FBAR Penalty in Canada! - View Single Post
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Old 4th January 2012, 11:51 PM
pwdunn pwdunn is offline
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Users Flag! Originally from canada. Users Flag! Expat in canada.

Originally Posted by Northof49 View Post
That is certainly the result that is being sought. It would definitely not be worth the time, effort and expense if the CLN ends up being dated currently. In fact, this would be the worst possible result because it would produce a huge, immediate exit tax liablity for all capital gains on all my assets as if they had been sold on the date of renunciation. I raised this point repeatedly with the lawyer and he seems confident that we can get it backdated.
Definitely yes. Clearly yes. If you are not a person under the jurisdiction of the United States, FBAR does not apply to you, and the statute of limitations is six years. Get a CLN that says your expatriation dates more than six years ago and your laughing, and there is nothing Obama can do to you--well, nothing lawful.