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Tag Archive for FATCA

Part 11 – Understanding “Exit Taxes”

S. 2801 of the Internal Revenue Code is NOT a S. 877A “Exit Tax”, but a punishment for the “sins of the father”

Updated September 12, 2015 – the IRS has issued “proposed rules”  governing the issue of “The sins of the father”.

The following was a comment on Part 9 of this “Exit Tax” series.

“I know many tax compliant, patriotic Americans who have renounced. Many have done so seeing the $2m threshold approaching, to protect their families and get on with their lives. All with heavy hearts.

You did not mention the additional burden on those who renounce who have US citizen relatives–the tax their Read more

Part 10 – Understanding “Exit Taxes”

The S. 877A “Exit Tax” and possible treaty relief under the Canada US Tax Treaty

Introduction – The Canada U.S. Tax Treaty Does Not Always Prevent Double Taxation

See: Part 9 – Understanding “Exit Taxes” – For #Americansabroad: US “citizenship taxation” is “death by a thousand cuts”, but the S. 877A Exit Tax is “death by the guillotine”.

When countries independently make major changes in tax law, double taxation can occur.

The following comment from 5thSwiss on the Isaac Brock Society site explains why and how double taxation can be a reality. It also underscores the dangers of a U.S. citizen leaving the United States. Read more

Unprecedented Success for US Offshore Amnesty Programs!

According to the Internal Revenue Service:

Since OVDP Began in 2009, There Have Been > 54,000 Disclosures!
The IRS has collected > $8 Billion.

We previously discussed this in our post “Offshore Compliance Programs Generate $8 Billion” However, the figures have risen sharply since the IRS’ last progress report in January this year, when it announced that the OVDP schemes had attracted 54,000 disclosures and USD7 billion in tax.

It is believed that most of the additional 30,000 taxpayers who have volunteered since then, have been attracted by the ‘streamlined’ program launched in June 2014 for ‘non-wilful’ taxpayers. This program originated from the IRS’ Read more

Offshore Compliance Programs Generate $8 Billion

IRS Urges People to Take Advantage of Voluntary Disclosure Programs… You Think?

The IRS released IR-2015-116 on Oct. 16, 2015, to remind U.S. taxpayers with undisclosed offshore accounts, that with more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, they should strongly consider existing paths established to come into full compliance with their federal tax obligations.

Both the Offshore Voluntary Disclosure Program (OVDP) and the streamlined procedures enable taxpayers to correct prior omissions and meet their federal tax obligations while mitigating the potential penalties of continued non-compliance. There are also separate procedures for those who have paid their income taxes but omitted Read more

IRS Offers FATCA Guidance For Trusts & Partnerships

TaxConnections

The IRS posted FAQ’s today on the effective dates of FATCA agreements for entities that apply on or after April 1 to be withholding foreign partnerships or withholding foreign trusts.

Qualified Intermediaries: Withholding Foreign Partnerships/ Withholding Foreign Trusts

Q1. How does a Financial Institution that is not currently a Qualified Intermediary (“QI”), a Withholding Foreign Partnership (“WP”), or a Withholding Foreign Trust (“WT”) register to become one?
Q2. How do FIs that are currently QIs, WPs and WTs renew their agreements?
Q3. I am not currently a QI/WP/WT.  Can I use the LB&I registration portal to register for Read more

US Increases Fee For “Relinquishment of Nationality” – Maybe It Is Worth The Increased Cost?

On Thursday, September 5, 2014, we posted The Cost To Renounce Your US Citizenship Just Increased By 422%  where we discussed that the number of Americans renouncing U.S. citizenship stayed near an all-time high in the first half of the year before rules that make it harder to hide assets from tax authorities came into force (FATCA – Effective Date July 1, 2014) and how the State Department interim rule just raised the fee for “Renunciation of U.S. Citizenship” to $2,350 from $450. Critics noted that it’s more than twenty times the average level in other high-income countries. The State Department says it’s about demand on their services and all the extra workload they have to process people who are on their way out.

For the second time in a year, the State Department just did another hike which Read more

Part 2 – Understanding “Exit Taxes”

Part 2 – Understanding “Exit Taxes” in a system of residence based taxation vs. Exit Taxes in a system of “citizenship (place of birth) taxation

Let’s begin with some politics …

In an interesting post Robert Wood writes:

Both Mayor Johnson and Senator Cruz are U.S. citizens. Both Mayor Johnson and Senator Cruz either have or are renouncing the citizenships of the countries where they were born. There will no tax consequences to Senator Cruz for renouncing Canadian citizenship. Mayor Johnson will probably be spared America’s draconian “Exit Tax” (assuming he was born a dual citizen) for renouncing U.S. citizenship. The “Exit Tax” Read more

Trouble In Paradise

Former Congressman Barney Frank recently remarked that the financial reform law that partially bears his name is in a unique position, because “No program in American history could more clearly combine two elements: great success and absolute unpopularity.” While the jury is still out on the “great success” of Dodd-Frank, there is no doubt that everyone hates it.

Many Democrats, especially progressives like Senators Bernie Sanders and Elizabeth Warren, don’t think the law went far enough towards reigning in the big banks. There is even talk in some quarters about blowing the dust off the Depression-era Glass-Steagall Act, which might effectively break up Wall Street banks the way the government broke up Ma Bell a generation ago. Read more

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