRS vs expats

This article from Accounting Today online. I especially like the quote from Roland Sabates, H&R Block director of expat services who said, “In the last year a lot of the potential clients that are contacting us are terrified.” I can understand this for an freshman expat newly exposed to the myriad of regulations, forms, and filing requirements over and above what the ordinary stateside filer has been exposed to and become accustomed. FBAR, FATCA, ACA, FinCEN, BSA, E-Filing and FIGMO. Just kidding about that last one. If you have a US military background, you know what I mean. If no, I have provided a link to help you understand my feelings about this whole thing. So here’s the article……..

By Michael Cohn
May 27, 2014

Nearly 6 million Americans living abroad are facing a June 16 deadline to file…

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IRS FBAR OVDP Opt-Out Interview Questions Revealed !

“Decisions regarding opting out should be carefully considered depending upon the taxpayers responses to each of the foregoing questions.”

TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report

For more than a year, numerous taxpayers with previously undisclosed interests in foreign financial accounts and assets have been seeking participation in the current IRS offshore voluntary disclosure program (the OVDP) which began in 2012, modeled after similar programs in 2009 and 2011.

Taxpayers participating in the OVDP generally agree to file amended returns and file FINCEN Form 114 (formerly Form TD 90-22.1, Report of Foreign Bank and Financial Accounts), FBARs, for eight tax years, pay the appropriate taxes and interest together with a 20% accuracy related penalty and an “FBAR-related” penalty (in lieu of all other potentially applicable penalties associated with a foreign financial account or entity) of 27.5% of the highest account value that existed at any time during the prior eight tax years. The OVDP does not have a stated expiration date but can be terminated by the IRS at any time as to specific classes of…

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Zwerner Answers DoJ Efforts to Collect Multiple 50 Percent Civil FBAR Penalties

“The Internal Revenue Manual suggests that “willfulness may be attributed to a person who has made a conscious effort to avoid learning about the FBAR reporting and recordkeeping requirements.” However, the willfulness determination should be based on the actual facts and the context in which statements are made (or not) rather than assertions in a legal pleading.”

TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the current IRS offshore voluntary disclosure program (the OVDP which began in 2012), modeled after similar programs in 2009 and 2011. Taxpayers participating in the ongoing 2012 OVDP generally agree to file amended returns and file FBARs for eight tax years, pay the appropriate taxes and interest together with an accuracy related penalty equivalent to 20 percent of any income tax deficiency and an “FBAR-related” penalty (in lieu of all other potentially applicable penalties associated with a foreign financial account or entity) of 27.5 percent of the highest account value that existed at any time during the prior eight tax years.

Under the 2009 OVDP, the FBAR-related penalty was 20 percent…

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