Don’t Let the Door Hit You Where the Good Lord Split You

I hope all of you are following the douche trail of tax evader Eduardo Saverin and enjoying it as much as me. As you may recall, this fuckstick decided to renounce his US citizenship and move to Singapore–land of the free, home of the cane–about the same time as the Facebook IPO so he would save $67 million in taxes. Now his attorney is telling the world that only a delusional idiot would think that the reason he renounced his citizenship was because of taxes. Why? Let’s look at point #10 on the State Department form that Ed had to sign to relinquish his citizenship [pdf]:

I understand that if my renunciation of United States citizenship is determined by the United States Attorney General to be motivated by tax avoidance purposes, I will be found excludable from the United States […]

In other words, unless Ed gets a little special treatment, he can’t ever set foot in the United States.

Here’s my guess at how this went down. Ed’s attorney, sensing the possibility that he will be able to stuff a good portion of that $67 million into his own wallet, told Ed that a little legal maneuvering was all that’s necessary to guarantee that Ed can land his private jet on US soil. I’m sure the attorney figured that a year of backroom dealing and careful legal maneuvering would get Ed’s travel rights back. Unfortunately, Ed’s attorney didn’t factor in the douche factor:

“This had nothing to do with taxes,” [Ed] insisted. “I was born in Brazil, I was an American citizen for about 10 years. I thought of myself as a global citizen.”

This motherfucker is so big and bad that his passport says “World” on it. Proles like you just wouldn’t understand. Ed’s 30 years old. He’s got at least 70 more years to be very careful where he spits his gum.

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194 replies
  1. 1
    Mino says:

    Boy, oh, boy. I’d like to see some multinational tax scofflaws hit with exclusion. Make my day.

  2. 2
    CVS says:

    Now his attorney is telling the world that only a delusional idiot would think that the reason he renounced his citizenship was because of taxes.

    Only a delusional idiot would think that the reason was for anything other than because of taxes. Only a delusional idiot would think that anyone would think otherwise.

  3. 3
    tulip says:

    I was talking about this with a co-worker who leans right and conservative and we both agree this guy is a complete douche.

    I should have called him a fuckstick, that’s so much better!

  4. 4
    shortstop says:

    That was a very comical and perfectly paced post.

  5. 5
    Ben Cisco says:

    land of the free, home of the cane

    Nice turn of phrase you got there.

  6. 6
    Gustopher says:

    Oh, how I hope they actually exclude him.

    I wish they just automatically excluded anyone who renounced their citizenship — make them beg and grovel if they want to come back for any reason.

  7. 7
    Calouste says:

    This is the most retarded post I have seen on the BJ frontpage in many a year.

    Yes, misterretard, some people think of themselves as global citizens. I carry a passport of a country I haven’t lived in in a decade, so what? Just fuck off you nativist fucker.

  8. 8
    Ben Cisco says:

    This motherfucker is so big and bad that his passport says “World” on it.

    His dick is so big it has it’s own dick. And even his dick’s dick is bigger than any prole’s dick.

  9. 9
    BGinCHI says:

    That settles it. I’m not friending him.

  10. 10
    r€nato says:

    global citizen? orly? does he pay taxes to the UN, then? Do the blue helmets guarantee his freedoms against enemies foreign and domestic?

    Didn’t think so.

    Waiting for the first right-wing doucheblogger to use him as an example of why taxes need to be slashed on the obscenely wealthy before they all flee the US.

  11. 11
    r€nato says:

    @Calouste: stow your outrage. I have two passports as well. This guy is using ‘global citizen’ in the worst sense – as a flimsy rationalization to skate on taxes he rightfully owes a country which helped make him wealthy in the first place… both directly and indirectly.

  12. 12
    honus says:

    @Calouste: maybe you should get a passport for where you actually live then. Or would it cost you some taxes?
    My grandfather came to West Virginia from Lebanon when he was 18. Ten years later he was naturalized. I guess he could have considered himself a citizen of the world, but as his wife said “this is my country now.”

  13. 13
    Villago Delenda Est says:

    @Calouste:

    I’m a bit confused here.

    You don’t mind some moocher using infrastructure your US taxes paid for skipping the country as a “world citizen” to avoid paying millions in taxes back in to the common pot he so casually sipped from to make his fortune?

    This isn’t a question of “nativism”. If you think it is, please look in the mirror for the retard.

