Monthly Archives: June 2014

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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ON FBAR WILLUL NON-FILING AND WILLFUL BLINDNESS – THE RUMSFELD DISCLAIMER

Former Defense Secretary Rumsfeld:
“I do hope that at some point in my lifetime, and I am now in my 80s, so there are not many years left, the U.S. government will simplify the U.S. tax code so that those citizens who sincerely want to pay what they should, are able to do it right, and know that they have done it right.”

The Tax Wars Blog

In United States v. Williams, (2012), the Fourth Circuit Court of Appeals reversed the District Court’s holding that Williams’ failure to file an FBAR that was due June 30, 2001 was a non-willful failure to file because the government already knew of the account prior to the filing deadline; and, therefore Williams had no deceitful motive for not filing despite answering “No” to the foreign bank account question on Schedule B of Form 1040 for that year.

The Fourth Circuit in reversing stated in part, “It (willfulness) can be inferred from a conscious effort to avoid learning about reporting requirements.” This effort to avoid learning is referred to as, “Willful Blindness.”

The IRS in the Internal Revenue Manual (IRM 4.26.16.4.6.3-6, discusses “Willful Blindness,” and states, in part:

6. Under the concept of “willful blindness”, willfulness may be attributed to a person who has made a conscious effort to avoid…

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INITIAL THOUGHTS ON IRS CHANGES TO OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND STREAMLINED PROCESS FOR NON-WILLFUL TAXPAYERS

Nice analysis of the transition. Ends with:
“What remains unchanged is the need to consider each non-reporting case individually, based on its peculiar facts and circumstances, and, chart the least risky course to a safe harbor. This is why experienced professionals with sound judgment must advise clients on these complex and delicate issues.”

The Tax Wars Blog

Yesterday, August 18, 2014, IRS announced and posted to the Offshore Voluntary Disclosure page on its website (www.irs.gov) significant changes to the 2012 OVDP reflected in revised Frequently Asked Questions; and, new Streamlined Filing Compliance Procedures for non-willful, out-of-compliance taxpayers, whether living abroad or here in the states. These new FAQs and procedures apply generally to OVDP submissions made after June 30, 2014.

OVDP CHANGES

The major changes to the 2012 OVDP are:

  • The 27.5% Offshore Penalty generally remains in place for participants but a 50% Offshore Penalty may apply, beginning with names submissions made on or after August 14, 2014, to those participants with foreign accounts at foreign financial institutions (FFI) about which public disclosure has been made of:
    • An IRS or DOJ investigation.
    • That the FFI is cooperating with IRS and DOJ, or,
    • A John Doe summons being served on the FFI.
    • FAQ 7.2 defines public…

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#IRS provides penalty relief: Isolates Congress and US tax laws as the problems for #Americansabroad

 

One June 4, 2014, I wrote a post speculating that that upcoming IRS amendments to the Streamlined and OVDP programs would likely provide relief for Green Card Holders resident in the U.S. This was based on a speech given by the IRS Commissioner of June 3, 2014. As was reported in numerous blogs (and given an enthusiastic review to Mr. Mopsick), the speech included:

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U.S. tax policy likely a factor in #Americansabroad returning to America

The article referenced in the above tweet is largely about Americans trying to thrive as expats in China (from a personal and business perspective). It appears to be written from a “China centric perspective”. The article and comments reinforce what Roger Conklin has been saying for years:

“U.S. policies and culture hurt the ability of Americans and American companies to compete internationally. We all (with the exception of the U.S. Government: Robert Stack edition and “don’t let the door hit you on the way out” Homelanders) know this. But, it’s interesting to see aspects of this issue discussed.

The comment that Amanda refers to appears with the following article in ChinaLawBlog.com and includes:

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