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: Law & Morality
March 22, 2018 Canadian FATCA IGA Litigation in Federal Court Update: New Timetable
Canadian FATCA IGA litigation UPDATE March 22, 2018 The attorneys for our side (our side are Plaintiffs Gwen and Kazia, the Alliance for the Defence of Canadian Sovereignty — the “client”, and our supporters) and the attorneys for Mr. Justin Trudeau’s Government have just agreed on the timing for the next steps of our CanadianContinue reading “March 22, 2018 Canadian FATCA IGA Litigation in Federal Court Update: New Timetable”
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”
U.S. Tax Culture Sees Individual Using a Small Corporation as a “Presumptive Tax Cheat”
This post is an actual comment by John Richardson that appeared here (PAYWALLED) You can see the article on the citizenshiptaxation facebook group Financial Times Americans abroad hit by Trump’s new repatriation tax rules by Andrew Edgecliffe-Johnson in New York – FEBRUARY 4, 2018 My comment to the article on theContinue reading “U.S. Tax Culture Sees Individual Using a Small Corporation as a “Presumptive Tax Cheat””
The Attributes of Immoral Laws or How the Internal Revenue Code Applies to Non-Resident Taxpayers
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 as immoral.Continue reading “The Attributes of Immoral Laws or How the Internal Revenue Code Applies to Non-Resident Taxpayers”
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”
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”
Why the proposed transition tax, if applied to individual U.S. shareholders living abroad, is analogous to the “Offshore Voluntary Disclosure Program
The following was written by John Richardson and is a section of a larger piece yet to be published. I will provide the link at the time it is available and of course, have permission to publish this. When I first read this, two things occurred to me. The OVDP/OVDI process represented aContinue reading “Why the proposed transition tax, if applied to individual U.S. shareholders living abroad, is analogous to the “Offshore Voluntary Disclosure Program”
Citizenship Taxation 