  14. 14
    Warren Terra says:

    @Calouste:
    You may not have understood. Mistermix isn’t deriding the concept of “global citizen” in its positive sense of someone with a broader allegiance to and sympathy with the human race. He is deriding the use of the term “global citizen” as a weaselish escape clause from a fantastically lucky entitled twit who is trying to dodge taxes – indeed, Mistermix is defending the term “global citizen” as used by well-meaning people such as yourself from the depradations of self-serving assho|es like Saverin.

    Oh, and yes: by all means, lets exclude this fncker. He’s exiled himself to avoid taxes, lets make his exile binding.

  15. 15
    paradox says:

    Love the title.

  16. 16
    shortstop says:

    @Calouste: I think of you as a global dim bulb. Look up the definition of “nativist” sometime. Ask for help if it includes words with too many syllables for you.

  17. 17
    r€nato says:

    @honus: what’s your point? Yes, I have a passport for where I live. I also hope to someday live and work and own property in the other country where I have citizenship. Much easier to do so as a citizen than not.

  18. 18
    Calouste says:

    @honus:

    You don’t know anything about US immigration and naturalization, do you? I think I might be elligible for a US passport by the time I have lived here for 10.5 years, but not before.

  19. 19
    shortstop says:

    If Eddie can’t come back, and George can’t leave, how will they exchange homemade holiday cookies? Those just don’t stand up well to shipping.

  20. 20
    SamR says:

    I didn’t really like The Social Network, but this makes it clear that its not even casually related to reality. In the movie, this prick is portrayed as a gentle spirit of goodwill suckered by Zuckerberg. What a joke.

  21. 21
    Raven says:

    Mary Kennedy, the estranged wife of Robert F. Kennedy Jr, has been found dead in her Bedford, New York home, TMZ reports.

  22. 22
    mouse tolliver says:

    @r€nato:

    Waiting for the first right-wing doucheblogger to use him as an example of why taxes need to be slashed on the obscenely wealthy before they all flee the US.

    Forbes already called him an American hero. For renouncing his U.S. citizenship. Idiots.

    This is reminding me of how annoyed I was after watching The Social Network, because it was so far from being the generation-defining Citizen Kane for the internet generation like nearly every movie critic said. Of all the obnoxious douchebags in that movie, Saverin was the one douchebag we were meant to feel sorry for.

  23. 23
    Older_Wiser says:

    If everyone closed their FB page and got the hell out, Eddie would be pounding sand in Singapore before long. I wouldn’t have to close mine because I don’t have one.

    Unfortunately, there are just too many on FB who want you to know when their kid had their last bowel movement or they scored something. TMFI and minutia that just takes up time and is boring to boot. Yeah, FB really contributes to the national discourse.

  24. 24
    Calouste says:

    @Warren Terra:

    Yes, I don’t see why he should have to pay taxes to a country he doesn’t live in. The US is the only country in the world that taxes citizens and even ex-residents under certain circumstances that live abroad.

    And it’s not like people who renounce their citizenship get of scotfree tax wise, there is a significant tax to be paid on all assets when you do that.

  25. 25
    beltane says:

    A family member of mine gave up his US citizenship for tax purposes and he manages to visit the US frequently. Rich people truly are above the law.

  26. 26
    r€nato says:

    @Older_Wiser: I’ve reconnected with several lost friends via FB, in a way that likely would not have happened otherwise. I keep in touch with current friends as well in a way that is difficult to do with email and phone calls (though I certainly don’t want to use FB to replace those).

    I know it’s now hip for the cool kids to hate on FB, but I still like it. I just won’t be buying their ridiculously overpriced shares nor do I use the apps that access my info.

  27. 27
    mouse tolliver says:

    @SamR: From what I read, Saverin was the FB co-founder who did the least amount of work. He was off in NY learning how to be a vulture capitalist and not even returning MZ’s phone calls. Which is why they forced him out.

  28. 28
    The Dangerman says:

    Facebook may be flying high now, but so was MySpace not that long ago.

  29. 29
    r€nato says:

    @beltane: if he had declared he was doing so in order to avoid taxes, things might have worked out differently for him.

    Or, not. I think that Mr. Saverin may well end up being made an example of.

  30. 30
    SectarianSofa says:

    Meh. I can’t get worked up about this guy, at least not in particular. I’m more pissed that corporations have been tax-evading for so long, and I don’t understand why that isn’t a bigger deal. Maybe it’d bother me more if he wasn’t Brazilian first.

  31. 31
    Steve says:

    You notice he doesn’t actually explain why he renounced his citizenship, he just wants to make sure everyone knows it wasn’t for tax purposes. You’d have to be such an idiot to believe that.

