#FATCA and the lowly Paypal account. Everybody answers to the accusation of having "USness"! #YouCantMakeThisUp! pic.twitter.com/F6fBf7Tlvv
— Citizenship Lawyer (@ExpatriationLaw) March 20, 2016
#FATCA and the lowly Paypal account. Everybody answers to the accusation of having "USness"! #YouCantMakeThisUp! pic.twitter.com/F6fBf7Tlvv
— Citizenship Lawyer (@ExpatriationLaw) March 20, 2016
Baby girl drawn into CRA-IRS information sharing controversy https://t.co/2FG6cEdNZV – What if that 8 month year old is a "US Person"?
— Citizenship Lawyer (@ExpatriationLaw) April 18, 2016
Escalating housing prices in Toronto leave buyers with sticker shock and owners reaping capital gains @globeandmail https://t.co/AALQfnTVqg
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 22, 2017
The price of Toronto real estate continues its upward trajectory.
This morning I met with yet another (who could have known) Canadian resident who wishes to renounce U.S. citizenship. This person is completely compliant with his U.S. tax obligations. He is renouncing for a very common reason.
The reason for renouncing U.S. citizenship is to:
Protect the tax free capital gain, which results from the sale of his Canadian principal residence in Canada.
Continue reading
As 2016 comes to an end …
Received #greatholidaynews today from two "ecstatic" renunciants who confirm that the wait time for CLNs is down to 2 – 3 months in Canada!
— Citizenship Lawyer (@ExpatriationLaw) December 17, 2016
I suspect that history will show that that the growth in renunciations of U.S. citizenship (and abandonment of Green Cards) continued in 2016. Absent a change in the way that the United States treats its “U.S. Persons Abroad”, I suspect that the growth in renunciations of U.S. citizenship will continue.
The purpose of this post and a short summary …
This blog post will hopefully encourage those with U.S. tax issues to consider whether they can deal with minor/unintentional FBAR violations as a “stand alone single problem”. There may be no need to escalate and expand one single problem into a multi-dimensional full blown tax problem that may end up with unintended and unanticipated costly professional fees as well as undue time spent! Read on and learn why. Keeping a calm head is most important, even if it is most difficult to do in the face of the scary situation of not being in compliance with the U.S. tax and regulatory regime.
This post consists of the following six parts:
Part 1 – Problems, more problems and the expansion of problems
Part 2 – Looking For Mr. FBAR
Part 3 – It often begins with a chance meeting with Mr. FBAR
Part 4 – How the compliance problems of “Homeland Americans” (particularly Green Card holders) differ from the compliance problems of “Americans Abroad”
Part 5 – Focusing specifically on the problem of FBAR non-compliance
Part 6 – Dealing with the tax professionals: Beware of how they can expand the number of problems
_____________________________________________________
Continue reading
Prologue – A law firm perspective …
As reported by Chelco Vat:
The law does not make dual citizenship illegal; it is merely a reporting requirement.
Federal Law No. 142-FZ on Amendment of Articles 6 and 30 of the Federal Law on Russian Federation Citizenship and Individual Regulations of the Russian Federation, which took effect on 4 August 2014, makes it a criminal offence for Russian nationals to conceal dual citizenship or long-term residence abroad.
Hmmmm … ONLY a reporting requirement you say …
The perspective of an individual subject to the citizenship-reporting requirement …
Russia’s Unwelcome Citizens https://t.co/huX8XlLEaA – Russians with dual citizenship are required to report their non-Russian citizenship!
— Citizenship Lawyer (@ExpatriationLaw) November 22, 2016
The above tweet references an article in the New York Times discussing Russia’s law that requires all Russians with a second foreign citizenship report that foreign citizenship to the Government.
Continue reading
Via @NPR: Steven Seagal Is Now A Citizen Of Russia, Courtesy Of Putin https://t.co/oIthR1Ka4c – Welcome to the Russian version of Mr. #FBAR
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 22, 2016
It has been widely reported that American actor Steven Seagal has joined American boxer Roy Jones in becoming a citizen of Russia. By becoming Russian citizens, Mr. Seagal and Mr. Jones are now subject to Russia’s Currency laws, which include the requirement to report their non-Russian bank accounts to the Kremlin. Messrs Seagal and Jones may admire Russia. That said, it’s clear that the Kremlin admires the U.S. Treasury in general and Mr. FBAR – America’s most important citizen – in particular.
Citizenship-based reporting: Mr. FBAR as a role model for President Putin and the Russian government …
Citizenship-based reporting: Russian nationals required to report on movements on their foreign bank accounts https://t.co/as9QyUhjSl
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 22, 2016
Although Russia has “residence-based taxation” it has “citizenship-based reporting”.