Similar Posts


  1. Those Canadian accounts may be exempt from FATCA reporting but, unless there is more to it, that won’t make an difference to the obligation on the individual to report and pay taxes on them.

    If that isn’t the case, it is not that much better than the exemptions for retirement schemes in the final FATCA regs, which you don’t need an IGA to benefit from.

  2. Thanks for the comment. Yes I will need to post this as a blog. Astonishing that the Canadian diplomats were able to beat some particles of sanity into their U.S. counterparts, really. 🙂

  3. I renounced in Auckland last month. A phone call and one visit. In and out in less than 20 minutes. I got the impression this is business as usual for them these days.

  4. Not sure where best to post this, since it relates to RRSPs which seems to be a locked thread. (feel free to move my post)

    News today posted on the Canadian Revenue Agency website ( regarding a new USA-Canada tax agreement exempting RRSPs from certain reporting requirements. Since I’m far from an expert, I’ll leave it to Phil (the expert) to (hopefully) comment on significance.

    “… Significant exemptions and relief have been obtained. For instance, certain accounts are exempt from FATCA and will not be reportable. These include Registered Retirement Savings Plans, Registered Retirement Income Funds, Registered Disability Savings Plans, Tax-Free Savings Accounts, and others …”

  5. I experienced a one visit relinquishment, at a Canadian consulate, but the consular official seemed determined to be unnecessarily combative/abrasive about it right from the start. Was asked about my REASONS, and ‘why now?’. I was there to formally notify the State department – as required, that I had performed an expatriating act with full and informed intent to relinquish. The act with intent had already taken place – and I had the requisite documents to prove it. There is no legal requirement that I must satisfy US consular officials by offering up my reasons or motivations in order that they might judge them to be acceptable or not. I was there to exercise my right to expatriate – and to meet the burden imposed by the US that I notify the consulate only in the manner prescribed. I was warned by the consular official that my application could be rejected if I had made any mistakes on the paperwork – but he didn’t go over it with me – putting the onus on me alone to know whether my answers were sufficient and forms complete and satisfactory. I left with the distinct feeling his manner was motivated by more than just professional rigour.

    For me, that experience was a very convincing final confirmation of the wisdom in formally severing any even vestigial relationship from ‘abroad’ with a US government who imposes needlessly harsh and punitive extraterritorial tax laws and confiscatory financial reporting burdens on all those who permanently live and may have been born “abroad “…based on the convenient rationale that [the US] “government by its very nature benefits the citizen and his property wherever found….”; see Cook vs. Tait 265 U.S. 47 (44 S.Ct. 444, 68 L.Ed. 895)
    COOK v. TAIT, Collector of Internal Revenue.
    No. 220. Argued: April 15, 1924. Decided: May 5, 1924.

    I would have liked to remind the US consular official that:
    …”Governments are instituted among Men, deriving their just powers from the consent of the governed,..”.

    from ‘The Declaration of Independence of the Thirteen Colonies’
    In CONGRESS, July 4, 1776

  6. The London embassy in the UK is one visit. They apparently used to require two. Then they replaced the first visit with a phone interview. Now they get you to fill out a form which acknowledges that you have read all of the things they sent you and that you understand the consequences.

    I do think they have a mandatory waiting or “cool down” period. In my case, I sent the embassy all the docs they needed by email and they didn’t respond for three weeks and, then, only after I prodded them. Every other email correspondence with the embassy after that was a matter of hours.

  7. I am going to put this on my “interesting ideas to tackle” list. Which is pretty long and constantly gets slapped down by all the other things that happen in life.

  8. Foreign pension plans are not US qualified plans and therefore any income or gains in the plan during the tax year are included in taxable income.
    There is an option to treat the pension similar to a US qualified pension under many of the US income tax treaties and therefore enjoy the deferral of tax until distribution (form 8833)
    Phil with regards to your great post from 2010

    could you please provide us an update for tax year 2013 with regards to Obamacare since the income from a pension will be considered NII (net investment income) , it will be subject to the surcharge from 2013 if you fall above the threshold. The looming question is whether the treaty will provide protection from this treatment. As with the issue of foreign tax credits, some commentators are arguing that there may be relief under the various income tax treaties currently in force. Whether this is ultimately the case, we will have to wait and see how the IRS will respond but what is your take on this for an USP living and working in Switzerland and his employers pension contribution.

  9. “the early bird gets the worm..”
    for SwissTechie that was CH, but I heard last week that in Bern the waiting time is close to 1 year now !

  10. I was one of the lucky ones to get it done in one appointment after waiting 4 days. At the going rate of things, soon there will be no appointments, kind of like how it is done with Eritrea where citizenship cannot be discarded.

Comments are closed.

Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.