  32. 32
    honus says:

    @Calouste: Actually, I do. I’m a lawyer who done a good bit of immigration work. And I’m not buying your self-serving rationalization.
    My ancestors came here and became citizens. Saverin came here, used the place, and now wants to pretend he’s a “citizen of the world” to evade his responsibility to the community that enabled him. That’s offensive to me. If you are not attempting to excuse that, then I apologize.

  33. 33
    beltane says:

    @r€nato: It would take a true moron to be honest about his reasons in this situation. However, even a true moron with money will tend to get away with things normal people cannot even imagine.

  34. 34
    honus says:

    @Calouste: Oh, and by the way, I was mistaken. My grandfather was naturalized after eight years, not ten. You are demonstrably full of shit about immigration law. Quit digging.

  35. 35
    Skerry says:

    I’m curious why Singapore? He was born in Brazil. Are there tax advantages to being a citizen in Singapore that wouldn’t be there as a Brazilian?

  36. 36
    jrg says:

    I think of myself as a resident of Saturn. I want to pay the Saturn tax rate of free.

    …And if you disagree with me, you hate the feeble-minded, and you probably kick puppies, too.

  37. 37
    magurakurin says:

    @Calouste:

    He may think of himself as a “global citizen” but he is now surely not a US citizen. So, he’s a global kind of guy if he ignores the third most populous nation in the world and the fourth largest in land area.

    Do you notice a big difference between you and him? You still have both passports. He just renounced one of his.

  38. 38
    lamh35 says:

    @r€nato: Agreed. FB is how I keep current with my family in NOLA. Way cheaper than flying homw all the time.

  39. 39
    Calouste says:

    @honus:

    No, your full of shit because if you knew anything about immigration law you would know that the time it takes for people to become eligible for naturalization depends on their personal circumstances. My 10.5 years is 5.5 years for my Green Card and then another 5 years (not counting time spend abroad) to get to naturalization. Some people will get their Green Card sooner, some will get it later. If you win the Green Card lottery, you can move to the US and be a citizen in 5 years.

    Yes, so what about Saverin? He lived in the US, paid his taxes, now he doesn’t live in the US, is no longer a US citizen and paid his exit tax, why should he keep paying US taxes? No other country does that.

    Oh, btw, great for you grandfather that he came to the US and thought that is was now his country. Not everyone thinks that the US is the be-all-and-end-all, or just the right country for us and some of us are just on the move.

  40. 40
    eemom says:

    @Older_Wiser:

    This has nothing the fuck to do with the merits of FB, and I am SO tired of above-it-all cooltards like you falling all over yourselves for an opportunity to diss on the thing and brag about how awesome you are for eschewing it.

    Wiser my ass.

  41. 41
    trollhattan says:

    If he’s good on “D” maybe GlobalBoy can play power forward for the Lakers.

  42. 42
    eemom says:

    @Skerry:

    Also too, Brazil has better weather.

  43. 43
    Omnes Omnibus says:

    He went Galt. Many have threatened; few have followed through.

  44. 44
    trollhattan says:

    @jrg:

    Just think how much your money would weigh on Saturn. You’d hardly be able to lift your wallet!

  45. 45
    Calouste says:

    @magurakurin:

    I only have one passport and I wouldn’t think about getting a US one. I have pre-renounced it, so to speak.

  46. 46
    Mino says:

    @The Dangerman: Didn’t My Space start to die after Murdoch bought it. Small wonder.

  47. 47
    shecky says:

    Folks seem to get this all wrong. Conservatives are pissed because he hurt their feelings. Liberals hate him because he’s taking his toys with him.

    I say the guy is doing exactly what the government wants him to do. Someone in his position is encouraged to renounce their citizenship because of tax laws that seem to be unique (or pretty close to it) to the USA.

    I view this as an issue of freedom to move as one sees fit. Regardless if you’re rich as Saverin, or as poor as an illegal immigrant from Central America. Either way, dumb US law wants to treat such people punitively for making choices that are in their best interests. It’s time America stops thinking of citizenship as having some magical properties that not only everyone else on the globe wants to steal, but only a traitor would give it up so easily.

  48. 48
    burnspbesq says:

    Even if Severin manages to avoid US tax on post-IPO appreciation in his Facebook stock, that comes at a huge current tax cost that he could avoid if he just stayed put and didn’t sell.

