— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) September 8, 2019
“Solving The Problems of U.S. Citizenship” and the FATCA Letter – Information Sessions
Before you rush to an accountant or lawyer in a panic, if you are close to any of these locations, check out one of these information sessions on Solving the Problem of U.S. Citizenship:
ADMISSION FEE $20 UNLESS OTHERWISE NOTED
- London, UK – Monday February 29, 2016 – Details here.
- Munich, DE – Thursday March 3, 2016 – Details here.
- Paris, FR – Saturday March 5, 2016 – Details here.
- Oakville, ON – Wednesday Jan. 21/15 – 6:30 p.m. – 8:30 p.m. – Oakville Public Library, 120 Navy St., Pro. Rm 2, L6J 2Z4 MAP – Details
- Toronto, ON- Wednesday Feb. 25/15 – 7:00 p.m. – 9:00 p.m. – Details
- London, UK – Monday March 2/15 – 6:30 p.m. – 8:30 p.m. – Details
- Innsbruck, Austria – Friday March 6/15 – Details
- Vienna, Austria – Saturday March 7/15 – Details
- Budapest, Hungary – Monday March 9/15 – 2:00 p.m. – 5:00 p.m. – Details
- Hamilton, ON – Thursday March 26/15 – 6:30 p.m. – 8:300 p.m. – McMaster Innovation Park, 175 Longwood Road S., Suite 105 Hamilton, ON L8P 0A1 MAP – Details
- London, ON – Thursday April 23/15 – 6:00 p.m. – 8:00 p.m. – Martha Bishop Room – Landon Branch Library (Landon and not London) – 167 Wortley Road, London, Ontario
- Toronto, ON – Sunday May 31/15 – 12:00 noon – 2:00 p.m. – Downtown Toronto – Details
- Vancouver, BC – Wednesday August 5/15 – 6:00 p.m. – 8:00 p.m. – Downtown Vancouver – Details
- Guelph, ON – Monday November 16/15 – 8:00 p.m. – 9:30 p.m. – University of Guelph – Details
- Toronto, ON – Saturday January 25/14 – 12:00 noon – 3:00 p.m. – Details
- Kingston, ON- Saturday February 1/14 – 1:00 p.m. – 4:00 p.m. – Details
- London, ON – Saturday February 8/14 – 1:00 p.m. – 4:00 p.m. – Details
- Toronto, ON – Saturday February 15/14 1:00 p.m. – 4:00 p.m.
- Vancouver, BC – Saturday February 22/14 – 2:00 p.m. – 5:00 p.m. – Details
- **NEW VENUE** London UK, Sun Mar 2,2-5 pm, The Church Hall, St Pancras Church House, Lancing Street, NW1 1NA CONFIRMED Cost – £15
- Toronto, Ontario – Saturday March 8/14 – 8:00 a.m. – 9:00 a.m.
- Waterloo ON, Sat Mar 8, 4-7 pm, Conrad Grebel Univ. College, 140 Westmount Rd. N., Waterloo, ON N2L 3G6 Rm 1300, Free parking CONFIRMED
- Hamilton ON, Tues Mar 11, 6-9 pm, TBA
- Montreal PQ, Sun Mar 16,12-5 pm, McGill Univ. Faculty of Law, 3644 Rue Peel, Chancellor Day Hall : Maxwell Cohen Moot Court (NCDH 100) CONFIRMED FREE Details
- NorthBay ON,Sat Mar 22,1-4 pm,Legion #23,150 1st Ave W,North Bay ON P1B3B9,Boardroom CONFIRMED
- **NEW**Burlington ON, March 27, 6-9pm, Burlington Public Library-Holland Room, 2331 New St, L7R 1J4 CONFIRMED – Details
- Richmond Hill ON,Sat Mar 29,Emmanuel Anglican Church,15 MacKay Dr,L4C 6N9 10am-12pm/1-3 pm CONFIRMED Details
- **NEW**Berlin,DE, Friday April 4, Venue & Details TBA, COST €15
- Munich,DE,Sat April 5, 2-5 pm, Eine WeltHaus München, Schwanthalerstr.80, München, Rm 211-212 (top floor) CONFIRMED Cost – €15
- Zurich,CH, Sun April 6, 12-4 pm, AWCZ ClubhouseSc, Schöntalstrasse 8,8004 Zurich,CONFIRMED 15CHF
- CALGARY AB,April 19, 2:30-5:30 pm, Kensington Legion, 1910 Kensington Rd NW, T2N 3R5 CONFIRMED ( Details ) – Debrief
- NEW Edmonton AB, April 20, TBA
- Toronto ON, Fri, May 2, 4:30-5:30pm, Carr Hall,100 St. Joseph St.,M5S 2C4 CONFIRMED Free admission for those attending the ACA conference Fri, May 2, 8:30am-4pm at University of Toronto – St. Michael’s College, Toronto, Canada
- OTTAWA ON, Tues, May 14, 6-8 pm, St. Paul University – 223 Main St. – Ottawa – debrief
- Toronto, ON, Saturday June 7 – 10:00 a.m. – 12:00 Noon – 100 St. Joseph St. – Room TBA – Seminar for young adults
- Vancouver, BC, Sunday June 22 – 11:00 a.m. – 1:00 Noon – Seminar for young adults
- Halifax, NS, Monday June 23 – 6:00 p.m. – 8:00 p.m. – Solving The Problems of U.S. Citizenship
- Moncton, NB, Wednesday June 25 – 6:00 p.m. – 8:00 p.m. – Seminar for young adults
- Fredericton, NB, Thursday June 26 – 6:00 p.m. – 8:00 p.m. – Solving The Problems of U.S. Citizenship
- Toronto, ON, Saturday July 19 – 10:00 a.m. – 12:00 noon – “Solving the problems of U.S. citizenship” – 100 St. Joseph St., Toronto, ON
- Dublin, Ireland, Tuesday August 12 – 6:00 p.m. – 8:00 p.m. – Solving The Problems of U.S. Citizenship – Quaker House, Stocking Lane, Rathfarnham, Dublin 16
- Belfast, Ireland, Wednesday August 20 – 6:00 p.m. – 8:00 p.m. –Solving The Problems of U.S. Citizenship – Belfast Castle, Antirim Road, Belfast, Antirim, Ireland BT15 5GR
- Toronto, ON, Monday August 25 – 7:00 p.m. – 9:00 noon – “Solving the problems of U.S. citizenship” – Beaches Presbyterian Church at 65 Glen Manor Dr. Toronto, ON
- Montreal, Quebec – Tuesday, September 23/14 – 7:00 p.m. – 9:00 p.m. – Solving The Problems of U.S. Citizenship – Atwater Library, 1200 Atwater (just below St. Catherine – Metro less than a block away).
