Are the Psychological Benefits of U.S. Citizenship An Adequate Justification For the Worldwide Taxation of Nonresident U.S. Citizens?
I recently wrote a two-part series about the inadequate justification for the United States’ worldwide taxation of its nonresident citizens (Part I is available here; Part II is available here). Professor Michael S. Kirsch offers a different perspective in defense of this system. Instead of assessing the propriety of U.S. worldwide taxation on the basis […]
Don’t Mistake “GIIN” For Gin Or You May Suffer More Than Just a Hangover!
In a recent blog entitled, “FATCA GIIN January 2015 FFI Registration Analysis … by the numbers,” Professor William Byrnes provides a brilliant commentary on the IRS’s publication of its first FATCA GIIN list of the new year (published on New Years Day!). The FATCA GIIN list is a list of “approved FFIs (Foreign Financial Institutions)” that have registered […]
US Automatic Exchange of Bank Information to 86 Foreign Countries in 2015
In a recent blog entitled, “US Automatic Exchange of Bank Information to 86 Foreign Countries in 2015,” Professor William Byrnes lists the countries with which the U.S. has an automatic exchange relationship. There are a total of 86. The article can be found on Professor Byrnes’ International Financial Law Prof Blog.
What Should A Swiss Banker Charged With Offshore Tax Evasion Do In The Wake of Raoul Weil’s Astonishing Acquittal?
The acquittal of Raoul Weil, the only Swiss banker to have prevailed over the U.S. government in an offshore tax evasion case, has become a source of inspiration for dozens of others who find themselves in a similar situation – indicted and living in Switzerland. As a result, many have become emboldened to come out […]
Is the Justification for the United States’ System of Worldwide Taxation A Hoax (Part II)?
In Part I, I argued that the benefits rationale – in terms of the public benefits received by citizens – was an unpersuasive justification for the U.S.’s system of worldwide taxation. I continue my rant in Part II, examining the practical effects of worldwide taxation on non-resident U.S. citizens. Through a labyrinth of “credits, deductions, […]
Bank Leumi Enters Into Non-Prosecution Agreement With Department of Justice; Agrees To Release More Than 1,000 U.S. Account Holder Names
In order to avoid a fate similar to UBS, Bank Leumi recently admitted to engaging in some tax “hanky panky.” One of the largest banks in Israel, Leumi admitted that it helped U.S. taxpayers evade their taxes. How so? By helping these individuals to hide their income and assets in offshore accounts in Israel and […]
Is FATCA Doing More Harm Than Good?
Few American laws have been as controversial as FATCA. FATCA stands for Foreign Account Tax Compliance Act, a law passed in 2010 to clamp down on the use of foreign bank accounts by U.S. taxpayers to hide money that is otherwise subject to taxation in the United States. FATCA is the U.S. government’s newest enforcement […]
THE NEW AMERICAN EXPAT: MORE COLLATERAL FATCA DAMAGE
As I reported in a previous article, the Department of Justice (DOJ) and the IRS instantly began to drool in anticipation when The Foreign Account Tax Compliance Act was passed in March of 2010. This gives them enforcement tools to make foreign countries and banking institutions play by our rules whether they like it or […]
Hong Kong and the United States Sign FATCA Agreement
On November 13, 2014, Hong Kong and the United States signed an inter-governmental agreement (IGA), which will require financial institutions in Hong Kong to comply with the US Foreign Account Tax Compliance Act (FATCA). FATCA provides the Internal Revenue Service (IRS) with the tools it needs (not a scalpel but a chainsaw) to obtain information on financial […]
The Spread of FATCA Envy Into The Northern And Western Hemispheres
South American countries have many reasons to be jealous of the United States. Most days, we have stable federal government. Our standard of living is mind-blowing for many people in impoverished countries. They view us as the land of opportunity. We argue about our health care system, but almost everyone gets the care they need. […]