    The way the expatriation rules work is that he will be deemed to sell his stock for its fair market value on the day before he expatriates. Even if he has already expatriated, he’s going to have a hard time convincing an IRS agent or a Tax Court judge to allow a significant valuation discount on his Facebook stock simply becaus the IPO price hadn’t been finalized as of the date he is deemed to have sold it.

    http://www.irs.gov/businesses/...../article/0,,id=97245,00.html

    Which is why I am less skeptical than some of you when he says his expatriation is not primarily driven by tax avoidance.

  49. 49
    shecky says:

    Not to mention, the guy was born in Brazil, has been living in Singapore since ’09, maybe he just doesn’t really care to live in the USA. What nerve!

  50. 50
    Shygetz says:

    @Skerry: No capital gains tax.

  51. 51
    jlow says:

    What’s the big deal? Just charge a $1,000,000 visa tax every time he wants to visit.

  52. 52
    Calouste says:

    @Omnes Omnibus:

    I don’t think he really went Galt. Wikipedia, for what it is worth, says that he has lived in Singapore since 2009. That might be some long term tax evasion, but I don’t think it looked in 2009 that there would be enough idiots in 2012 to make a Facebook IPO worth $100 billion. And it’s not like Singapore is a backwater.

  53. 53
    burnspbesq says:

    @Skerry:

    Are there tax advantages to being a citizen in Singapore that wouldn’t be there as a Brazilian?

    That depends on whether you see the total absence of capital gains tax as an “advantage.”

  54. 54
    Odie Hugh Manatee says:

    @The Dangerman:

    So was the Pet Rock. Never owned one and will never have a FB account (or its equiv). My personal info is not for sale, period. I know that FB makes it easy for people to contact each other but it compromises your privacy to do so.

    If someone is fine with that, great, but I’m not. I value my privacy and my information is not going to be collected and sold to the highest bidder.

    As far as this asshole goes, I hope he is permanently blocked from returning. It’s clear why he left as he was the one who stated the reason, taxes. It’s also clear that he was warned that if this was determined to be the reason that he would be excluded from ever returning to American soil.

    What a selfish and stupid fuck.

  55. 55
    jlow says:

    @shecky: I don’t give a damn where he lives, but the US is where and why he got rich. Just pay the taxes already. It’s not like our tax rates are particularly punishing for the 1%.

  56. 56
    jlow says:

    @Calouste: Moving somewhere is slightly different than renouncing your citizenship, which is what he is doing now.

  57. 57
    Djur says:

    US citizenship is kind of unusual in that it is by far the most ‘useful’ citizenship available (that is, from an advanced economy and military power with the attendant diplomatic advantages) by right of soil. Whether this justifies the unusual taxation of expats is debatable, but I think it’s an important consideration in that debate.

  58. 58
    Brian R. says:

    @Calouste:

    He lived in the US, paid his taxes, now he doesn’t live in the US, is no longer a US citizen and paid his exit tax, why should he keep paying US taxes? No other country does that.

    That’s not what happened here. After a decade of enjoying his American citizenship, he suddenly renounced it ONE DAY before Facebook had its IPO. And he didn’t return to the citizenship of his own native land, he chose Singapore, a country that has no capital gains tax. It was a move that led anyone with a brain to note that he was going to save $67 million dollars in dodged taxes as a result.

    Instead he trots out the “oh no, that was just a coincidence, I’ve always considered myself a global citizen and just happened to decide on that day that it would be a good idea — you know, spiritually, because I feel the pulse of the world — to renounce my U.S. citizenship. And I randomly chose Singapore because, uh, the Singapore Sling is my favorite cocktail. OK? All this extra money? TOTALLY UNRELATED.”

    Do you really believe that bullshit? If so, congrats, you’re fucking retarded.

  59. 59
    AA+ Bonds says:

    Whether or not he did this to dodge taxes it’s pretty LOL to see the right assume that if he did do this to dodge taxes, well, that means he’s a hero and it’s America’s fault for, like, providing him with the means to become a billionaire

  60. 60
    shecky says:

    @jlow: He has been paying taxes AFAIK. Maybe he doesn’t think citizenship is all that, and finds it costs too much, since he wasn’t using it anyway.

    As far as thinking he owes the US something, that’s pretty silly. If I got rich selling widgets in Los Angeles, does Los Angeles get a share of my earnings if I move to San Francisco?

    Just imagine if some rustbelt State could claim a piece of income from everyone who had a domicile there, and left for better prospects elsewhere. Absurd, right? But this is exactly what the US does, unlike pretty much every other forward thinking nation on the planet.

