Investments Effectively Prohibited To Canada U.S. Dual Citizens

“There has been a lingering question about the US tax treatment of Canadian Mutual Funds in taxable accounts.  This discussion does not apply to investments in RRSP accounts.  In early 2010, the Internal Revenue Service issued a determination that most Canadian Mutual Funds are corporations for US tax purposes, even though they are organized as […]

#Americansabroad denied child tax credit for children who are NOT US citizens – Benefit or burden?

Introducing the “FBAR Marriage” #Americansabroad who file "married filing separately" read http://t.co/UilDEsSXXe – U pay a price 4 protecting spouse in #FBARmarriage — U.S. Citizen Abroad (@USCitizenAbroad) September 6, 2013 The “FBAR Marriage” is a marriage between a U.S. person abroad and a non-U.S. person. The most important partner in the “FBAR Marriage” is the […]

Tax compliant #americansbroad with a principal residence or mutual funds should renounce before becoming a covered #expats

#americansabroad in Canada: The sale of your principal residence is a US taxable capital gain http://t.co/SQaSzY0Rgg — U.S. Citizen Abroad (@USCitizenAbroad) July 12, 2013 If you sell a #PFIC (mutual fund) you have held for many years, you can"basically say goodbye to that investment" http://t.co/mu5k07xAv2 — U.S. Citizen Abroad (@USCitizenAbroad) July 11, 2013 For those […]

When law becomes a substitute for morality

The following tweet appeared as a post at the Isaac Brock Society and generated a collection of rich comments. @MopsickTaxLaw Great post on “FATCA Feast” think you salivating people mean “stakeholders” – not “steakholders” http://mopsicktaxlaw.blogspot.ca/2013/03/on-january-30-and-february-1-i-chaired.html … https://twitter.com/USCitizenAbroad/status/314009089812361217 To provide some context: Steven J. Mopsick wrote a post which was a report of his experience at a […]

Does Cook v. Tait really mean that citizenship-based taxation is constitutional in all cases?

In December 2012 U.S. Judge Robert Bork died. He  taught at Yale Law School. His students included Bill and Hilary Clinton. He was once the Solicitor General of the United States. He was a prolific writer and a forceful intellect. Even those who disagreed with him respected him. President Reagan attempted to appoint Judge Bork to the Supreme Court of  […]

The Sun Life Betrayal Part 2 – The possible consequences of pension plans being PFICs

Prologue: If you are a US citizen or permanent resident and have been living and working outside the US and investing your savings through a non-US financial institution, you need to learn what a Passive Foreign Investment Company (PFIC) is very quickly. Why? Because the passage of the Foreign Account Tax Compliance Act (FATCA) in […]

Sun Life prepares to turn clients over to IRS for processing – bitter end to a company with a proud history

@SunLife Throwing ur customers under the Bus are you? It could be some of your own family members who r "U.S. Persons' http://t.co/HRelOO7f — Marvin Van Horn (@FATCA_Fallout) December 16, 2012   [https://www.youtube.com/watch?v=rNtIDy78DdE]   Once upon a time there was a Canadian life insurance company. It’s name was Sun Life. Sun Life was founded  in 1865 […]

How fluctuating FX rates generate capital gains taxes on the discharge of debt and the sale of property – US citizens abroad!

Financial planning is difficult for US citizens abroad. I have been writing a series of posts that describe the tax treatment of US citizens abroad in very specific circumstances. Few would imagine many of these circumstances. I have recently written about when US citizens abroad sell a principal residence and why US citizens abroad  should […]

Why US citizens in Canada should NOT invest in TFSAs or any other “Foreign Trust” (RRSPs excepted)

Not if you are U.S. citizen Introduction – U.S. citizenship has opportunities, liabilities and disabilities Living as a U.S. citizen outside the “Homeland” is at best difficult and at worst impossible. Those who wish to remain U.S. citizens and live outside the United States must live by the motto: “The difficult we do today. The […]

New Filing Compliance Procedures for Non-Resident U.S. Taxpayers – Effective September 1, 2012

Note: There is an updated version of this crossposted to the Isaac Brock Society. #Americansabroad with #FBAR and Tax problems – who worry about #FATCA #offshore accounts and #OVDP – new IRS program http://t.co/dQNqzarJ — U.S. Citizen Abroad (@USCitizenAbroad) September 1, 2012