Tag Archives: Jackie Bugnion

Why is the United States imposing full U.S. taxation on the Canadian incomes of Canadian citizens living in Canada?

This is post is based on one of two submissions that I submitted in response to Senator Hatch’s request for submissions regarding tax reform.

Responding to Senator Hatch’s request for Feedback on Tax Reform

From:

John Richardson

Toronto, Canada

citizenshiptaxation@gmail.com

To: taxreform2017@finance.senate.gov

July 17, 2017

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Why is the United States imposing full U.S. taxation on the Canadian incomes of Canadian citizens living in Canada?

The Internal Revenue Code mandates that ALL “individuals” EXCEPT “non-resident aliens” are subject to full taxation under the Internal Revenue Code. The word “individuals” includes U.S. citizens regardless of where they live and regardless of whether they are citizens and residents of other countries where they also pay tax. This means that, by its plain terms, the United States imposes full taxation on the citizens and residents of other nations, because they are also (according to U.S. definitions) U.S. citizens. The United States is the only country in the world that has such a broad definition of “tax residency”.

The United States is “making noises” about “tax reform”. Senator Orrin Hatch requested submissions from “steak stake holders” on what should be included in tax reform. He has clearly received (as did the Ways and Means Committee in 2013 and the Senate Finance Committee in 2015) many suggestions advocating the repeal of “citizenship-based taxation”.

As noted at a site compiling the submissions of those affected by U.S. extra-territorial taxation:
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Jackie Bugnion 2017 Residence Based Taxation: To Chairman Hatch’s request for tax reform proposals

Introduction: It’s tax reform season and Senator Orrin Hatch wants to hear from you (again)

As reported on the Isaac Brock Society and other digital resources for those impacted by U.S. taxes, you have until July 17, 2017 to tell Senator Hatch what you think needs to be changed in the Internal Revenue Code. After great deliberation, it occurred to me that people who either are (or are accused of being) U.S. citizens or Green Card holders living outside the United States, might want the USA to stop taxing them. After all, they already pay taxes to the countries where they reside. This is your opportunity to “Let your voices be heard” (well maybe).

The Senate Finance Committee is yet again asking the general public to send comments on tax reform. The deadline is July 17, and the email address is taxreform2017@finance.senate.gov.

https://www.finance.senate.gov/chairmans-news/hatch-calls-for-feedback-on-tax-reform

(July 17, 2017 is coming quickly. Please take a few moments to send your thoughts to Senator Hatch. Tell him you feel about FATCA, citizenship-based taxation, FBAR, etc.)

Speaking of “tax reform”: Introducing Jackie Bugion

Jackie Bugnion is a U.S. citizen who has lived in Switzerland for many many years. She has been a tireless advocate for “residence based taxation”. She worked with “American Citizens Abroad” for many years and has recently retired. She was recently honoured with the Eugene Abrams award by ACA – an event that was the subject of a post at the Isaac Brock Society – that described her many achievements (over a long career).

She was the principal organizer of the “Conference on Citizenship Taxation” which took place in Toronto, Canada in May of 2014. The Conference was widely discussed on the Isaac Brock Society here and here. The live video of the “Kirsch Schneider debate” is here.

I have reproduced a number of her written submissions and posts on this blog, specifically:

Jackie Bugnion – 2013 Submission to the House Ways and Means Committee – Explains the upcoming New American Revolution

The submission referenced in the above tweet describes the history of the construction of the U.S. “fiscal prison” brick by legislative brick! (Forward it to anybody and everybody with a interest in this.)

Jackie has returned with her 2017 submission to Senator Hatch.

Jackie Bugnion – 2017 submission to Chairman Hatch – reproduced with permission of Jackie Bugnion

 

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“A Proposal for Fair US Tax Treatment of Foreign Pensions” from @JackieBugnion and Paula Singer

Even in retirement Jackie Bugion writes the best arguments against citizenship taxation ever“. Other references to Ms. Bugnion’s work are here.

In this new post published on May 30, 2016 at Tax Analysts, Ms. Bugnion collaborates with U.S. tax lawyer Paula N. Singer to explain the problems experienced by Americans abroad who have pensions in their country of residence.

This new article explains:

1. The problem – how U.S. tax laws destroy the value of the “foreign pension” as a “pension” at all

2. The treatment of non-U.S. pensions under various U.S. tax treaties (underscoring now tax treaties are very different)

3. The proposal – how the Internal Revenue Code can be simply amended to fix this simple but painful problem.

Below you will find the PDF of this must read article. Please note that this article appears on CitizenshipSolutions.ca under the following conditions:

Permission is for this one use and is contingent on properly crediting the article to the respective authors and to Tax Analysts as the original publisher. Using the PDF attached above covers proper attribution. Any other requests would need to be addressed separately.

Bugnion-Singer (05-30-2016)

John Richardson

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

#Americansabroad: Thoughts on the May 2/14 Toronto Conference on CBT vs. RBT – #FATCA #FBAR

The May 2, 2014 Toronto Conference on U.S. citizenship-based taxation was a great success. As the ACA Global announcement of results describes the morning and afternoon had separate themes and participants.

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