Tag Archives: Alliance For The Defence of Canadian Sovereignty

Thoughts on the @ADCSovereignty #FATCA Trial 1: 2015 interview with @AliBrunet underscores which people are primarily affected by FATCA in Canada

What the Canada U.S. FATCA IGA is NOT about
Canada’s FATCA IGA is NOT about information exchange. The United States does NOT exchange information under the FATCA IGAs.
Canada’s FATCA IGA is not about residency. After all the purpose of FATCA is to transfer information from a country where the person DOES actually reside (and is a tax resident) to a country where the person does NOT actually reside (but is deemed to be a tax resident).

What the Canada U.S. FATCA IGA IS about

Canada’s FATCA IGA IS about the Government of Canada surrendering its citizens to the United States (effectively stripping them of their rights as Canadian citizens).
Canada’s FATCA IGA is about assisting the United States in imposing worldwide taxation on Canadian citizens who actually live in Canada, are tax residents of Canada and pay full taxes in Canada. Transition Tax anyone? Do you feel GILTI today? What were you thinking by buying that Canadian mutual fund in Canada?
Canada’s FATCA IGA is NOTHING like the OECD Common Reporting Standard. In simple terms, under the CRS information is transferred from a country where the person does NOT live to a country where he does live.
Yes, Canada’s lawyers spent the week of January 28, 2019 to February 1, 2019:
1. Denying each of these obvious points; and
2. Arguing that Canada that Canada has a constitutional right to betray its citizens by turning them over to the United States.
Post 1 – February 17, 2019:
The U.S. claim of lifetime tax jurisdiction based ONLY on the fact of having been born in the United States
This is based on a post from March of 2015 which was about the number of so called “Accidental Americans” in the Eastern Townships of Quebec.
Let’s start by listening to the CBC interview with Ali Brunette.
Question:
Do these life long residents of the Quebec Eastern Townships (great ski country) seem like U.S. tax evaders to you?

OVDI Refund: On the one hand #Americansabroad should "beware" and on the other hand they should "be aware"

beaware
It’s been a week of “ups and downs”. As you know, the Republicans Overseas lawsuit was NOT successful in obtaining an injunction. The Alliance For Canadian Sovereignty was NOT successful in obtaining their own injunction in the Canadian lawsuit. The rulings in both lawsuits included judicial observations, and were supported by affidavits, that are likely to be helpful as these lawsuits continue. These “observations” are good news.
But, on the “coming into U.S. tax compliance front” I bring you some additional good and interesting news.
I am happy to report (with the permission of the taxpayer, although the specifics of the information continue to be privileged) that:
A U.S. citizen abroad, who had NOT been filing U.S. taxes and who entered the Offshore Voluntary Disclosure Program (“OVDI”) in August 2011 (do  you remember that month?), has just received a full refund for the amount of the penalties that she paid under “OVDI” (well in excess of $100,000). The payment of the “in lieu of” penalty” was made with the initial “OVDI” submission in 2011. She did not receive a refund of the taxes and interest (which were very minor amounts)  or her legal and accounting fees (approximately $50,000).
After entering “OVDI” in 2011, filing eight years of back tax returns,  and paying an “in lieu of” penalty of approximately $120,000, she transitioned into “Streamlined” (which first became available in 2012). The bottom line is that she received a refund of all penalties paid under “OVDI”.
My point in writing this post is to illustrate that “compliance issues” can have better and worse outcomes. (Obviously the outcome depends on the “facts and circumstances” of one’s specific situation.) Given that this taxpayer, “voluntarily” (on the advice of lawyers) entered “OVDI”, this strikes me as an extremely good outcome. Furthermore, this outcome could not have been anticipated at the point of entering “OVDI” in 2011. Therefore, it’s important to understand that the resolution to compliance (or non-compliance) issues is always in a state of evolution.
Note that in 2012, the “OVDI” program was renamed “OVDP” (which continues to exist).
This story suggest that:
On the one hand, you should BEWARE, but
On the other hand, you should BE AWARE.
Finally …
The current “OVDP” program is suitable ONLY for those who have been committed “willful” tax and compliance omissions. You should NOT enter “OVDP” without being advised by at least three lawyers (who don’t know each other).
John Richardson
 
 
 
 
 
 
 
 
 

CBC #FATCA Interview: @SusanCBCQuebec and @AliBrunet – @ADCSovereignty lawsuit mention

FATCA awareness in the Quebec Eastern Townships


 
The interview and discussion – March 30, 2015


 


 
Feedback and discussion invited


This is a good opportunity to engage the people of Quebec on the issues caused by FATCA and U.S. citizenship taxation. In Standtead Quebec approximately 25% of the town residents, including the Mayor Phillippe Dutil (featured in the interview), were born in Vermont, U.S.A.
I guess there must be a few FATCA border babies in Stanstead.
CBC Quebec AM is seeking your comments. Your options are:
Phone –
1 888 691 3476
Email –
quebecam@cbc.ca
Facebook –
https://www.facebook.com/cbcquebecam/posts/10153262768318140
 
Updated – March 31, 2015 – Some thoughts for the residents of Stanstead, Quebec
Continue reading