The World’s Favorite New Tax Haven Is the United States https://t.co/Zu0TJOlJas via @business – Bc @TaxHavenUSA will not exchange info — Citizenship Lawyer (@ExpatriationLaw) February 2, 2016 How Secrecy Is […]
Introduction – FATCA is really about extending the U.S. tax base into other nations … In other words, FATCA is more about the “creation of taxable income” than it is […]
Introduction – FATCA and U.S. residents In Part 10 of this series of FATCA posts, I discussed the meaning of “U.S. Person”. The vast majority of people affected by FATCA […]
The purpose of this post is to highlight: who are the targets of the “FATCA inquisition” under the FATCA IGA; and who will not turn up in the “FATCA inquisition” […]
FATCA Hunt: "Review, Identify, Report" on possible "USness" in acct of Canadian born teenager https://t.co/Pf3tuNFMOK – Beware of RBC Way! — Citizenship Lawyer (@ExpatriationLaw) January 17, 2016 The above tweet […]
FATCA is about withholding and reporting. The basic principle is that a financial institution will: 1. Withhold payments unless the “RIR” (“Review, Identify and Report”) rule has been satisfied; and […]
On May 13, 2014, Calgary lawyer Roy Berg appeared as a witness before the House Finance Committee in Ottawa. His testimony was in relation to Bill C – 31 AKA […]
Introduction Part 5 of this series introduced the idea of the “Great FATCA Entity Hunt”. The key is to seek “USness” hiding behind ANY entity anywhere in the world. Not […]
Introduction … The difference between “Individual” and “Entity” accounts FATCA-eng If you read Annex 1 of the IGA (starting on page 20) you will that it distinguishes between “Individual Accounts” […]
In previous posts I have described how the FATCA Inquisition has been used to determine whether the beneficial owners of various associations (PTA) small businesses (New Zealand law firms) are […]