Monthly Archives: August 2014

Americans Line Up to Renounce US Citizenship in Toronto

Multicultural Meanderings

More on the US FATCA and impact on Canadians:

Canada finalized its IGA earlier this year. It requires Canadian banks send the account information of customers with U.S. citizenship to the Canada Revenue Agency CRA. The CRA then forwards that information on to the IRS, a tidy workaround to Canadian laws forbidding banks from sending that information directly to a foreign government.

But attorney John Richardson calls the information-sharing deal a “mechanism for the United States to extract after-tax Canadian capital out of the country.”

“What the U.S. is really doing is claiming the right to levy taxes on people who don’t live in the United States on income that is in no way connected to the United States. It simply cannot be tolerated,” said Richardson.

Many Canadians don’t even realize that the U.S. considers them taxable citizens, nor do they want U.S. citizenship, he said. That’s because the U.S…

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Washington likely to keep close watch on tax loophole as Burger King seeks to become Canadian

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.)


Interesting thoughts on FATCA from Jamaica which include:

“Finally, anyone who contradicts this rule can be charged as a voice for Tax Evasion. Many Americans cannot open new accounts, for failure to close old ones. Americans and Expatriates face an impossible situation, as their mortgages are being called or denied. To the extent that an expatriate faces an obligation to IRS, the efforts of his local employer may come under scrutiny.

Do we now have a form of economic totalitarianism?”

You should also read about the FATCA costs imposed on the average Jamaican.


The fate of ‘”FATCA”” now hangs in the balance. Arranged to be a January 2014 regulation, it is now a July planned regulation, ostensibly to give the F.F.I’s (Foreign Financial Institutions) time to get their house in order and then register and be accepted.  Internal Revenue Service Notice 2013-14 authorizes the decision, and that is supported by the U.S. Treasury Dept., administered by Treasury Deputy Robert B. Stack.

The reason given for the delay is because the FFI’s are overwhelmed by closures of accounts by consumers and customers all over the world. Apparently FATCA is a law that everyone seems to dislike, and everyone needs the time to be compliant (ref: Forbes Mag., Dec 2013, and Jan 2014). In and out of the USA, Banks and other FFI’s must report account numbers, balances, names and addresses, US tax identification numbers and Jamaican of course, of any and every substantive owner…

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William Watson: The only thing more Canadian than Tim Hortons is taxes, right? — Well, not any more

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!

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant


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.

#FATCA debate via Twitter – Defines some well articulated positions and provides structure for debate

This week the National Post published an article about the possible effects (suggesting it could be damaging to Canadians) of the 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.

Continue reading

Want to shed U.S. citizenship? Get in line

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.”

Vancouver, Toronto, Calgary named among the best places to live in the world by The Economist

But, are they safe cities for Americans being subjected to FATCA Hunt?