Canadian FATCA IGA Litigation cross-posted from Isaac Brock Society by Stephen Kish Now appears more likely that we will get to trial in January 2019 in our Canadian FATCA IGA enabling legislation lawsuit in Federal Court. The Case Management Judge has just advised: “The hearing of this summary trial motion shall take placeContinue reading “Canadian #FATCA IGA Litigation Update: Court has fixed Monday January 28, 2019 as trial date”
Category Archives: Ethics
It’s Happening Again – Enough is Enough is Enough
NB: STAY TUNED – a 7-part video on the Transition Tax, with John Richardson & Karen Alpert will be posted in the next couple of days. NB: For anyone with time to spare/the interest/needing specifics to make the point regarding the “intention” of the law, here are some of the relevant House/SenateContinue reading “It’s Happening Again – Enough is Enough is Enough”
Imposing Tax & Reporting Obligations on the Citizens & Residents of Other Countries is Immoral
https://www.taxconnections.com/taxblog/latest-podcast-guest-tax-attorney-john-richardson/#comment-15477 cross-posted from Tax Connections After the latest IRS Medic podcast, Tax Connections published a post by Anthony Parent. Perhaps the most unifying statement of the post is: A part of our interview that really stands out to me is when Attorney Richardson referred to the current system of global taxation and compliance asContinue reading “Imposing Tax & Reporting Obligations on the Citizens & Residents of Other Countries is Immoral”
The Current System of Global Taxation and Compliance is Immoral
cross-posted from Tax Connections UPDATE February 2,2018 For more on how an expat can have higher U.S. taxes than a comparably situated Homeland American, please see here. After the latest IRS Medic podcast, Tax Connections published a post by Anthony Parent. Perhaps the most unifying statement of the post is: A part ofContinue reading “The Current System of Global Taxation and Compliance is Immoral”
Meet the Proposed Commissioner of the IRS – A Welcome Change?
cross-posted from Brock. Politico announced Trump’s nomination Of Charles P. Rettig, including the following excerpts: Rettig, who specializes in settling complex tax disputes between his taxpayer clients and authorities like the IRS, known as tax controversies, has for more than three decades represented clients before the IRS, the Justice Department, state tax authorities and otherContinue reading “Meet the Proposed Commissioner of the IRS – A Welcome Change?”
The Conscience of a Lawyer and “The FBAR Fundraiser” Revisited
The compliance community leads the @USTransitionTax charge: "TCJA’s transition tax could hit cross-border biz owners" https://t.co/jQwJ1sUomM — U.S. Transition Tax – Subpart F (@USTransitionTax) January 24, 2018 https://platform.twitter.com/widgets.js Many of you may remember this outstanding post (below) from the early days……when the incessant torment was massive fear of “#FBAR penalties.” Compounded by #OVDP, (or #OVDIContinue reading “The Conscience of a Lawyer and “The FBAR Fundraiser” Revisited”
Appears U.S. can Suggest but Cannot/Will not Force Citizenship on Those Born Outside the Country
This post appeared at reddit. It is interesting that while the Consulate in Montreal asked “why we did not want to apply for citizenship of our son” several years later, there had been no efforts to impose or force it. This gentleman explains it as pressure however, the lack of any follow-through by theContinue reading “Appears U.S. can Suggest but Cannot/Will not Force Citizenship on Those Born Outside the Country”
The Nightmare for Mexicans who have US Citizenship………
The following comment appeared today at Brock. It is unbelievably shocking to see how this miserable situation is evolving-I have yet to hear anything like this. We have reached out a couple of times to try and link to the expat community in Mexico without results. I guess back then, this situation had notContinue reading “The Nightmare for Mexicans who have US Citizenship………”
Seven Simple Points to be Made Re: Transition Tax and CFCs
This comment from the Isaac Brock Society makes basic points to be made with regard to the proposed “Transition Tax” in both the House and Senate Tax Reform Bills. Every expat who knows there are private individuals who are incorporated in their country should be contacting relevant government representatives giving them theContinue reading “Seven Simple Points to be Made Re: Transition Tax and CFCs”
The Merry-Go-Round of “Unintended Consequences”
This provision is not designed to catch individuals (I think), and certainly not Americans abroad – they are collateral damage. it’s incredibly unfair. A little more than 10 days ago, an article by a Canadian tax lawyer claimed the proposed House Bill contained two very startling changes that would affect #AmericansAbroad: BAD NEWS FORContinue reading “The Merry-Go-Round of “Unintended Consequences””
Citizenship Taxation 