Discover and read the best of Twitter Threads about #FBAR
Most recents (12)
Lunch with Jim Bennett (@jbennettatty) of @FairTaxOfficial fame and his wife Christine in Toronto. Jim's visit sparked hope for #Fairtax(ation) in Canada AND USA. @FairTaxAbroad would completely end the US tax nightmare for #Americansabroad. Learn more at fairtax.org 
Great podcasts with Jim Bennett (@jbennettatty) of @FairTaxOfficial. Learn how the #FairTax helps ALL Americans and expecially #Americansabroad in an #FBAR and #FATCA world! prep.podbean.com/e/rethinking-t…
@jbennettatty @FairTaxOfficial To learn why the #FAIRTax if particularly helpful #Americansabroad see the following discussion ...fairtax.org/videos/358-the…
How #FATCA IGAs relate to legislation in IRC: To be consistent with FATCA law and avoid the 30% US sanction, IGAs must require the FFIs to close the account of "US Persons" who fail to supply required data (without regard to local #GDPR law). Solutions? law.cornell.edu/uscode/text/26…
US #FATCA can accommodate Europe's #GDPR only by by excluding @USCitizenAbroad with @TaxResidency abroad from the definition of "U.S. Person". These two screen shots illustrate the problem ... Some thoughts on how this might this be achieved. law.cornell.edu/uscode/text/26…
As the @DemsAbroadTax statement and @SEATNow_org states/implies this problem can be solved ONLY if the US joins the world in adopting residence as the criterion for @TaxResidency. Citizenship would no longer be relevant for taxation. NOT part of any current legislative proposal.
An intelligent response which reinforces the #FATCA (sorry fact) that that the real problem is US @CitizenshipTax. The Decision in Belgium underscores that the sole purpose of the FATCA IGAs is to ensure Americans cannot leave the USA and acquire rights denied to US residents.
As the @DemsAbroadTax statement states/implies this problem can be solved ONLY if the US joins the world in adopting residence as the criterion for @TaxResidency. Citizenship would no longer be relevant for taxation. But, this is NOT part of any legislative proposal.
A second solution would be “A Regulatory Fix For Citizenship Taxation” Which would define “individual” as resident. As published by @TaxNotes here … taxnotes.com/featured-analy…
Ending @CitizenshipTax would mean fewer #Americansabroad caught in this #FATCA, #FBAR enforcement dragnet. What's truly "criminal" is unwillingness of US Gov to allow US citizens who live outside USA with @TaxResidency in other countries to avoid being caught in this crossfire.
Report goes on and on about Dan Horsky and a "The Family" (US residents) who used Credit Suisse to (presumably) evade US taxes. It concludes a vast conspiracy and uses this to condemn @DualCitizenship (pp 33 - 337)and justify the hiring of more IRS agents. finance.senate.gov/imo/media/doc/…
What is really disturbing is how the Report focuses on US citizenship and NOT residence. This should be of great concern to #Americansabroad. Remember also how dissent by Justice Barrett in the Bittner #FBAR case focuses ONLY on US citizenship with NO other circumstance relevant!
Almost all victims of the US extraterritorial tax AKA @citizenshiptax regime (enforced by #FATCA) agree that the practice of the US defining @taxresidency based on the "status" of citizenship alone must end. The plea is: End @citizenshiptax (enforced by #FATCA) and adopt #RBT.
When an organization or individual says they support #RBT or a political party includes #RBT in their platform, you must ask EXACTLY what do they mean by #RBT (Residence-based taxation)? Does their proposal leave citizenship in any way relevant to @taxresidency, #FATCA or #FBAR?
Do advocates of #RBT mean simply supporting a kinder more gentle (Eritrea style) of @citizenshiptax or do they mean making citizenship irrelevant to @taxresidency? Would #Americansabroad still remain US tax residents or do they cease having US @taxresidency for all purposes?
Podcast - A privilege to connect with @andygr to discuss: "The Decline Of The British Pound And Phantom Capital Gains For #Americansabroad Subject To @CitizenshipTax In The UK (a lose-lose situation)" podbean.com/ew/pb-q9vcz-13…
Highly recommend this 2014 interview with @andygr about the nature of US citizenship. How to get it. How to lose it. How to determine whether you have it.
