Tags
Broken, cbt, citizenship-based taxation, expats, fatca, Financial Services, NAFTA, Sucks, TBT, territorial-based taxation
International financial services need an overhaul. The first North American Free Trade Agreement (NAFTA) did diddley for competition in this area — any restriction already in place was to remain in place. Fine. Makes sense to some degree. Nations should have control over their own tax systems, retirement programs, and investment incentives. Unless of course it is deemed as an unfair restriction of U.S. sales, then it’s evil.
Some examples.
- Americans cannot buy Canadian mutual funds.
- Americans cannot buy Canadian Life Insurance
- Americans cannot buy Canadian stocks
- Americans cannot participate in Canadian private pensions
- Canadians cannot buy American stocks unless protected by a registered plan
- I am not sure if Canadians can buy American mutual funds. I think we can, but generally such investments are hidden from us as those of us who purchase such things tend to bury them in registered plans and buy them through management companies. My financial advisor is Sun Life, and I have no idea which funds I own. Some of everything. But as they live in an RRSP, the IRS cannot touch them.
These might seem abstract concepts and do not affect you as a Canadian or American. After all, why would an American want to buy life insurance from London Life or participate in a provincial government pension plan?
In reality, these policies do not affect the everyday Joe or Jane, but they do affect at least one million American Persons living in Canada, maybe more, maybe double that. We do not have an accurate count of active Canadian citizen green card holders (those people who were resident in America but returned without cancelling their card. And why would you cancel it as they are so hard to get in the first place, especially if you have any hints of non-white or non-Christian ancestry.) now resident in Canada.
It affects us because the U.S. taxes its citizens and green card holders no matter where they reside. A cash value on a whole life insurance policy that is not registered in America is treated as a savings account, and it does not grow tax free. That private pension plan we may participate in (often we are required to as a condition of employment) is nothing but a savings account, It does not grow tax-free in the eyes of the IRS. Investments into non-American mutual funds are subject to harsh PFIC taxation rules making them prohibitive. Dividends of American stocks by Canadians and Canadian stocks by Americans are exempt from favourable dividend tax credits*; so if you want to invest your millions in foreign dividend generating companies for whatever reason, you won’t because there’s no way to benefit as much as even a marginal company of your own country, For Americans in Canada who are subject to both the CRA and the IRS laws, what one grants the other takes away. We cannot benefit from any dividends. Again, RRSPs grow tax-free, so as long as your money is buried in one (not a private pension plan) these laws don’t matter much. *I won’t get into the mechanics of dividend tax credits.
What this all means is
- the majority of people do not have a full range of choices. These are protectionist policies and only the major corporations benefit. Individuals do not.
- Americans living in Canada are severely restricted when it comes to investing, protecting their families, and saving for retirement.
- The major financials are in no way impacted.
Let me rant about the banks. Canadian charted banks operate in the U.S. They are major financial players. The services they offer in Canada are offered in America. They can sell American things to Americans and Canadian things to Canadians. They are happy and are not raising a stink.
The real people impacted here are Americans living in Canada, and we are being hurt by the U.S. policies.
Does this rant matter? Not int he least. President Obama was the American Expat’s worst enemy; Trump is too stupid to understand the problems (and he has other, more important problems); Prime Minister Trudeau is a two-faced ******* who promised to help us fix these problems but now brushes us off; and because the financial institutions are not really impacted, they couldn’t care less. After all, it’s all about their money, not ours,