Tag Archives: ACA

Whether through regulation or legislation #FATCA Same Country Exemption won’t work

In the beginning there was Facebook …

and from a second Facebook group:

 

Introduction: If you were to REPEAL FATCA

A previous post discussing the what exactly is meant by FATCA and the Mark Meadows “Repeal FATCA” bill, described:

FATCA is the collective effect of a number of specific amendments to the Internal Revenue Code which are designed to target both (1) Foreign Financial Institutions and (2) Those “U.S. Persons” who are their customers.

1. There are “Three Faces To FATCA” which include:

– Face 1: Legislation targeting Foreign Financial Institutions (Internal Revenue Code Chapter 4)

– Face 2: The FATCA IGAs (which for practical purposes have replaced Chapter 4)

– Face 3: Legislation targeting individuals (primarily Americans abroad who commit “Personal Finance Abroad – While Living Abroad” – Internal Revenue Code 6038D which mandates Form 8938)

2. The amendments to the Internal Revenue Code that would be necessary to reverse the sections of the Internal Revenue that created FATCA.

Legislative FATCA vs. Regulatory FATCA

The sections of the Internal Revenue Code that comprise “FATCA” are surprisingly few.

FATCA Face 1: Internal Revenue Code S. 1474(f) gives Treasury broad authority to make “FATCA regulations”.
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Even in “retirement” Jackie Bugnion writes the best arguments against citizenship taxation ever

This article originally appeared on the Alliance For The Defence Of Canadian Sovereignty blog.

Introducing Jackie Bugnion …

Jackie Bugnion has published a superb article describing the problems of U.S. citizenship taxation and why the United States must move to residence based taxation. Before, describing her article, for those who don’t know …

On May 7, 2015 I received notification that Jackie Bugnion had submitted her resignation to the Board of ACA “American Citizens Abroad“. I read the notification with a combination of sadness and total appreciation for the incredible efforts that Jackie has made in advocating for the rights of Americans Abroad. Jackie was largely responsible for organizing the “Citizenship Taxation Conference” (featuring the debate between Michael Kirsch and Bernard Schneider) that took place in Toronto on May 2, 2014. Some of you may have had the privilege of meeting her there. It’s unlikely that she could be replaced by any one individual.
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Excellent @JackieBugnion and Roland Crim article on Boris Johnson @MayorOfLondon and plight of #Americansabroad

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Charles Cullen, Bernard Schneider, David Kuenzi, Jim Yager, Jackie Bugnion (left to right)

Charles Cullen, Bernard Schneider, David Kuenzi, Jim Yager, Jackie Bugnion (left to right)

 

Just received this article in written by Jackie Bugnion and Roland Crim pdf format. Jackie was in Toronto on May 2, 2014 for the ACA Conference on the Taxation of Americans Abroad. (The conference was a great success leading to many things including David Kuenzi’s New York Time’s Op-Ed explaining that the application of the FATCA rules to Americans abroad is absurd. You will find a report on the Conference here.)

The article is an exceptionally clear statement of the problems facing Americans who choose to live outside the United States. The problem is that by moving form the United States and by being subject to the U.S. tax system that are:

1. At an extreme disadvantage when it comes to retirement planning; and

2. When it comes to U.S. taxation abroad – getting the worst of both worlds.

Here is the article:

Bugnion-Crim

“Changes in the US Tax Laws: How they impact US Citizens in the UK” @ACAVoice Event

 

The following event organized by ACA may be of interest to a “world-wide” audience. It is modestly priced and available by webinar.

“Changes in the US Tax Laws: How they impact US Citizens in the UK”
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