Monthly Archives: June 2014

Living with Dual Citizenship – Matthew 22:15-22

Living with Dual Citizenship – a most interesting post. Includes:
“Dual Citizenship Requires Proper Activism

Let’s go back to that coin. Jesus holds it up and asks the crowd, “whose image is this?”, and “whose inscription?” Inevitably they respond “it is Caesars”. Then Jesus says, “Well, if it has Caesars image on it, it belongs to him, so give it back[19] [to him].”[20][21]”


– To Watch Sermon Video Click Here –

The very word patriotism comes from the word patriarch; and we all acknowledge that each of us have a connection to a “father land.” This has with it identification to a particular kinship, a kinship that has worked, and sometimes fought to sustain and protect the family. I believe that just as one honors father and mother one should also honor where God has placed you. My great grandfather served in World War I, my grandfather served in World War II as a helmsmen on a Navy ship.

Obviously, these men did not battle the other side because they hated the individual men in front of them, they simply loved the men behind them.[3] They stood for their fellow Americans and stood against the ideals that the enemy represented. When I hear the Patriotic songs and pledge allegiance to the flag…

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Cook v. Tait 17: Voices from the crowd – What U.S. citizenship-based taxation really is

This comment by Deckard1138 was made to: Dropping The Bomb at the Economist.

Please, let’s all cut the crap, shall we? Especially those apologists for CBT who treat it like some esoteric academic exercise, the same way supposedly learned men, who should have known better, once opined about eugenics. It’s really very simple: citizenship-based taxation is America’s Apartheid system. It is repugnant, immoral and indefensible. Since CBT is so clearly irredeemable, there is really nothing to talk about, unless your intellectual curiosity exists in a profoundly amoral vacuum. CBT discriminates against a particular group of people on the basis of their place of birth – a characteristic as immutable as the colour of their skin. It labels them, tracks them, intimidates them, criminalizes them and forces them into virtual prisons from which escape is nearly impossible. Worse, the architects of CBT are now co-opting the rest of the world to implement this discriminatory regime for them. It is astonishing and disheartening how quickly and easily this is unfolding. Far too many countries, cowed by the 30% withholding stick that the U.S. threatens to beat them with, like the FBAR and OVDP sticks they already beat their CBT victims with, simply refuse to challenge America on fundamental moral grounds and it is wrong. The U.S. does not deserve a free pass on CBT and FATCA any more than the old South African government deserved a free pass for its heinous apartheid policies. Yet several ostensibly modern and enlightened nations have rationalized their acquiescence to FATCA by publicly exclaiming that America has the inherent right to tax its citizens in whatever manner it chooses. Well, in a just world it does not, for CBT represents a clear denial of basic human rights and dignity. Yes, the global hypocrisy is staggering, especially from countries like Canada. Last year, our Conservative government expelled the consul-general for Eritrea for that regime’s tax extortion efforts against its expats in Canada. Just last week, the same government enthusiastically ushered-in America’s FATCA laws to override our country’s own Charter of rights and freedoms, discriminating on the basis of national origin, gutting federal banking privacy laws and setting the stage for a massive legal challenge which will be fought in our Supreme Court. Beneath all the technocratic language about forms, compliance, jurisdictions and enforcement, there is a fundamental truth: these American policies are morally unjust and the world must not condone them any longer. FATCA will be a global disaster unless it is stopped now. It is indeed time for the world to say no to the U.S. practice of citizenship-based taxation and to force it to adopt residency-based taxation like the rest of the world. If not, then the world better find a more deserving reserve currency in a hurry – the United States has abused its position of trust for far too long and it needs to be reminded that it is just one nation in a community of nations. The breathtaking audacity of FATCA is simply a bridge too far.

More from Deckard1138:

Wow, these academics sure seem to have a hard time getting to the point – only to miss it completely. 56 fucking pages to dance around, but never quite grasp the truth that citizenship-based taxation is fundamentally, morally wrong and indefensible – period. As many have convincingly argued before, CBT is no different than slavery, Jim Crow laws or apartheid. What exactly is there to talk about?

What really annoys me is the unstated presumption of people like Mason and Kirsch (who no doubt genuinely consider themselves our intellectual superiors) that it is somehow legitimate to lovingly, almost pornographically, explore CBT – in a world which so categorically rejects it – only because it is an American idea and policy and therefore somehow intrinsically worthy of debate. I counter that there is nothing to debate, and no need to kill innocent trees and waste energy on bits and pixels pathetically striving – and spectacularly failing – to turn lead into gold. The best I can say for Mason is that she greatly disappoints me, while Kirsch, as always, simply disgusts me. These people are no magical alchemists of inhumane tax policy and never will be. Rather, they will become the true footnotes of this sordid chapter of American history.

But what the hell do I know since I only have a lowly B.A.?

