Discover and read the best of Twitter Threads about #PFIC
Most recents (5)
Canada’s new #FHSA has different kinds. US citizens resident in Canada should avoid those administered by trustee (possibly creating foreign trust for US tax purposes). Stick with the basic “bank account” FHSA with no trustee and no (#PFIC) mutual funds. canada.ca/en/revenue-age…
General features of Canada’s new #FHSA: max contribution $8000 per year and $40,000 lifetime. Contributions tax deductible. Growth in plan not taxable. Distribution not taxable if used to buy first home. US citizens in Canada will need special planning. canada.ca/en/revenue-age…
A ”self-directed” #FHSA is possible which does NOT appear to be a “trust”. This would be good for US citizens (and all CDN residents) who want to invest in individual stocks. US citizens must avoid CDN mutual funds. canada.ca/en/revenue-age…
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?
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…
The @ACDSovereignty #FATCA appeal has started and in the early moments. The plaintiff/Appellant's lawyer Greg D. is off to a good start ...
Three arguments: 1. Standard Of Review 2. Confusing the S. 8 test of unreasonable search with S. 1 "reasonable limits" 3. Question of whether the Appeal court can conduct a hearing on the S. 1 issue.
Is the ITA of Canada a regulatory statute or a criminal statute? #FATCA info can be sent to the USA for the purposes of a criminal prosecution. Judge seems to be suggesting that the criminal aspect was not raised at trial ...
