Tag Archives: Michael Kirsch

Video of May 2, 2014 Toronto debate on Citizenship taxation of #Americansabroad – Professor Michael Kirsch and Dr. Bernard Schneider

As you know, on May 2, 2014 ACA Global Foundation sponsored a debate on “21st Century Taxation of Americans Abroad: Citizenship-based taxation vs. Residence-based taxation. The debate featured Professor Michael Kirsch of Notre Dame University law school and Dr. Bernard Schneider of Queen Mary University in London, UK.

The debate has previously been discussed here and here. In addition, I used the ideas in the debate for a separate post on question of what connection to the United States should be required to justify citizenship taxation.

The video of the debate as been released and is referenced in the above tweet.

I reiterate my thanks to ACA Global, Professor Kirsch and Dr. Schneider.

I welcome your comments.

Taxation of #AmericansAbroad in the 21st Century: “Country of birth” Taxation vs. “Country of Residence” Taxation

Prologue – The “Story Of The Century

Since July 1, 2014, the United States via threats threats of the FATCA Sanction, has begun a “world wide hunt” for people born in the United States. The U.S. legal justification is two-fold:

1. Those born in the United States are U.S. citizens.

2. Citizens of the United States are obligated to pay taxes to the United States regardless of where they live in the world. Furthermore, regardless of where they live, the U.S. government has the right to control their lives and activities under the guise of “citizenship-based taxation”.

As the article referenced in the above tweet makes clear, many people “claimed” by the United States have never had any connection to the United States except that they were born there. The article includes:

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Taxation of #Americansabroad: @Thunfinancial Wall Street Journal Op-Ed follows article from @SaundersWSJ

The above tweet references an Op-Ed by Thun Financial’s David Kuenzi which recently appeared in the Wall Street Journal. This is a nicely done article which adds reinforcement to the excellent journalism by the Wall Street Journal’s Laura Saunders and Liam Pleven which appeared in the Wall Street Journal on June 18, 2014 and (discussing the new IRS Streamlined procedures) on  June 19, 2014. 

(The new Streamline Procedures were discussed by various “stakeholders” extensively:

The OVDP and  Streamlined Historians – Perspectives  of various Americans Abroad:

– at the Isaac Brock Society here and here

– by American Citizens abroad here

The second citizenship advocates:

– by Mark Nestmann here

The accounting firms:

– from Frank Hirth (U.K. based) here

The “What is non-willfull” group  here:

– by Stephen Mopsick here and earlier here

– by Patrick Martin here

– more by Patrick Martin here

– by Jack Townsend here

– by Robert Steinberg (particularly good analysis) here

The “Technicians” AKA “who is streamlined intended for” here:

– by Moodys here

– by Virgina La Torre Jeker here

– by Jack Townsend here

– by Robert Steinberg here)

Those who recognize that citizens of certain countries may have a second level of “home country specific issues” (Iran):

– by Virginia La Torre Jeker here

The Logistics – How to manage Streamlined “conFORMity”:

– by Virginia La Torre Jeker here

Interestingly both Mr. Kuenzi (as a presenter) and Ms. Saunders (as a journalist) attended the recent conference on U.S. Citizenship-based taxation conference which was held at the University of Toronto on May 2, 2014. The Toronto citizenship-based taxation Conference was a great success. Those interested can read: Thoughts and reflections on the Toronto Conference on the taxation of Americans abroad in the 21st century.

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Conference on “Citizenship-based taxation” – May 2/14 Toronto, Canada

I am very proud to participate in (what I believe to be) the first ever conference organized to debate issues surrounding “citizenship-based taxation”. The conference has been organized by “ACA Global“. The conference was reported on the Maple Sandbox blog as follows:

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