“Canada is expected to defend the constitutional rights and freedoms of its citizens and not bargain them away or capitulate to threats from a foreign bully state.” say Plaintiffs Gwen and Kazia in 12/13/2018 Canada Federal Court FATCA submission — Plaintiffs go to court January 28, 2019 and will ask for your support, later, for the appeal costs
cross-posted from Brock by Stephen Kish …and Plaintiffs go on to say: “The notion that a foreign state could indirectly cause the violation of a Charter right in circumstances where Canada could not do so directly simply cannot be accepted. This is a deeply illiberal proposition and it would undermine the principle of the rule…
Part 27 – While addressing some Sec. 965 @USTransitionTax concerns, there is NO EVIDENT CONCERN from @WaysandMeansGOP for the injustice inflicted on Americans abroad
cross-posted from citizenshipsolutions Introduction – “Indifference being the worst form of abuse” https://twitter.com/ExpatriationLaw/status/1068157453974585344 A quick summary of this post: On November 26, 2018 the House Ways and Means Committee under the leadership of Chairman Brady announced a bi-partisan bill which contains a number of “Technical Fixes” to the December 22, 2017 Tax Cuts and Jobs…
Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn Part C
cross-posted from citizenshipsolutions Part A is here Part B is here continued from Part B: 5. Why most Americans abroad are like most small business owners in America (and presumably should have similar tax treatment from a U.S. perspective) It’s simple. The vast majority of Americans abroad who carry on business through Canadian Controlled Private…
What if Meghan Markle’s child is born a U.S. citizen? Would the child have any immediate tax and information reporting requirements to the IRS?
-posted from Quora John Richardson Toronto lawyer: FATCA U.S. tax + renunciation of citizenship CitizenshipSolutions John Richardson, Lawyer (1982-present) Answered Mon What if Meghan Markle’s child is born a U.S. citizen? Would the child have any immediate tax and information reporting requirements to the IRS? I note that the question (1) assumes that…
Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn (Part B)
cross-posted from citizenshipsolutions Part A is here . 1. What exactly is an S Corporation? An “S corporation” is a corporation which elects a specific kind of tax treatment under the Internal Revenue Code. It is NOT a type of corporation. Rather it is the “tax treatment” used by a corporation. (A corporation can be…
Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn (Part A)
cross-posted from citizenshipsolutions This post is in 3 parts, published over 3 days. Beginnings … A recent comment at the Isaac Brock Society includes: It’s too bad I didn’t put my Canadian corporation in an S Corp before I knew I was a US taxpayer. I must have misplaced my crystal ball at the time.…
John Richardson and Monte Silver: The Sec. 965 Transition Tax & Sec. 951A GILTI Taxes – Next steps
https://www.youtube.com/watch?time_continue=14&v=nl-NH_oyUEs The US wants to “raise funds” by imposing taxation on the undistributed earnings of Canadian Controlled Private Corporations. Lawyer Monte Silver needs to “raise funds” to stop them. You can help! this section cross posted from Brock A message from one Canadian resident … https://twitter.com/suzanneherman1/status/1062494561199509504 When life is stranger than fiction … https://twitter.com/USCitizenAbroad/status/1062589827659558912 It’s…
John Richardson and Karen Alpert Session in Brisbane Australia Oct 25, 2018
Retain or Renounce US Citizenship with John Richardson and Karen Alpert VIDEO PDF John will also be doing information sessions in Sydney (Nov 1) and Auckland (Oct 31). See details and email the address given to register.
Considering renouncing US citizenship? @Expatriationlaw information sessions Fall 2018
A series of information sessions (some formal presentations and some informal discussions); for information concerning the content of the programs please see here. John Richardson is a Toronto citizenship lawyer, the co-chairman of the Alliance for the Defence of Canadian Sovereignty as well as the Alliance for the Defeat of Citizenship Taxation. He is a…
CANADIAN FATCA IGA LAWSUIT UPDATE: October 3, 2018 Plaintiffs’ Memorandum of Argument Has Been Submitted to Canada’s Federal Court
cross-posted from Brock. by Stephen J. Kish CANADIAN FATCA IGA LAWSUIT UPDATE Here is the Memorandum of Argument of our Plaintiffs (Gwen and Kazia) for our FATCA IGA legislation lawsuit that was submitted on October 3, 2018 to Canada’s Federal Court. [Note that text is limited to 30 pages.]…
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