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: Legal Issues
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”
Can the Common Law “Revenue Rule” be used to stop Enforcement of #CBTax on non-US Residents?
cross-posted from Storify/Expatriation Law INTRODUCTION In 1775 Lord Mansfield proclaimed “no country ever takes notice of the revenue laws of another.” In common parlance this means that the courts of one country will not enforce the tax laws of another country. It is articulated in the “The Conflict of Laws, Rule #3Continue reading “Can the Common Law “Revenue Rule” be used to stop Enforcement of #CBTax on non-US Residents?”
Alliance for the Defeat of Citizenship Taxation (ADCT) seeks major donors to fund United States lawsuit in federal District Court
cross-posted from Brock by Stephen Kish It is now likely that the new United States Tax “Reform” legislation will not help citizen-residents of other countries who are deemed to be “U.S. persons”. Consequently, we at the Alliance for the Defeat of Citizenship Taxation (ADCT), a non-profit corporation, want to move quickly on aContinue reading “Alliance for the Defeat of Citizenship Taxation (ADCT) seeks major donors to fund United States lawsuit in federal District Court”
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”
Parsing Proposed Legislation -Intended Confiscation or Not?
cross posted from The Isaac Brock Society Is there a duty to obey a law that was never intended to apply to you, even if the literal reading of he law suggests that it may/does apply? USCitizenAbroad says November 22, 2017 at 7:13 am @Karen notes: At theContinue reading “Parsing Proposed Legislation -Intended Confiscation or Not?”
Vulnerable Americans Abroad: Legal Weight of IRS Pubs, Info, FAQs = ZILCH!
An article by Virginia La Torre Jeker JD, at the angloinfo blog This is an excellent post. It clarifies how one can determine what the IRS really can (and can’t) do and in particular, points out how the OVDP program is NOT rooted in law. This is important for those who do not/never did belongContinue reading “Vulnerable Americans Abroad: Legal Weight of IRS Pubs, Info, FAQs = ZILCH!”
Citizenship Taxation 