Is U.S. Citizenship-Based Taxation On Its Way Out?
The prayers of Americans living overseas may have finally been answered. A bill is in the works in the United States Congress to establish “Territorial Taxation for Individuals” (TTFI). If passed, the bill would change the current tax regime from one of “U.S. citizenship-based taxation” to “residence-based taxation.” This would go a long way to […]
FATCA Brings End to Switzerland’s Time-honored Tradition of Bank Secrecy
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Survey of Citizens Renunciation Intentions: A Lannister Always Pays His Debts, but Americans Change Kingdoms to Evade Taxation
After the IRS shouted “Dracarys” in 2010, the Foreign Account Tax Compliance Act (FATCA) breathed fire on American taxpayers, causing more chaos than the destruction immortalized in the Rains of Castamere. The law mandates that U.S. citizens, including those residing outside the country, report their financial accounts outside the U.S. The IRS didn’t stop there; […]
Is Making A “Quiet Disclosure” In Today’s Environment A Smart Choice For A Taxpayer with An Undisclosed Foreign Account?
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A Primer on DOJ’s Swiss Bank Program
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Unintended Consequences
Some basketball fans may remember the 1988 Summer Olympics in Seoul when, for the first time since the earth cooled, Team USA did not bring home a basketball gold medal. But NBA Commissioner David Stern had a plan: assemble a roster stocked with future Hall of Famers and allow them to run roughshod over any […]
Foreign Account Disclosures Soar To Over 1 Million
The IRS published a News Release on March 15, 2016 entitled, Foreign Account Filings Top 1 Million; Taxpayers Need to Know Their Filing Requirements that readers of this blog might find interesting. Below are some snippets: WASHINGTON — Strong and sustained growth of taxpayers complying with foreign financial account reporting reflects improving awareness and compliance of this important […]
Slow Boat To Somewhere
Ancient Greek thinker Heraclitus is famous, at least in some circles, for his rather perplexing observation that “the only constant in the universe is change.” Murphy’s Law, a much more familiar axiom, states that “if anything can go wrong, it will.” If these two phrases are combined into some sort of latter-day Frankenstein’s monster of […]
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 […]
‘Justice Delayed Is Justice Denied’?
Wighead English jurist William Gladstone, the author of this famous quote, was obviously not a criminal defense lawyer. In many, if not most, cases, delay is a fundamental element of a successful defense, or even the lynchpin of the entire schmear. Over time, memories fade, evidence is lost (or at least becomes more difficult to […]