DualUSAbroad Jun 27th, 01:08 – explains why Americans abroad must renounce U.S. citizenship:

As an American expat (and now dual citizen) living abroad for 20 years, I have first hand, on the ground experience, to say without hesitation that (i) Citizenship based taxation and FATCA have been, and are, a disaster for US expats, and (ii) the US government is the biggest threat to US citizens living abroad today. No other country treats its overseas expats as poorly as the United States, and without any justification. We are treated like property, and under threat of fines and penalties applied extraterritorially, the US extracts taxes for money earned, invested and spent overseas by expats living overseas, with no connection whatsoever to the United States and without receiving ANY services for the tax dollars extracted from us. We already pay taxes in the countries where we live and work. Now, because of this grand idea called FATCA, we are branded as second class persons to the entire financial community worldwide. Citizenship based taxation and FATCA is a square peg forced by the US government into a round hole, and it is ruining the lives of US citizens overseas. If the US Treasury was a responsible entity (which it clearly has not been), it would go to Congress and the Administration and propose that citizenship based taxation be changed to the world standard of residence based taxation. Ironically, US companies already get the advantage of residence based taxation for money earned and retained outside the US, but US persons are taxed on worldwide income no matter where they reside on the planet. Whereas holding a US passport living overseas was a point of pride, today because of FATCA, the US passport has become toxic for US citizens living overseas. For the first time in my life, I am faced with the decision whether to renounce my US citizenship so I can have the same level of ‘normalcy’ in my life outside the US as any other world citizen. It is a horrible choice forced on me by my own government.

I will elaborate on my personal beliefs that residence based taxation is not good fiscal policy. At least here, I do have a bit more knowledge of the subject than on FATCA in general. I do understand that the rest of the world does it differently, but that doesn’t mean I think it is good policy. In general the U.S. should try to fit better in the world, and should only differ when there is good reason when we do it differently. Personally I do feel there is good reason, but I certainly respect those who see it otherwise, I don’t see a perfect solution. My reasoning is based on the fact that in the real world, taxes don’t directly pay for services, but rather most government services are amortized over many years, and many government things government provides are essentially insurance policies, not services. (E.g. if one has a fire at one’s house, one doesn’t pay the cost of the firemen. We all pay a much smaller amount per year. The system would not work if people could only pay their taxes in the years of high fire probability.) Despite the fact that you aren’t using any direct services, there is still significant benefit to being a citizen. E.g. if war breaks out, you can get on a plane and move back to the U.S. and be immediately protected by the U.S. military. The system wouldn’t work if we only paid for the military in war years. Another example is public education. The annual taxes we pay for a student in public school is a fraction of the annual cost of educating that student. But if a parent pays taxes their entire life, there are years they are paying school taxes when they have no student in school, so the costs are essentially amortized. If we allow people to only pay school taxes when they have children in school, the system breaks. Look, I get that these are simplistic examples, there are all kinds of details and exceptions. I’m sure you can point out differences with your specific situation. I am simply pointing out why philosophically and fiscally I favor some citizenship based taxation. Cheers. Thanks for all your replies. I do sincerely hope we can find a better solution for your situation. It is easy for me to philosophize when it doesn’t affect me directly. I do sympathize for your situation. You and others here have helped educate me, and I thank you all for that. I will certainly take your postings to heart, give them more thought, and shift my position on FATCA, even if it is not as much as you’d like. I’ve learned a lot. Thank you!

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Twas the night before #FATCA @TaxPolBlog interview – Mentions

This is a good interview with a mention of the FATCA Charter Challenge – covers a number of issues in a short period of time!

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Individual Rights: Essential to a Free Society

” We must stay vigilant in holding our representatives responsible for what they legislate and always stand up for the underdog. We must question the official narrative of everything because it is our duty to keep our government in check, and as long as we keep on asking questions, we will find answers.”

Cook v. Tait 16: Supreme Court’s Decision in Cook vs. Tait and Notification Requirement of Section 7701(a)(50)

This interesting post goes along well with my series of posts on Cook v. Tait found here:

The author is arguing that even if U.S. citizenship-based taxation is constitutional (which is questionable), that the Cook v. Tait rationale could not justify citizenship-based taxation beyond the point where one ceases to be a citizen for immigration purposes.

The author writes:

The statute says ” . . . An individual shall not cease to be treated as a United States citizen before the date on which the individual’s citizenship is treated as relinquished under section 877A (g)(4). . .”

“How can the U.S. federal government continue to impose U.S. worldwide income taxation on former U.S. citizens because of the provisions under Section 7701(a)(50) and 877A (g)(4)?”

