Richardson, Snyder, Alpert: 'Treasury could also fix CBT'

While there is apparently some disagreement as to whether Albert Einstein ever actually said that the "definition of insanity is doing the same thing over and over again, but expecting different results," few would challenge the argument for changing one's approach when, after numerous attempts to do something, one is clearly making no progress whatsoever.

Among the latest advocates of this strategy are Toronto-based U.S. citizenship lawyer John Richardson, Paris-based attorney and U.S. taxpayer rights campaigner Laura Snyder, and Australia-based university lecturer and founder Karen Alpert...

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New anti-extraterritorial taxation expat organization forms; launches survey

Stop Extraterritorial American Taxation, or SEAT, is the name of a new education and advocacy organization that's been formed by a half a dozen individuals who are already well known in the community of Americans living overseas.

As part of its launch, the international not-for-profit group, which is based in France and headed by lawyer and Taxpayer Advocacy Panel member Dr. Laura Snyder, is unveiling a survey it says is "aimed at learning more about how persons living outside the United States experience the extraterritorial application of U.S. taxation and banking policies".

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Expat advisers Richardson, La Torre Jeker go looking for ‘Mr. FBAR’

Looking for Mr Goodbar was a 1975 book, made into a film two years later, about a New York City schoolteacher who ended up being murdered by a young man she’d just met. 

“Mr FBAR,” on the other hand – and of rather more relevance here – is an Expatland nickname for a document that U.S. expats around the world have been required to file annually with the IRS since 1970, if their total offshore bank and financial account holdings total US$10,000 or more at any time during the tax year...

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Online course in September for advisers seeking to know more about advising U.S. expats

DJH International Tax, a UK-based, American expat tax specialist firm, and Toronto-based U.S. citizenship and tax lawyer and commentator John Richardson, will be holding an online training course in September that will be aimed at financial advisers keen to learn more about advising American clients resident overseas on such issues as taxes, investments and retirement planning.

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U.S. gov't publishes near-record list of quarterly renunciants' names in spite of Covid-19 lockdown

The U.S. government on Thursday published its second-largest-ever quarterly list of names of Americans who have renounced their citizenships – in spite of the fact that the processing of renunciations by U.S. consulates and embassies around the world has all but ceased, according to U.S. citizenship renunciation experts, who help dual citizens looking to give up their U.S. passports, and in some cases Green Cards, to do so.

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A few tax quotations the IRS missed...

Happy Tax Day! And what better way to celebrate than a few tax quotations.

As we noted yesterday, the collection of 15 tax quotations on the IRS's website (yes really), wonderful though it is – does miss a few classics that rank highly in our own collection...

There's Benjamin Franklin’s quote, for instance, which is probably among the world's best-known tax quotations of all: “In this world nothing can be said to be certain, except death and taxes.”

(Almost equally famously, American author Martha Mitchell included a variation on Franklin’s quote in her 1936 novel Gone with the Wind, in which she has her heroine, Scarlett O’Hara, say: “Death, taxes and childbirth! There’s never any convenient time for any of them!”)

Then there’s Lord Roy Jenkins’s classic quote about inheritance tax, always popular among British estate planners keen to help clients understand why they should take their (the estate planners') advice.  Jenkins – a former chancellor of the exchequer – described inheritance tax in a 1986 Commons debate as “broadly speaking, a voluntary levy paid by those who distrust their heirs more than they dislike the Inland Revenue."

Below are some other quotes that we consider classics, but which the IRS, for some reason, chose not to include in its compendium...

Some Tax Quotes the IRS missed... 

  •   “The avoidance of taxes is the only intellectual pursuit that carries any reward.” 
    ~ John Maynard Keynes

  • “A government which robs Peter to pay Paul can always depend on the support of Paul.”
    ~ George Bernard Shaw, Irish playwright and critic

  • “The art of taxation consists in so plucking the goose as to obtain the largest possible amount of feathers with the smallest possible amount of hissing.” 
    ~ Jean Baptiste Colbert (French economist and minister of finance under King Louis XIV of France,1619-1683)

  • “We contend that for a nation to try to tax itself into prosperity is like a man standing in a bucket and trying to lift himself up by the handle.” 
    ~ Winston Churchill

  • “The problem is not that people are taxed too little, the problem is that government spends too much.”
    ~  The late U.S. president Ronald Reagan

New tax quotes

 The introduction of the Foreign Account Tax Compliance Act in 2010 has resulted in the creation of a new genre of tax quotations, which Toronto-based lawyer and tax expert John Richardson has been perfecting – as anyone who has heard him speak at a tax industry event recently will know.

Below are some of Richardson's best-known quotes. 

  •    "The motto for Americans abroad should be: Report early, report often, report everything – and keep a record of what you report."

  •   "We’re in a situation in which the IRS is the judge, the jury and the executioner.”

  •   "The beauty, genius and timeless wisdom found in the Internal Revenue Code include the principle that the Internal Revenue Code, in its majestic equality, punishes both Homelanders and Americans abroad for having financial assets and accounts outside of the United States.”

  • "Americans abroad are always the most highly taxed people in their country of residence – making them the most highly taxed people in the world."

  • "The United States imposes a separate and more punitive tax system on those Americans living outside the United States than it does on Homeland Americans."

  • "The IRS treats marriage between a U.S. citizen and a non-U.S. citizen as a form of tax evasion."

  • "To the IRS, a non-U.S. pension is nothing but a sacred instrument of tax evasion."

  • "There are two kinds of Americans abroad with problems: First, those who do not file U.S. tax returns. Second, those who do file U.S. tax returns."

  • "All roads lead to renunciation."

  • "If you see the word foreign in the Internal Revenue Code, the word "penalty" (usually starting at  US$10,000) is sure to follow."

  • "It's not that Congress doesn't care about Americans abroad. It's that they don't care that they don't care."

  • "When the United States move to 'territorial taxation' for corporations [in the 2017 Tax Cuts and Jobs Act], what it actually did was to expand internationally the territory over which the United States claims tax jurisdiction." 

  • "The single most important skill for American citizens in the 21st century is the ability to complete and file a U.S. tax return without having to resort to professional help."

  • "A supporter of citizenship-based taxation is someone who has merely given some thought to the idea of citizenship-based taxation. An opponent of citizenship-based taxation is someone who actually understands citizenship-based taxation." 
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Alan S. Lederman: 'U.S. taxation and foreign expropriation without U.S. representation?'

Alan S. Lederman: 'U.S. taxation and foreign expropriation without U.S. representation?'

US citizens holding dual foreign nationality and living abroad may have individually owned assets that could be subject to foreign government expropriation, says Florida based attorney Alan S. Lederman, of...