Monthly Archives: June 2014

@Taxpolblog "Conference on Tax Justice and Human Rights" – June 18 – 20/14 #TJHR

Looks like this was a great conference! What follows are the tweets.
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Unintended consequences: How 911 made the lives of #Americansabroad hell

Interesting article by Byron Toben includes:
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@SaundersWSj and Liam Pleven article on life as #Americansabroad

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Which U.S. consulate is best for relinquishments of US citizenship?

Once upon a time, before FATCA, before “The FBAR Fundraiser” and before the “Offshore Jihad” people wanted U.S. citizenship. Times have changed.  The U.S. government is making the lives of Americans abroad   (particularly in Switzerland) very unhappy and very uncomfortable. As a result, renunciations and relinquishments of U.S. citizenship are rising. Many more Americans abroad are simply vanishing from the map – AKA informal relinquishments.
The short answer is I don’t know. This can depend on the person and on the consulate itself. The more important consideration is to be very well prepared and understand your grounds for relinquishment well in advance. In general, I am finding that those who put care into the preparation of their material are much more successful than those who don’t. (Who could have known?)
It is clear that the U.S,. government is NOT predisposed to allow people to sever their ties with the U.S. (I honestly can’t understand why).
In any case, the above tweet references an interesting and illuminating comment at the the Isaac Brock Society:
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Are those without a U.S. connection U.S. citizens? What sports can teach us about citizenship

Sooner or later the debate about U.S. “place of birth taxation”, will focus on the meaning of citizenship and connection to the country of citizenship. What’s needed to get the discussion going? Sometimes, the most unlikely events (although they are obvious after the fact) become the catalyst.
It turns out that the U.S. World Cup Soccer team has (are you ready for this):
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#FBAR Lawyer – Needed by Americans in Switzerland

Introduction – It’s about “disclosure” and penalties for “non-disclosure”
On June 9, 2014 U.S. lawyer Robert Wood wrote a short but interesting article titled: “Offshore Bank Letters, FATCA & IRS Penalties – Are There Any Choices Left?“.
The article included:

With the impending FATCA compliance rollout and the U.S. Justice Department deal for Swiss banks, there are lots of letters and phone calls being made to account holders with American indicia. American citizens, residents—even people with a U.S. address or phone number—should be prepared. Possible American status means proving you’re compliant with the IRS or proving you’re not American after all.
Some people react like a deer in the headlights. But the bank’s letter or call is unlikely to evaporate. Failing to respond in any way is likely to mean the bank will close your account, if it isn’t closed already. Banks routinely turn over the names of closed accounts, and may even be more likely to disclose closed accounts than active ones..
Swiss banks are the most serious, since they are trying to get better penalty categories for themselves. But FATCA, the Foreign Account Tax Compliance Act, is also taking some blame. The U.S. can penalize foreign banks if they don’t hand over Americans.

Mr. Wood’s article alludes to a number of different topics. FATCA is unrelated to the U.S. attack on Swiss banks. But, Americans abroad are clearly under siege. Those in Switzerland are under the most pressure (at the moment).  The community of Americans abroad should pay attention. Without international “pushback” there is nothing to prevent the U.S. from using the attack on Swiss banks as a blueprint to attack the banks in other countries. Why would these banks be attacked?  It’s because they are suspected of allowing those with a U.S. birthplace (can you imagine a greater crime?), to hold bank accounts.
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#FATCA – A US law to keep the poorest nations poor

So, what’s FATCA anyway?
FATCA means so many different things to so many different people. FATCA is versatile. FATCA accomplishes so many things in so many different ways. It affects so many different people in so many different ways.
Therefore, the answer to the question:
What is FATCA?
Depends on who you ask.
For example:
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