.@TheDemocrats through their @DemsAbroad wing is working hard to harvest the votes of #Americansabroad. The Republicans are not. As the recent Pelosi message shows, the Democrats don't understand @citizenshiptax or #FATCA problems, don't care or don't care that they don't care.
Now before people start saying "But what about the Republicans?" I remind you that the #FATCA of the matter is that Republicans are NOT out harassing you for your vote. Maybe they should be? It IS possible to discuss one party without discussing the other.
The bottom line is that US democracy has been hijacked by the parties. It's the parties that matter and not the people. It's "Democracy" for the parties, by the parties and of the parties. YOU - as an individual - matter only to assist a party.
This is why @independents are a growing movement in the USA. It's difficult for individuals to matter in a @Partyocracy. In this respect US voters resident in the USA have the same problem as @USVotersAbroad. All US voters struggle to be relevant.
Resident Americans consciously recognize growing numbers of independent voters. I suggest that @USVotersAbroad (if they care about themselves, families and
country of residence) should STOP thinking of themselves as party members but as US residents abroad - @Independents.
Since at least 2016 we have periods where each party has controlled all branches of government and could easily have ended @citizenshiptax. They have not. It is unreasonable to expect help from the parties. It is therefore unreasonable to commit to voting for a party.
Ending @citizenshiptax through the democratic/political process is possible only by making it clear that @USVotersAbroad will vote ONLY for candidates (regardless of party) who will advance the interests of #Americansabroad.
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.
A Mexico Land TRUST, is not a FOREIGN TRUST for IRS purposes - ("cannot be what it isn't"). But, a Liechtenstein “Stiftung” - private FOUNDATION with no reference to the word TRUST is a FOREIGN TRUST for IRS penalty purposes - ("would be what it isn't"). casetext.com/case/rost-v-un…
Here is IRS Rev. Rul. 2013-14 which decided that certain Mexican Land Trusts are NOT trusts for IRS purposes irs.gov/pub/irs-drop/r…
Here is the August 11, 2022 decision of the US Court Of Appeals - 5th Circuit that ruled that a Liechtenstein "Stiftung" (a German word meaning, roughly, "foundation" or "endowment.") ARE trusts for IRS purposes casetext.com/case/rost-v-un…
This informative summary of the differences among U.S. state income taxes naturally leads to a discussion about the difficulty in severing @taxresidency from high tax states like CA, NY and Mass.
Whether constitutional or not I suspect that these high tax states will attempt to impose “Exit/Departure Taxes” on individuals who try to sever @taxresidency with the state.
As discussed in this WSJ article by Hank Adler California has already proposed a very “progressive” exit tax on people who sever @taxresidency. Great article here. wsj.com/articles/a-cal…
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.
2022 FATCA Report: If US doesn't agree to amend #FATCA IGAs to include full reciprocity and respect GDPR (which it won't) options include: 1. Blocking law generally 2. Blocking law for @USAccidental 3. Deem #FATCA inapplicable to European residents period! europarl.europa.eu/RegData/etudes…
The very last paragraph explains that #FATCA is not in the spirit of multilateral cooperation. Basically it saying that the US is essentially a 100% taken and a 0% giver. But, we know that