During 2012 US citizenship and, more particularly, the tax consequences of US citizenship became a major source of anxiety for US citizens living in Canada. Widespread reports in the media of increased US enforcement of tax and financial account reporting obligations of US citizens living outside the United States created considerable anxiety. They also spurred…
DetailsBefore delving headfirst into the taxation of intellectual property, it is important to understand what constitutes intellectual property and how it relates to intangible property. Intangible property is any property that has no physical substance, and intellectual property is intangible property created by individual(s). While these terms are often used interchangeably, some types of intangible…
DetailsAfter publishing final rules regarding people reporting their signature authority over foreign financial accounts, the Financial Crimes Enforcement Network (FinCen) received questions and comments about reporting for certain types of accounts. In response FinCen delayed the reporting requirement for individuals with signature authority over these types of accounts until June 30, 2012. The most problematic…
DetailsRecently, Flott & Co. assisted a client apply for a Certificate of Loss of Nationality of the United States (“CLN”) based on his relinquishment of US citizenship in 1984. He has now succeeded in obtaining an official CLN from the US Department of State, showing that he ceased being US citizen as of March 1984.…
DetailsFlott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. Specific guidance is needed for cases when former US citizens living abroad wish to establish that they relinquished their US citizenship at a date in the past and a Consular…
DetailsFlott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. Specific guidance is needed for cases when former US citizens living abroad wish to establish that they relinquished their US citizenship at a date in the past and a Consular…
DetailsThese publications do not constitute legal advise. Further information regarding this notice. Confusion at two US Consulates in Canada during recent relinquishment cases initiated by Flott & Co. clients revealed the need to develop forms and documents for use in establishing the intentional loss of US citizenship in the past. The current form, Form DS-4079,…
DetailsVolume 7 of the U.S. Department of State Foreign Affairs Manual (FAM) sets out the legal basis upon which Consular Officers are to deal with the loss of U.S. citizenship. In a nutshell 7 FAM 1211 states that US citizens cannot lose their citizenship involuntarily. Instead, a US citizen must establish that he or she committed an…
DetailsFlott & Co.’s recent experience in assisting two former US citizens seeking formal documentation of their prior loss of US citizenship underscores the need for expanded guidance on the relinquishment of US citizenship in the US Department of State Foreign Affairs Manual (Volume 7 – Consular Affairs) (“FAM”). In cases that appear to have been…
DetailsFlott & Co.’s recent experience in assisting two former US citizens seeking formal documentation of their prior loss of US citizenship underscores the need for expanded guidance on the relinquishment of US citizenship in the US Department of State Foreign Affairs Manual (Volume 7 – Consular Affairs) (“FAM”). In cases that appear to have been…
Details