Citizenship-based Taxation and FATCA

I am occasionally asked for a list of the things I've written or presented about FATCA and citizenship-based taxation, and decided I may as well post it here. I have a newer article on the adoption of the IGA in Canada, will post that soon and add to this list.

On the personal impact of CBT/FATCA:

• Uncle Sam Wants...Who?  A Global Perspective on Citizenship Taxation (explaining the expansive US tax jurisdiction and its consequences on citizens abroad)
• Understanding the Accidental American—Tina’s Story (describing the “gotcha” of CBT and FATCA)
• Paperwork and Punishment: It’s Time to Fix FBAR (explaining FBAR, its mission creep, and its effects on USPersons living abroad)
• Taxpayer Rights, On and Off-shore (exploring tax complexity and compliance for nonresident US Persons)
• Regulating Tax Preparers: A Global Problem for the IRS (exploring the problem of regulating the tax compliance industry outside the US territory)
• Could a Same Country Exception Help Fix FATCA and FBAR? (calling for exemption of local accounts held by nonresident US Persons from FATCA reporting; third item in a compilation; scroll to p. 7 of the document).
• Two expert reports in connection with the Hillis v. Attorney General of Canada litigation. 

Providing Legal Analysis of FATCA and the IGAs:

• Submission to Finance Department on Implementation of FATCA in Canada (discussing legal issues with proposed adoption of IGA)
• What You Give And What You Get: Reciprocity under a Model 1 IGA (explaining asymmetrical account disclosure and sharing requirements)
• Tax Cooperation: Past, Present and Future (explaining why FATCA is a tax treaty override & the IGAs do not “cure” it)
• The Dubious Legal Nature of IGAs and Why it Matters (arguing that the IGAs violate the US constitution regarding the treaty power, and thereby implicate public international law as to the treaties they ostensibly interpret)
• Interpretation or Override: Introducing the Hybrid Tax Agreement (further analysis on the public international law problems created by the IGAs)
• Putting the Reign Back in Sovereign: Advice to the Second Obama Administration (analyzing FATCA’s unilateral nature and its implications for international tax policy)

Videos and Podcasts:

• Interview with Tax Analysts (November 2015)
• Podcast with the McGill Law Journal (February 2014)
• Testimony to Finance Committee (March 2014)
• Interview with CBC News (January 2014)
• Interview with CBC Radio "All in a Day" (July 2014)
• Explaining the basic structure and issues surrounding FATCA (2012-prior to the IGA era)