Monthly Archives: December 2015

While some Homelanders have a private tax system – USA imposes FATCA and CookvTait on #Americansabroad

A “bed time story”  explaining why FATCA does not matter in the least for those it was supposedly intended to target!

Once upon a time in America – a FATCA fairy tale …

There were some homelanders who didn’t pay their fair share!

Most of the taxes were paid by higher income earning homelanders!


Unless you were a “super wealthy” homelander in which case you could create your own special tax system and pay the lowest taxes of all!

Which created many revenue shortfalls, so Congress passed “Revenue Offsets” and set the IRS to hunt Americans abroad

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IRS Creates “International Practice Units” for their IRS Revenue Agents in International Tax Matters

https://twitter.com/USCitizenAbroad/status/681894792415019008

Since Homelanders don’t pay their fair share of U.S. taxes it’s essential that the IRS make up the shortfall from citizens and residents of other nations who are making use of financial planning vehicles in their country of residence, thereby depriving the U.S. Treasury of the fruits of economic activity in other nations. Right?

Tax-Expatriation

The U.S. international tax law has become increasingly complex.  I am confident when I say that very few individuals in the world (including IRS revenue agents) understand the complexities of Title 26 and Title 31 as they apply to IRS Form 1040 p1international matters such as gifts of foreign property, gifts involving U.S. intangible property, gifts to or inheritances from foreign estates with U.S citizens (USCs) or Lawful Permanent Residents (LPRs) beneficiaries, foreign partnerships with USCs, transfers of property to foreign trusts by USCs or LPRs residing outside the U.S., transfers of property to foreign corporations, etc.

Most USCs and LPRs who live in the U.S. certainly know and understand the basics of IRS Form 1040.

However, the type and scope of international transactions contemplated by the law can be significant and are rarely understood in any depth, even by many tax professionals.  I have seen cases during my career of sophisticated…

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The #FATCA Retirement and other assorted #CookvTait short stories …

Have you either considered stopping working because of U.S. policies toward Americans abroad? Have you stopped working? Have you given up attempting to plan for your retirement?

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FATCARetirement

Updated and continued on January 8, 2015 …

Meanwhile back on the Homeland Front …

As the above tweet confirms:

Yes, it’s true! Americans abroad are damaged by FATCA, FBAR and CBT. Who could have known? Of course the “FATCA Retirement” is only one form of damage. What follows is the message forwarded  from ACA and rerouted to me:

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The comments of @submergingmkt James Henry appear to assume that the #CookvTait Principle of extra-territorial taxation is correct

My last post featured the comments of Apple CEO Tim Cook about the ongoing debate over whether U.S. companies should be punished for their strict compliance with the absolutely archaic, dysfunctional, overly complex tax laws of the United States of America. It has reached the point where it appears there are two classes of corporations that Homeland politicians and groups like the Tax Justice Network dislike:

Group 1 – U.S. Politicians dislike those U.S. companies who do comply with U.S. laws; and

Group 2 – U.S. Politicians dislike those U.S. companies who do NOT comply with U.S. laws.

These sentiments were recently expressed by James Henry of The Tax Justice Network who makes the point that:

The interview with Mr. Henry is fascinating. Mr. Henry is opposed to “territorial taxation” for Corporations. This suggests that he might be opposed to “residence based taxation” for individuals.

I would appreciate you commenting on what you think of Mr. Henry’s interview. What are the key points that he makes? What (if anything) does he say that is relevant to the RBT vs. CBT debate? Do you get the impression that Mr. Henry believes that U.S. companies are the property of the U.S. government?

By the way …

Here is Tim Cook’s testimony before the Levin Committee in 2013:

#CookvTait principle has created problems for Apple and has created advantages for non-US persons and corporations

Introduction …

The U.S. tax system is premised on the assumption that it can levy taxes on economic activity in other nations. This simple premise applies to both corporations and to individuals.

In the case of individuals: The taxation of economic activity in other nations takes place at the time that the money is earned.

In the case of corporations: The taxation of the economic activity, the taxation takes place when the money is returned to America.

In any case, the United States discriminates very strongly and punitively against all things American. The views of Apple CEO Tim Cook has some interesting comments on this issue.

Apple CEO Tim Cook interviewed on 60 Minutes 2015 …

”This is a tax code, Charlie, that was made for the industrial age, not the digital age,” he said. “It’s backwards. It’s awful for America. It should have been fixed many years ago. It’s past time to get it done.”

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Americans Abroad Caucus’ FATCA Same Country Exemption

Leaving aside the fact that this is a very weak letter, the real weakness of this letter is that it doesn’t give any reason why Homelander politicians should care. Homelanders are in one of two camps.

Camp 1 – They dislike and distrust Americans abroad and therefore are happy to abuse them.

Camp 2 – They are indifferent to Americans abroad. Indifferent is one of the worst forms of abuse.

Bottom line: There is NO POINT in trying to negotiate with these people. Just get on with the job of renouncing U.S. citizenship Frankly it’s the most patriotic thing you can do.

IRS vs expats

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Latest of 30 Guilty of Not Reporting to the IRS = What happened to one man who didn’t report his FBAR

Anybody with an offshore bank account is suspect. The only thing Americans abroad can do is renounce citizenship.

IRS vs expats

This post is from the United States Department of Justice website.

I emphasize that this individual, Michael Reiss, WAS AND IS NOT AN EXPAT. The next post will deal with how these thieves are causing the IRS to be on high alert and hunting for huge amounts of money that are legally and morally due to the United States. These American thieves who live IN America are causing we expats, who try to comply with the law, to suffer as a result of intense scrutiny by the IRS.


United States Attorney Southern District of New York
FOR IMMEDIATE RELEASE
AUGUST 5, 2011
CONTACT:
U.S. ATTORNEY’S OFFICE
ELLEN DAVIS,JERIKA RICHARDSON,CARLY SULLIVAN
PUBLIC INFORMATION OFFICE
(212) 637-2600
IRS
JOSEPH FOY
PUBLIC INFORMATION OFFICER
(212) 436-1032

NEW JERSEY DOCTOR AND MEDICAL PROFESSOR PLEADS GUILTY
IN MANHATTAN FEDERAL COURT TO FAILING TO INFORM IRS
OF MILLIONS HIDDEN IN SWISS BANK ACCOUNTS

PREET…

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