@RepBrianHiggins launches campaign seeking "carve out" from Canada's @VacantHomeTax for US citizens. He argues that this CDN tax (based on citizenship) violates US/CAN tax treaty and #USMCA. What about US @citizenship tax and #FATCA imposed on CDNs? higgins.house.gov/media-center/p…
Although @RepBrianHiggins is reinforcing the image of "The Ugly American" by his bullying tactics and viewing the world ONLY through his interests, this may be an opportunity to bring a discussion of US @citizenshiptax and #FATCA as applied to CDN residents into public domain.
As this thread indicates, @RepBrianHiggins is demanding that Secretary Blinken raise this issue when he visits Canada next month. Notice also the google from used to solicit complaints from his constituents.
Both @RepBrianHiggins and @USAccidental are using "Google Forms" in their respective fights against applications of @citizenshiptax. Is this an opportunity for "joint advocacy" to oppose ALL "forms" (pun intended) of citizenship-based taxes (#FATCA too)?
BTW, for those who don't understand Canada's Underused Property tax (yes it's a stupid tax), why it's based on citizenship and/or immigration status and why @RepBrianHiggins and US residents are (justifiably) upset, see this description and explanation citizenshipsolutions.ca/2023/02/08/us-…
It does strike me as rather ignorant (most probably explanation) and hypocritical for @RepBrianHIggins to opposed the CDN citizenship tax but (presumably) support US @citizenshiptax applied to CDNs and enforced by #FATCA. But probably he just doesn't know ...
It seems likely (given his propensity for fairness, justice and dislike of @citizenshiptax) that @RepBrianHiggins would want to advocate for the recognition that all citizenship taxes, imposed by either Canada or the US violate, "long standing tax treaties" and the USMCA.
And since @RepBrianHiggins references the USMCA, he really should also be complaining that Mexico's "citizenship based" restrictions on owning certain Mexican property should be called into question. Surely this discriminates against US citizens? See here mexlaw.com/desired-proper…
And surely @RepBrianHiggins would want to support CDN Snowbirds but are required to pay higher prop taxes than Americans. Could it be that he only objects to discrimination against US citizens who are not CDN residents? See this: snowbirds.org/bird-talks/flo…
In furtherance of fair taxation and the abolition of ALL forms of @citizenshiptax I would like to invite @RepBrianHiggins to join hands with @USAccidental in a joint statement opposing ALL forms of taxation based solely on citizenship or immigration status!
Where @RepBrianHiggins sees division, I see a clear opportunity for unity and collaboration toward fair taxation. What unites Mr. Higgins, the Gov of Canada and individual citizens - ending @citizenshiptax - is far greater than what divides them... Yes!

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More from @ExpatriationLaw

Jan 18
Post from @1040abroad (includes) attempts to define who is an ”Accidental American” (not defined in US law). US Treasury has made consistent attempts to help them without defining them. How should “Accidental American” be defined? taxconnections.com/taxblog/being-… via @TaxConnections
The first recognition of the problem of "Accidental Americans" is found in the 2015 Obama budget proposal discussed here ... See the screen shots for what was proposed. citizenshipsolutions.ca/2015/02/08/the… ImageImage
The second recognition of the problems of "Accidental Americans" appeared to result in the 2019 "IRS Relief Procedures For Former Citizens" as discussed here ... citizenshipsolutions.ca/2019/12/18/irs… ImageImage
Read 9 tweets
Dec 31, 2022
Notice 2023-11: Temp relief provided to banks under Model 1 #FATCA IGAs who can't provide SSN numbers of #Americansabroad ("preexisting accounts only") if the gov joins banks in taking specific steps to educate individuals about FATCA + @citizenshiptax. home.kpmg/us/en/home/ins…
Purpose of Notice 2023-11 is to ensure that banks in a Model 1 #FATCA jurisdiction won't be deemed to be "non-compliant" with the IGA if they can't provide a US SSN for "pre-existing accounts". The notice can be accessed and read in its entirety here ... irs.gov/pub/irs-drop/n…
Step 1: The relief is available to the banks in a Model 1 #FATCA IGA jurisdiction and ONLY if the government of the jurisdiction commits to engaging with (1) individual US citizens (2) the banks and (3) US Treasury to facilitate compliance.
Read 17 tweets
Dec 30, 2022
Lots of discussion on "reciprocity" question. What does "reciprocity" mean? Q. Is it possible for there to be "reciprocity" when "obligations" are in the form of an agreement (possible contract) or where the contract is the result of duress? Consider the following examples ...
What if Mr. A makes Mr. B "an offer he can't refuse"? Mr. B agrees to the obligation. Is this "reciprocal" or is this an agreement under duress? Can one really say this "classic" staple of American culture - is an example "reciprocity? Is it thuggery?
A second example ... neither Roxie nor Mamma Morton is behaving in a spirit of kindness/generosity. What is called "reciprocity" is about avoiding sanction (which is why all governments entered into #FATCA IGAs).
IRC 1471 imposes sanctions. Reciprocity?
Read 10 tweets
Dec 29, 2022
Excellent article by @HelenBurggraf explaining that the new Argentina IGA (like previous #FATCA IGAs) is NOT reciprocal. An earlier and lengthy expose explaining in detail why #FATCA IGAs are NOT and likely will never be reciprocal agreements is here ... citizenshipsolutions.ca/2022/07/24/the…
The remarks from Ambassador Stanley are clearly designed to suggest the US Argentina #FATCA IGA is "reciprocal". Whether by accident or design this statement is not accurate.
It is useful to examine the exact text of the US Argentina #FATCA IGA to determine what Argentina is required to do and what the US is required to do and decide whether the agreement is reciprocal. home.treasury.gov/system/files/1…
Read 10 tweets
Dec 20, 2022
#RBT countries understand "saving clause" to protect the internal tax base. Bc of @citizenshiptax + #FATCA US uses "saving clause" to BOTH PROTECT internal tax base + EXPAND tax base by claiming people with @taxresidency in other countries as US taxpayers. taxconnections.com/taxblog/croati…
Both OECD + UN Treaties include a "saving clause" which "saves" right of a country to tax its "residents". All countries (including the US) make "residency" a sufficient condition for @taxresidency. Only the US has @citizenshiptax. Hence, "saving clause" speaks only of residents.
The evolution of the "saving clause" found in US Tax Treaties is VERY (really) interesting. Watch how they become tighter over time. Here is paragraph 3 of Article 4 of the 1973 US Romania Tax Treaty. It applies to (1) "residents" (as defined by treaty) and (2) "citizens".
Read 12 tweets
Dec 16, 2022
Appears a delay in processing US tax forms is making it difficult for Canadian residents to comply with their Canadian tax obligations. Nobody told them about the perils of the cross border tax world when one lives in Canada and is paid for working in US. cbc.ca/news/canada/wi…
The relevant treaty provision ... canada.ca/en/department-…
Article XV says that the salary earned by the Canadian resident nurses who work in the USA "may" be taxed by the USA. Article XXIV par 3 says that the income is "sourced" to the USA which gives the USA the first right of taxation ... canada.ca/en/department-…
Read 6 tweets

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