Once again President Obama demonstrates his contempt for the law by noting that if he doesn’t like the results of the law, he has no respect for the law.
And on the Levin front:
Ohio Senator Sherrod Brown urged people to boycott Burger King over its move to relocate to Canada and eat at rival Wendy’s or White Castle instead. Meanwhile, Senator Carl Levin said he believes Burger King risks a backlash from its customers that would outweigh any tax benefit.
Of course, the U.S. could simply amend it’s tax laws to make them compatible with the rest of the world (that is if there is world outside the U.S.)
The above tweet references a post at the Isaac Brock Society which includes:
Obama: Corporate Deserters!
Posted on August 25, 2014 by usxcanada Posted in Issues regarding US persons abroad 7 Comments
So they’re technically renouncing their U.S. citizenship. They’re declaring they’re based someplace else even though most of their operations are here. Some people are calling these companies “corporate deserters.”
And it’s only a few big corporations so far. …
— Barack Obama (24 July 2014) White House Transcript
Post Tim Horton’s, Obama looks like he’s thinking about (1) Canada as haven (2) the individual lives worldwide that the U.S. has willfully been driving into the desperations of financial ruin, severe psychic stress, marital breakup, contemplation of suicide — and skyrocketing rates of renunciation.
What really ticks Obama off is those big corporations. He talks about them just like they were individuals. Oopsie. Category mistake!
This is just one more example of how U.S. tax law makes it difficult for U.S. corporations to compete in a global world. There is no other country in the world that penalizes its own citizens and corporations simply because they are U.S.
Imagine if the Canadian government gave preferential treatment to non-Canadian citizens and corporations.
The U.S. believes it can both have the highest corporate tax rates in the world and expect corporations/people to want to remain Americans. This is delusional.
This week the National Post published an article about the possible effects (suggesting it could be damaging to Canadians) of the ADCS-ADSC.ca FATCA lawsuit. The article is a report on an interview that the author had with Calgary based U.S. tax laywer Roy Berg.
The above tweet references an article, published by Moody’s in which there is a suggestion that by participating in this lawsuit, that the plaintiffs would incur further tax liability to the IRS. The article states:
As an aside, we acknowledge that the two Canadian plaintiffs are exposing themselves to tremendous tax and other legal risks. Sticking to what we know, the plaintiffs seem to have admitted that they willfully did not file FBARs and US tax returns, both of which are criminal acts. In addition, there might be US tax exposure to them personally because a Canadian non-profit organization is raising funds and paying their legal fees to fund the litigation. Even the most casual observer has to applaud the bravery of the plaintiffs and the not-so-subtle parallel to original signatories to the Declaration of Independence.
Since this “aside” is irrelevant to the issue, we can assume that this is an attempt by Moody’s to somehow intimidate the plaintiffs. (Or at least that’s how I view it.). The simple reality is that the compliance industry is the sole beneficiary of FATCA.
But, that “aside” aside, the article generated a number of interesting comments. I suggest that the following stream of comments do a good job of framing the issues in the context of a broader FATCA debate.
In the meantime, Nightingale warns, the tax side of renouncing U.S. citizenship can be expensive:
“If somebody comes to us and says, ‘I’m a U.S. citizen, I’ve never filed tax returns, I’ve got a pretty ordinary life, but I’ve got an RRSP, an RESP, a TFSA and some mutual funds, and can you prepare all my returns and get me ready for expatriation?’, by the time we do all that, it’s not hard to spend $15,000 or $20,000 for a fairly ordinary person.”
But, are they safe cities for Americans being subjected to FATCA Hunt?