  61. 61
    currants says:

    @r€nato: and Older Wiser:
    I don’t like the way they keep changing the rules, sometimes without telling you. Seriously–why would I want personal information on a website run by some guy who got started by hacking his school’s network to set up a “hot” ranking system? Or by folks who make it THIS HARD to quit? Not interested.

  62. 62
    querlvox says:

    Myself, I wouldn’t put too much importance in him having been living in Singapore since 2009 as being indicative of this not being about the Facebook IPO and his tax liability.

    I mean, it’s not like it hasn’t been known since *before* 2009 that an IPO and huge potential payday was all but a certain eventuality.

    IE, it’s a completely legit reading that he’s just a shrewd longterm planner.

  63. 63
    Calouste says:

    @jlow:

    If the US has tax laws like the rest of the world, there would be no reason at all for him to renounce his citizenship after he moved.

  64. 64
    burnspbesq says:

    @Odie Hugh Manatee:

    my information is not going to be collected and sold to the highest bidder.

    Perhaps not by Facebook, but …

  65. 65
    Soonergrunt says:

    @Calouste: This is the most retarded comment I have seen on a BJ post in many a year.

    Yes, Calouste, some people claim to be “global citizens” as a PR stunt to avoid the negative repercussions of renouncing US citizenship as a tax dodge. You carry a passport of a country you haven’t lived in in a decade, so what? If you’d use that passport to evade legal responsibilities in your country of residence, while using your country of residence to avoid legal responsibilities to the country of your passport, then it seems to me that you’re the fucker who needs to fuck off.

  66. 66
    currants says:

    @SectarianSofa: YES. If he is made an example of, it will be to help corporations avoid facing the music, or at least to deflect attention from theat particular concern. “Pay no attention to the man in the corner….”

  67. 67
    burnspbesq says:

    @Brian R.:

    Can you explain, or link to an explanation of, how that $67 million number was derived?

  68. 68
    shecky says:

    @Djur: I’ve heard that, but the examples of special privileges of citizenship have been explained to me as foreign embassies (apparently so awesome, Saverin is a fool to give them up) and maybe the military will rescue you when you get kidnapped by pirates when you take your yacht off the coast of Somalia. I mean, really, can I get some examples that will sell me?

  69. 69
    Calouste says:

    @Brian R.:

    After a decade of enjoying his American citizenship, he suddenly renounced it ONE DAY before Facebook had its IPO

    Facts, what are those?

    Saverin’s name is on a list of people who chose to renounce citizenship as of April 30, published by the Internal Revenue Service. Saverin made that move “around September” of last year, according to his spokesman.

    Oh, and Facebook hasn’t had its IPO yet.

  70. 70
    burnspbesq says:

    The Onion is officially toast.

    http://krugman.blogs.nytimes.c.....nt-enough/

  71. 71
    Tom says:

    @Djur:

    You might have a point if the US expat had moved to Iran, North Korea or some other unstable country. But I don’t see your point for US expats who live in the UK, France, Germany or other stable western countries.

    Maybe Americans who live in Iran should pay be forced to file US income taxes. But I fail to see why a US expat in the UK should have to pay taxes in the US. They use the roads, infrastructure etc of the UK, not the US.

    And today the U.S. is the only western country that taxes based on citizenship, not residency.

  72. 72
    AA+ Bonds says:

    @Calouste:

    One might safely assume Saverin knew when Facebook’s IPO would occur

    One might even safely assume that he had influence over when it would occur

  73. 73
    The prophet Nostradumbass says:

    @burnspbesq: Here you go, from Bloomberg.

  74. 74
    shecky says:

    And I’m not getting the hate about being a global citizen. In fact, I recall some folks who claimed that was exactly how they’d continue life if one G. W. Bush were elected. Even if they quietly grumbled and continued on as if nothing happened after the election.

  75. 75
    RP says:

    I disagree. Despite having been given a US passport, he was never really an American. He came here for financial gain, so why not go to Singapore for financial gain. There seems to be this delusion that everybody who becomes a US citizen really super-duper loves the US, like they instantly cease to be what they were for the 1st 16 years of their lives (when in reality, the 1st 16 years of your life makes you what you are and you don’t ever really change that). US citizenship, as legal status, doesn’t really mean that much; it’s a convenience. Saverin was never an American, he was just a guy who lived here for a time.

  76. 76
    Soonergrunt says:

    @Calouste: Why are you trying to get citizenship here if you disdain it so much?

  77. 77
    Raven says:

    @Soonergrunt: No shit, this is about a stupid fucking thread.

  78. 78
    Quicksand says:

    He’s probably living in Singapore only because Peter Thiel’s libertarian paradise floating island isn’t ready yet.