I am not convinced that the effects of S. 7701(a) 50 and 877a(g)4 do apply to those who expatriated prior to 2004. On this point see the interesting article by Michael Miller:

This issue was recently canvassed at the Isaac Brock Society as follows:

Those interested in this issue are encouraged to read the perspectives of a variety of lawyers in the “Isaac Brock post”. I find it incredible that some (but not all)  “cross-border professionals” routinely interpret S. 877A(g) 4 in he way that is least advantageous to the taxpayer.
In any case, this is an interesting “Cook v. Tait” post.


The U.S. Supreme Court upheld as Constitutional the concept of citizenship based taxation in 1924 in Cook v. Tait.  In that case, the U.S. citizen resided permanently and was domiciled in Mexico City with his Mexican citizen wife.

In those years, the Revenue Act of 1921 imposed a top income tax rate of 8%.  The IRS made a demand against Mr. Cook to pay his tax.  Mr. Cook paid it and sued for refund of the US$1,193 paid.    That amount represents about Zwerner Notice of SettlementUS$16,893 in 2014 inflation adjusted dollars.  Neither amounts are significant in current actions taken by the IRS.

As a point of reference, Mr. Zwerner was alleged to owe US$3,630,119 (on an account with a maximum value during the years at issue of apparently no more than US$1.69M) and ultimately paid about US$ 1.75M (more than he even had in his account?) per the Notice of Settlement…

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Passport issuance used to control people and borders

The U.S. government has begun to tie the issuance of passports to tax issues and issues of debt. But, Canada is getting on this act as well.

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“Second Citizenship, Dual Citizenship, Second Passport” – What Are They Talking About?

There’s one very good Chinese proverb: “The best time to plant a tree was 20 years ago. Second best time is now”.

Second Citizenship Tips

I didn’t have a chance so far to meet a person who would refuse to have a second citizenship if it’s legal, easy to get and no negative consequences; second passport of a decent country to let you travel free and safe, open accounts and invest offshore. And it would be of course better to get it cheap as well though all we know the cheaper is not always the best. There exist different options, costly and not that expensive too, with their benefits and inconveniences accordingly. Sometimes you may have to renounce your current citizenship, sometimes you may eagerly want to.

If you are in the position making sure you will benefit from it, there is one certain thing about second citizenship. There’s one very good Chinese proverb: “The best time to plant a tree was 20 years ago. Second best time is now”. These guys can help you…

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Top 6 reasons to buy a second passport and nationality

Stigmatization due to ethnic origin, religion, cultural background, may be an blockage for you in business or if you do business in some regions.

How to obtain a second passport and citizenship

Professional service to serious customers, who need it for an overall tax and business plan.

Security reasons when traveling for U.S, Israeli and U.K. citizen.

Traveling with a European passport may get you out of harms way or may significally reduce stigmatization due to nationality, religious belief or culture background.

Study and move freely within the Europe without the need for visa, resident permit. Eu constitution enable citizen of EU to take any job or study within EU member states. Work in EU without the need for work permit (great for “fallen CEO” to use their expertise in a region where they are more appreciated. Basically can you re-locate you`re whole family.

Anonymity as an individual or as a family. Stigmatization due to ethnic origin, religion, cultural background, may be an blockage for you in business or if you do business in some regions. The program comes with a possible…

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Second Passports: High Profile vs Low Profile

A polite enquiry as to whether “any residency or citizenship incentives may be offered to those willing to invest in the country”, directed to the relevant government department of your chosen destination, might well get you started.

How to obtain a second passport and citizenship

Expect hassle if everybody knows that the passport you hold can be bought for cash.
One of the main problems associated with economic citizenship programs is that they are frowned upon by many industrialised nations, who see them as government-sponsored “passports-for-sale” schemes.
Note that this is highly hypocritical: the same countries will often offer passports by discretion — particularly to the mega-rich, in return for a slice of their taxable income and the inward investment that their citizenship may deliver. Rupert Murdoch, whose media empire is worth a fortune, was granted US citizenship, for example.
Yet the same nations do not care for their Caribbean or Central American neighbours doing the same.
Countries such as Grenada, Dominica, St. Kitts and Nevis and Belize, for example, have operated official second citizenship programs. In my opinion, however, there was a fundamental problem with all of them: these nations, hungry for investors’ cash…

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Getting Your Second Passport

Second passports are becoming more and more important.

How to obtain a second passport and citizenship

The pathway to second citizenship is not always an easy one. Setting a realistic agenda at the outset is essential.

Perfect Second Passport?

Second passport programs come and go. At any one time, there may be any number of programs to choose from worldwide. Naturally, they vary greatly in both quality and cost.
There are many questions you should ask yourself before you make a commitment to a particular second passport program. Here are but a few:
* Is the political and/or economic stability of your passport-issuing country important?
* Will you wish to relocate there?
* How will a new citizenship and/or residence affect your tax position?
* If your concern is ease of travel, which parts of the world do you intend to travel to?
* Is asset protection a major priority?
* Is a name change important?
* What level of investment do you wish to commit?

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