Tuesday, December 8, 2015

Understanding the Accidental American: Tina's Story

Tax Analysts has published my talk on taxpayer rights and citizenship-based taxation as enforced via FATCA, which I gave in November at the International Conference on Taxpayer Rights in Washington DC, organized by National Taxpayer Advocate Nina Olson. Tax Analysts' content is normally gated but they have made this column available on their free site.


  1. And the response at the conference to your presentation?

    How about this fellow Ali Noroozi, Inspector General for Taxation of Australia - roughly IRS Taxpayer Advocate equivalent - who was on a panel re The Right to a Fair and Just Tax System. Does he get the injustice of US Extraterritorial Citizenship Based Taxation?

    1. I can't speak to what anyone thinks or understands. I did hear from a number of participants that they appreciated my talk, learned from it, thought it raised valid concerns, should be addressed etc. After my panel, Commissioner Koskinen gave a talk about tax system fairness and integrity and mentioned the central importance of FATCA in ensuring such fairness and integrity.

  2. I would hope that when a tax authority such as the CRA commits to assist in the enforcement of another country's tax collection, the tax authority providing the assistance would be under the same obligation to inform their own taxpayers of those obligations, rather than leave it to the banks to inform the customer. The CRA will now be receiving an unprecedented level of information on its own taxpayers without probable cause and possibly without their knowing it. What does this new regime hold in store for Canadian taxpayers?