— U.S. Citizen Abroad (@USCitizenAbroad) September 13, 2015
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.
MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business.
Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s international fiscal treaties and dodge U.S. taxes. He predicts it will all eventually implode if American authorities claw back the taxes he believes Valeant may owe.
The Canadian businessman confirmed that he and three other individuals formed a group that made a formal presentation in 2012 to U.S. regulatory authorities, notably those in charge of taxation, denouncing Valeant’s tax strategy. In an interview this week, he called himself an “official whistleblower.”
The group alleges that Valeant’s merger with Canada’s Biovail in 2010 — which the group, among others, claim was more like California-based Valeant taking over Biovail — was a…
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“At stake is whether the United States will choose to be the Policeman of a “Pax Americana”, which is a recipe for disaster, or partner with other nations on the way to a safer, more just and more sustainable future”.
From time to time I have written posts call into question the “Official version” of America’s History. An example is the post on the book Liberty’s Exiles by Maya Jasonoff.
About a year ago I became aware of a book by Oliver Stone and Peter Kuznick called “A True History of the United States“. The book will be featured in a mini-series commencing next week. In any case here are two DemocracyNow.org interviews with the authors. They are very interesting. Pay particular attention to the last three minutes of the second interview where Mr. Kuznick talks about the effects of ON THE UNITED STATES of the Obama drone attacks.
For those who do not want to read this post. Here is the bottom line:
If you are a tax compliant U.S. citizen abroad, with a net worth of less than two million U.S. dollars, with investments (including mutual funds, pensions, and a principal residence in your country of residence), you should renounce your U.S. citizenship at the earliest possible moment. To the extent that your investments are in non-U.S. mutual funds, other kinds of PFICs or your principal residence, the U.S will confiscate large amounts of the proceeds of sale. (And you thought you were solving your problems be being tax compliant.)
Many Canadians are using their principal residence as their retirement plan. Their plan is to sell, downsize and live of the balance of the proceeds. This is NOT possible if you are a tax compliant U.S. citizen! You must NOT be a U.S. citizen at the time the investments are sold.
If you want to preserve your investments you must relinquish your U.S. citizenship to protect your access to your investments!
For those who want to understand why, read on …
Once upon a time there was a Canadian life insurance company. It’s name was Sun Life. Sun Life was founded in 1865 in Montreal (predating Confederation by two years). It was a proud Canadian institution. It was in the business of protecting families. The story of Sun Life parallels the history of the world since 1865. It is an international company with a presence in most of the developed world. It saw itself as a “good corporate citizen”. During World War II the wealth of Great Britain was stored in the Sun Life building in Montreal. During World War II the company provided entertainment for Canadian troops abroad. After World War II it helped “protect” the middle class of North America. The name “Sun Life” meant “trust”. If you want to learn about Sun Life, review a bit of history and understand Sun Life’s important role in Canadian history, I urge you to watch the video history of Sun Life financial.
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 not invest in TFSAs. I have written about why PFICs must be avoided.
My topic today is how the fluctuating exchange rates can create “phantom gains”. AARO has noted and proposed the following as part of legislative tax reform for US citizens abroad:
Based on current tax law, for Americans living abroad, currency fluctuations create U.S. dollar capital gains or losses even on daily transactions as well as on movements of short and long term investments done in local currencies. The exchange rate on the purchase date and the exchange rate on the sale date determine the capital gain for the U.S. Treasury.
Allow Bona fide foreign residents the option to choose a foreign currency as their functional currency and calculate all capital gains/ loss transactions in that currency before converting to U.S. dollars. The current average annual exchange rate with the U.S. dollar is then used to convert any gains/ losses into dollar amounts from the foreign currency. Since the use of a functional currency is allowed for foreign subsidiaries of U.S. corporations, it is only reasonable that a similar logic be applied to U.S. citizens abroad.
Obviously fluctuating FX rates are a problem for US citizens abroad. My inspiration for this post comes from the following comment by Lisa on the Isaac Brock Society site. Anybody who has taken out a mortgage loan will have to deal with this problem.
The Isaac Brock Society recently featured a discussion about how and when to advise young people about the potential problems of U.S. citizenship and whether they should consider renouncing U.S. citizenship. As parents, teachers, mentors and friends we should pass on to our young people the benefits of our (in varying degrees) knowledge, wisdom and experience. We do this because we want to equip them with the skills they need to make the best life decisions that they can.
The books: “Letters of A Businessman to His Son” and “Letters of A Businessman to His Daughter“, by G. Kingsley Ward, are wonderful examples of this principle. They are chock full of practical advice and thoughts on – the only business that really matters – “The Business of Life”.
I have been inspired by Mr. Ward. Here is the letter (with many factual modifications to protect the young person in question) that I wrote on the occasion of that young person’s High School graduation. Continue reading