  79. 79
    The prophet Nostradumbass says:

    @Soonergrunt: Calouste has “pre-renounced” US citizenship.

  80. 80
    AA+ Bonds says:

    Rich people can fly a lot of flags but my general opinion is, fuck ’em hard

  81. 81
    Brian says:

    So why do we always allow people to take advantage of the tax code and government subsidized entities then flee because they don’t feel like paying back into the system that they used to get rich.

    To hell with them, you know they’ll be back in US courts for patent infringement or the like as soon as it suits them again.

  82. 82
    AA+ Bonds says:

    Definitely fuck Singapore’s elite while we’re on the topic and fuck anyone who wants to become part of it in name or fact

  83. 83
    AA+ Bonds says:

    Any of this money that can get ‘looted’ out of Saverin? IN FAVOR

  84. 84
    AA+ Bonds says:

    Hit him with the “leaving town tax”

  85. 85
    Calouste says:

    @Djur:

    There are citizenships with far better benefits than the US one. Free health care, free education, guaranteed income. I’m certainly not trading in my current passport for a US one, because I know my country of origin won’t let me die in the street if I were to hit really hard times.

  86. 86
    AA+ Bonds says:

    It is comforting to see the standard gaggle of antsy rich-ass quasi-liberals still haunting the edges of BJ fall right in line with the liber-trolls as usual

    Spring is in the air! ! ! ! !

  87. 87
    Soonergrunt says:

    @RP: Well, then it shouldn’t be an issue for him to never come back once he’s made the decision as someone who was using the country as a convenient port of call and nothing more.
    Nobody expects a naturalized citizen to forget from whence they came. Hell, we take pride on where our great-great-great-great grandparents came from here.
    But we do expect, and rightly so, that people who take US Citizenship will accept the responsibilities that come with all the rights, among these being the primary responsibility to obey the law. Savarin, having chosen to renounce his US citizenship, can do so (or has done so, depending upon the source of information) in the full knowledge that, having done so for tax avoidance purposes, can never come back here.
    Good.

  88. 88
    Raven says:

    @Calouste: Delta is ready when you are.

  89. 89
    Brian R. says:

    @shecky:

    If I got rich selling widgets in Los Angeles, does Los Angeles get a share of my earnings if I move to San Francisco?

    Depends. Did you get your college education in Los Angeles, meet your business partners in Los Angeles, and then create a business based on a technology that Los Angeles developed and gave to you for free?

  90. 90
    Tom says:

    @shecky:

    You make it sound like the U.S. is the only country in the world that helps its expats. Here’s just one example of another country helping its own expats. And by the way, France does not tax its citizens based on your citizenship, they, unlike the US, tax on residence.

    http://www.guardian.co.uk/worl.....rate-yacht


    French storm yacht held by Somali pirates. Four freed as two Somali pirates are killed in ocean raid

    <

  91. 91
    Boots Day says:

    I know that FB makes it easy for people to contact each other but it compromises your privacy to do so.

    No, it doesn’t. I’ve had to give up more personal information to rent skis than I ever had to give to Facebook.

  92. 92
    Calouste says:

    @AA+ Bonds:

    One might safely assume Saverin knew when Facebook’s IPO would occur

    I’d say he would have a clue, but so would anyone who was paying a bit of attention.

    One might even safely assume that he had influence over when it would occur

    AFAIK (but prove me wrong) he is no longer an officer with the company and he has less than 5% of the shares, so his influence would have been fairly minimal.

  93. 93
    Mnemosyne says:

    @shecky:

    If I got rich selling widgets in Los Angeles, does Los Angeles get a share of my earnings if I move to San Francisco?

    Since both cities are in California and we have a state income tax, I’m pretty sure the answer to that is yes.

  94. 94
    AA+ Bonds says:

    I think Saverin’s money should be taken out in fine Colombian and distributed by airdrop across these fifty nifty United States

  95. 95
    the fugitive uterus says:

    not so sure Mitt should be using the term “wrestle it down” just saying

  96. 96
    AA+ Bonds says:

    @Calouste:

    AFAIK (but prove me wrong) he is no longer an officer with the company and he has less than 5% of the shares, so his influence would have been fairly minimal.

    Well I know you can’t possibly think the world works like that but ;) good show on the thread wreck honey

  97. 97
    Brian R. says:

    @shecky:

    And I’m not getting the hate about being a global citizen.

    This isn’t hate about the concept of a global citizen, it’s hate for how an obvious liar is using that as an excuse for his tax avoidance.

