NO Evidence of Intent to apply the “”Transition Tax” to Small Business Corporations of #AmericansAbroad

  It appears that we are very likely at a breaking point in this intolerable situation faced by expatriates as regards U.S. application of citizenship-based taxation. Tax reform does not happen often. It is critical that relief for expats occur in the current legislation. Many of us simply will not be around in 30 yearsContinue reading “NO Evidence of Intent to apply the “”Transition Tax” to Small Business Corporations of #AmericansAbroad”

US tax reform bill appears to confiscate 12% of retained earnings of certain Canadian Controlled Private Corporations

  UPDATE November 9, 2017 Today Chairman Brady concluded the “Mark Up” period of his proposed tax legislation. The “Mark Up” period contained NO move to “territorial taxation” for individuals. It did increase increase the “proposed confiscation” of the retained earnings of certain Canadian Controlled Private Corporation, from 12% to 14%. Renunciations to increase!: BradyContinue reading “US tax reform bill appears to confiscate 12% of retained earnings of certain Canadian Controlled Private Corporations”

Hands Down this is the Worst Academic Piece About FATCA ever Written

  CONSIDERING "CITIZENSHIP TAXATION":IN DEFENSE OF #FATCA– Hands Down Worst Academic Piece About FATCA ever Written https://t.co/qYvsrzpEyL — Patricia Moon (@nobledreamer16) May 27, 2017   Profesor Paul Caron, on his TaxProfBlog posted the following article: CONSIDERING “CITIZENSHIP TAXATION”: IN DEFENSE OF FATCA 20 Fla. Tax Rev. 335 (2017): by Young Ran (Christine) Kim   IfContinue reading “Hands Down this is the Worst Academic Piece About FATCA ever Written”

Irony-“Because it’s the Law” – For once, NOT applied to non-willful expats but a “citizenship” Lawyer

ON Lawyer remains in Poland as Law Society files notice of motion 4 interlocutory suspension or restriction https://t.co/dDaFdcxegz — Homelander NOT (@Homelander_NOT) May 15, 2017 //platform.twitter.com/widgets.js While this particular post is not about a tax-compliance professional per sé, it IS about a person with whom many of us have had interactions and from whom weContinue reading “Irony-“Because it’s the Law” – For once, NOT applied to non-willful expats but a “citizenship” Lawyer”

When Law Becomes a Substitute for Morality & Causes Cruel & Unneccesary Harm

    Another comment deserving its own post USCitizenAbroad says March 13, 2017 at 7:08 am @Karen and all Thank you for collecting and posting these stories. Our Stories I would like to offer some general observations (of which Shaun is one of many examples) and suggest some lessons which are largely based on Shaun’sContinue reading “When Law Becomes a Substitute for Morality & Causes Cruel & Unneccesary Harm”

Burning Down Barns is not Wrong Because it is illegal; it is illegal Because it is Wrong

  Burning Down Barns is not Wrong Because it is illegal; it is illegal Because it is Wrong   Burning down barns is not wrong because it is illegal; it is illegal because it is wrong PERFECT description #FATCA https://t.co/6KSAQRRkrT pic.twitter.com/twozrKiAUr — Citizenship Taxation (@CitizenshipTax) March 8, 2017 //platform.twitter.com/widgets.js   Every #Americanabroad (along with his/herContinue reading “Burning Down Barns is not Wrong Because it is illegal; it is illegal Because it is Wrong”

When law becomes a substitute for morality

When law becomes a substitute for morality reblogged from the renounceuscitizenship wordpress blog Today I’ve decided that I would like to go back and reblog some of the best expat posts from the last five years. For lack of a better title, I am going to call it the “A Blast From the Past Series.”Continue reading “When law becomes a substitute for morality”

Do Canadian (or Australian etc.) Tax Attorneys Advising Canadian Clients on United States IRS Compliance Typically Comply With The “Professional Code of Conduct” of Their Law Societies?

cross-posted from Isaac Brock Society In a recent post I mentioned the situation of a “Caroline” who seeks advice from a Canadian tax attorney (let’s say in B.C.) regarding a question of (IRS) tax compliance with a country foreign to Canada. How should the Canadian tax attorney advise this frightened Canadian citizen– specifically, regarding theContinue reading “Do Canadian (or Australian etc.) Tax Attorneys Advising Canadian Clients on United States IRS Compliance Typically Comply With The “Professional Code of Conduct” of Their Law Societies?”

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