- Paris, France – Monday October 6, 2014 – 6:00 p.m. – 8:00 p.m. – Location TBA
- Niagara Falls, ON (Niagara Region) – Solving The Problems of U.S. Citizenship – Tuesday November 11, 2014 – 8:00 p.m. – 10:00 p.m. – McBain Community Centre – Room A – 7150 Montrose Rd., Niagara Falls, Ontario L2H 3N3
- Toronto, ON, Sunday Nov. 30/14 – 6:30 p.m. – 8:30 noon – “Solving the problems of U.S. citizenship” – 100 St. Joseph St., Toronto, ON
Who: John Richardson
$20 donation to offset costs-payable at the door
Sessions are available in Canada and Europe. Full details and updates are here.
What is “U.S. Citizenship – Educational Outreach” and why was it created?
I have created an “Educational Outreach” program to educate “U.S. persons abroad” about topics of current interest including:
1. The state of your U.S. citizenship
2. Your tax obligations and U.S. extra-territorial taxation
3. Your “information reporting” obligations including FATCA
Why is this important?
It is estimated that there are 7 million U.S. citizens living outside the United States and approximately 1 million in Canada. Some of these people don’t even know that the U.S. may consider them to be citizens. The vast majority of these Americans abroad are (according to U.S. law) required to pay taxes to the United States. Although “citizenship-based” taxation has existed for years, what is new is the enforcement. In addition the U.S. has enacted FATCA (“Foreign Account Tax Compliance Act”) and the Harper Government has signed an “IGA” (Inter Governmental Agreement) to assist with enforcement.
The recent FATCA IGA signed between the Harper Government and the Obama administration has exacerbated the problems of having U.S. indicia. The following comment by 5thSwiss (which appeared on the Isaac Brock Society Society blog) demonstrates the staggering scope of people who will the ultimate targets of the “FATCA Round Up”. I urge you to read this comment at least twice:
This issue of US nationality is complex, and not all US nationals are alike in rights and obligations. To simplify, 14th Amendment citizens (born in the 50 States) are one class of citizen; those born or naturalised in territories are citizens under Organic Laws; those naturalised otherwise and those born abroad to one or both US parents with qualifying presence or residence are yet another class (of statutory citizens). Under present constitutional law one has the right to expatriate.
But wait, there is now a new category of attachment to the USA: “US Person” which includes Green Card holders and certain others. Thinking back, there was once another: those who took out First Papers (for naturalisation).
If you think of US nationality as “allegiance” — which it really is, based on old English Common Law — rather than a Christian, Civil-Law notion of “nationality”, then you may understand it better. This is why expatriation is, for the Congress, akin to apostasy (and your Web site, perhaps, to blasphemy!)
There comes, if not now then in the future, a time when the US will have reached its limit in bullying and cajoling. It has already exceeded its ability to enforce FATCA as against those who are not notorious in their US Person status.
But wait, there’s more: All persons with “a claim to US nationality” must use US passports when traveling to and from the USA. By extension, the IRS would like to enforce tax law against all such persons. But who has a “claim”? Let me cite two infants whose status I was recently consulted on, both born in Europe. Both have at least one US grandparent.
Child #1 was born to a person herself born abroad to US parents. She has never lived, and only very briefly visited on occasion, the USA. Her husband is a NRA. The child only has a “claim” to US nationality via expedited naturalisation under § 322 http://photos.state.gov/libraries/greece/38517/USCIS/US_citizenship_eligibility_section322INA.pdf
Child #2 was born abroad to an unmarried mother who lived, while the child was age 2-3, for 1½ years on the US side of the Canadian border. If, and only if, the child did not cross that border and interrupt one full year of presence in the USA, then (and only then) is the child a US citizen at birth. Otherwise the child could be naturalised under § 322. My understanding is that the State Department would (contrary to the terms of the law) disregard the mere possibility of the child having crossed the Canadian border and interrupted US presence unless that fact were brought to its attention.
But, as readers of this Web site will be aware, possession of US nationality is hardly an asset unless a person intends to live out his or her life in the USA.
Now, as to banks and other financial services providers as collection (or enforcement) agents of the IRS: that’s certainly true if and only if the bank is aware of its customer’s US Person status. There remain millions of US Persons abroad whose status is not obvious and as against whom enforcement, either by a bank or by the IRS, is wildly improbable, denunciation aside.
Denunciation is the key word: many cases are brought to the attention of the IRS by disgruntled, scorned women and angry business competitors.
Once the IRS is aware of a nonresident, noncompliant person’s defalcation it can pursue assess indirectly through correspondent accounts in the USA. But there are limits: http://uniset.ca/other/cs6/68OR2d379.html (Van deMark case: the Canadian bank wound up paying twice).