  98. 98
    Soonergrunt says:

    @Raven: I just don’t understand that.
    You know, I think that the way a lot of middle eastern countries treat women and religious minorities is fucking wrong.
    I hereby promise to never seek citizenship in any of those countries.
    @The prophet Nostradumbass: HA!

  99. 99
    Violet says:

    @RP:

    Despite having been given a US passport, he was never really an American.

    What does this even mean? According to law he was an American citizen. Are you looking at something else, like what’s in his heart? How do you measure that? Answer: you can’t, so law is what we’re stuck with. And according to law he was an American citizen.

    He could have chosen to be a resident in the US, but he didn’t. For whatever reason, he chose to become a citizen. And his citizenship was just as good as anyone else’s, including those whose ancestors have been Americans for generations.

  100. 100
    Calouste says:

    @Raven:

    Well, thank you for welcoming foreigners to the US who just want to live here and don’t want to take citizenship. And people on this thread thought using the term ‘nativist’ was over the top.

    Oh, and Raven. Fuck you.

  101. 101
    AA+ Bonds says:

    @Brian R.:

    This isn’t hate about the concept of a global citizen

    I’ll go on record with my big bundle of hate for that bullshit

    When we have a global state there will be global citizens

    Until then ‘global citizen’ is:

    1) a lie rich people use to dodge taxes
    2) a lie rich liberals use to treat guilt

  102. 102
    burnspbesq says:

    Saverin’s name is on the expat list that was published in the Federal Register on April 30. That means that the IRS found out about it in Q1 (it doesn’t necessarily mean that it happened in Q1, but it’s fairly likely that it did).

  103. 103
    Soonergrunt says:

    @Tom: “France does not tax its citizens based on your citizenship, they, unlike the US, tax on residence.”
    So different countries do things differently. Yay for international diversity.

  104. 104
    pseudonymous in nc says:

    @Soonergrunt:

    Why are you trying to get citizenship here if you disdain it so much?

    [deep breath]

    US citizenship and immigration laws are really fucking complicated, and unlike things like health care reform, the really fucking complicated stuff tied to citizenship is never ever presented to voters — the actual citizenry — as something they get to decide collectively.

    Did you vote for the rule that makes US citizens liable for taxation on foreign income and assets, something that only the US and Eritrea do? Did you vote to ensure that retirees living outside the US have trouble finding local banks, because of the reporting requirements imposed on US account holders? Did you vote for it to be illegal for US citizens to buy and smoke a Cuban cigar in Canada?

    You can’t just write it off as part of representative democracy. The entire superstructure of American citizenship is erected out of view of most citizens, and the only people who pay attention to it are the ones who bump into it at the edges — the immigrants and the expats.

    (And it’s honus, not Calouste, who’s full of shit here, because plenty of visas require, in practice, over a decade of residency before naturalization. Don’t retain him for immigration work.)

  105. 105
    Calouste says:

    @AA+ Bonds:

    That already happens, as burnes explains above.

  106. 106
    Raven says:

    @Soonergrunt: I should have said many of the comments in this thread are stupid fucking comments. It was fucking stupid of me not to. And I have a tummy ache.

  107. 107
    shecky says:

    @Tom: Actually, no, that wasn’t my claim. Those (embassies and personal military intervention) were examples that I heard on another forum. I’m asking folks to explain why American citizenship is so awesome, that giving it up is unthinkable.

  108. 108
    AA+ Bonds says:

    I know someone born outside of America who has deftly manipulated citizenship in two different countries to get the best deal she can from this shitty world

    I should introduce her to the term “global citizen”; she would laugh and laugh and laugh

  109. 109
    Raven says:

    @Calouste: Do what you want, it’s a free country.

  110. 110
    Tom says:

    @Soonergrunt:

    So different countries do things differently. Yay for international diversity.

    Not really. The US is the only country in the western world to tax its citizens based on citizenship, not residency. I would not call that diversity.

  111. 111
    AA+ Bonds says:

    @Calouste:

    You can take Asperger’s out of the symptoms but etc.

  112. 112
    Tom says:

    @shecky:

    Sorry. I misunderstood you.

    I think the real issue is why we tax based on citizenship, not residency. Saverin would not have renounced if we tax based on how the rest of the world taxes its residents.

    You can still make it extremely difficult for folks like Saverin to escape taxation in the US with residence based taxation.

  113. 113
    pseudonymous in nc says:

    @Soonergrunt:

    So different countries do things differently. Yay for international diversity.