Catching up with @andygr in 2016 where we discuss the problems of US citizenship in an #FBAR, #FATCA and @CitizenshipTax world
Tuning in on the live argument in the Bitter #FBAR case. Will tweet some of my thoughts/impressions as this unfolds. supremecourt.gov/oral_arguments…
Suggestion that existence of "reasonable cause" mitigates against the threat of draconian penalties.
Judges suggesting that the quantum in the unreported accounts matters. "If you fail to do what the secretary required you to do then you are subject to a penalty of $10,000".
The National Whistleblower Centre has filed an amicus brief in Bittner - TOTALLY DEVOID OF LEGAL ARGUMENT - arguing for per account #FBAR penalties because higher penalties would create incentives for Whistleblowers" to report @InFBARWeTrust violations. supremecourt.gov/DocketPDF/21/2…
As evidence of the significance of #FBAR violations (and therefore the need to incentivize whistleblowers) the brief cites statistics on the small number of FBARs filed in comparison to the far larger number of #Americansabroad (relying on info from @aaro).
The brief seems to advocate that: 1. There is severe #FBAR noncompliance 2. The Government needs whistleblowers 3. Per account penalties will result in higher total penalties 4. The higher the penalty the more likely the whistleblowers will step in to assist the government.
Supreme Court Asked to Consider if FBAR Penalty Is Excessive Fine taxnotes.com/research/feder…
Separately on Nov. 2/22, in Bittner, the US Supreme Court will hear the case on the issue of whether the non-willful civil #FBAR penalty (found in 5321) - can be applied (based on a reading of 5314) on a "per account" or on a per "form" basis. It's the season of @InFBARWeTrust!
So, Bitter is about the interpretation of penalty application under 31 USC 5314 and 5321. Toth (if the Supreme Court hears the case) is about whether there are constitutional limitations to any penalties imposed under 31 USC 5321.
In 2022 a "Message in a bottle" from 2013 washes up on the shore as a reminder of US Treasury's " Myth vs. #FATCA isaacbrocksociety.ca/2013/09/20/fro…
Walking further down the shoreline, I found a second "Message In A Bottle" - Circa 2015. A 192 page book documenting the "Facts" exposing US Treasury's 2013 "#FATCA Myths" (AKA "Stack-Of-Lies) which continue to this present day. Have a look at this. citizenshipsolutions.ca/wp-content/upl…
Spent afternoon reading that 192 book absorbing the shocking atrocities committed by the USA against its diasporA. I then tripped, fell into a ditch, landing on a 3rd message Circa 2017 - about a #FATCA hearing - from @AndyGr delivered by @IsaacBrockSoc isaacbrocksociety.ca/2017/05/28/tra…
A recent archeological/twitterological dig uncovered a historical artifact from the Carter years (1977 - 1981) titled "Equitable Treatment by United States of Its Citizens Living Abroad" - a curious thing from a curious time. law.cornell.edu/uscode/text/22…
The first law was Public Law 95 - 426 which became law on October 7, 1978. Sec. 611(a) and 611(b) of the "Foreign Relations Authorization Act, Fiscal Year 1979" created a law which acknowledged the existence and value of #Americansabroad. Specifically the mandated ...
The second law was Public Law 96-60 which became law on August 15, 1979. SEC. 407 of that law amended "Subsection (a)(2) of section 611 of the Foreign Relations Authorization Act, Fiscal Year 1979" as follows ... govinfo.gov/content/pkg/ST…
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adım adım formul yükleme, basit formulleri yazma, basit al sat sistemleri, sistem birleşmeleri vs..
adım adım formul yükleme, basit formulleri yazma, basit al sat sistemleri, sistem birleşmeleri vs..
2-Basit hareketi ortalama sistemi oluşturma, hareketli ortalamanın fiyatı kesmesi sonucunda oluşan al sat sistemi.
3- RSI a göre al sat sistemi. Rsı istediğiniz rakamın üzerine çıktığın al, rakamın altına indiğinde sat mantığında. başlangıç için adım adım gitmeniz öğrenme hızınızı arttırır.