    To repeat myself: the “international diversity” here places the US with Eritrea. That’s all. And the US signed on to a UN Security Council resolution last year complaining about Eritrea’s diaspora tax, which is bleakly fucking funny.

  114. 114
    AA+ Bonds says:

    The U.S. taxes its citizens like everywhere else: rich people pay whatever they fucking feel like paying

    You just have to be a lot richer than “rich” to be rich in the U.S.

  115. 115
    shecky says:

    @Brian R.: Sounds like a whole lot of envy to me. Saverin is free to leave (after the US gets its pound of flesh). And he’s doing exactly that. Freedom sucks, I guess.

  116. 116
    Linnaeus says:

    Sir, I heartily commend you for your excellent and appropriate use of the term “fuckstick”.

  117. 117
    burnspbesq says:

    @The prophet Nostradumbass:

    I’d need to see the inputs to their valuation model before I accept that $67 million number. I’ll bet a six-pack of your favorite malted beverage that the IRS challenges whatever valuation he put on his return.

  118. 118
    AA+ Bonds says:

    The question is: will he get away with it, whatever the fuck he’s doing, this rich asshole

    And the answer is: overthrow the capitalists

  119. 119
    jayboat says:

    Josh Marshall posted an interesting email from one of his readers:

    I can’t speak for the quality of Mr. Saverin’s legal advice going into the renounciation process, but as a consular officer with the Dept. of State who’s done denounciation of citizenship overseas, I can assure you that we’re under guidance to go over in detail with the applicant the potential consequences renounciation for purposes of evading taxes, and the visa ineligibility they may face. By the time he gets to the session with the officer, he can’t claim ignorance. We also also gave them two weeks to think it over. We don’t like having to deal with folks coming back saying “just kidding.”

  120. 120
    Calouste says:

    @Soonergrunt:

    I don’t. Why would I need to get citizenship in the US, just because I live here?

  121. 121
    Cacti says:

    @Calouste:

    some people think of themselves as global citizens

    Especially when they don’t want to pay taxes on income they generated in the United States.

  122. 122
    pseudonymous in nc says:

    @burnspbesq:

    Which is why I am less skeptical than some of you when he says his expatriation is not primarily driven by tax avoidance.

    I’m minded to agree with you: my guess is that he and his legal team were more concerned about the annual reporting requirements for foreign holdings and investments — FBAR, Forms 8938, 8865, 8621, 5471, 3520, etc. ad nauseam.

  123. 123
    Calouste says:

    @AA+ Bonds:

    Well, heaven forbid that people would actually live in different countries and experience different cultures during their lives.

  124. 124
    burnspbesq says:

    @AA+ Bonds:

    If you accept Bloomberg’s valuation analysis, Saverin voluntarily accelerated a $366 million tax liability in order to renounce his US citizenship. That number doesn’t say “get away with” to me.

  125. 125
    Calouste says:

    @Cacti:

    You have to pay tax on income you generate in the US under most cicumstances, regardless of where you live. If Saverin still has holdings in the US, he will get taxed on those, whether he is a US citizen or not, and whether he lives in the US or not.

  126. 126
    Soonergrunt says:

    @pseudonymous in nc: So what? And I don’t mean that to be offensive. I don’t really have a problem with any of that, frankly. No one forces expats to live abroad. It accrues nothing to the country for them to do so, and the fact that a lot of them do in fact choose to do so to lower their tax burden gives me no heartburn that it’s difficult to do so. They can, as Savarin has done, renounce at any time, or not, and accept the personal responsibility for that choice.
    Those are the laws of the country. Obey them or not at your risk, both as a citizen or a foreign national living here.

    Hell, if anything, what you’ve just told me makes it seem an even dumber prospect to become a US citizen if one is not committed to living here, earning one’s income here, and so forth. I mean, really–Why in the hell would Calouste want to become a US citizen if it’s so onerous a burden?

  127. 127
    Tom says:

    @burnspbesq:

    This is from the New York Times:

    If he remained an American citizen, he would not have had to pay the United States capital gains tax on his income until he sold his shares.

    When you renounce your citizenship, you have to pay en exit tax, even on all your unrealized transactions.

  128. 128
    pseudonymous in nc says:

    One last point: if Saverin earns a lifetime exclusion, it’s no skin off my nose. He’ll just have to park his yacht in Vancouver or wherever.

    But the foreign reporting and filing requirements mean that the majority of American expat citizens — not billionaires, but people who have moved abroad for work, or to be with family, or as retirees — have to deal with an annual bureaucratic clusterfuck.

  129. 129
    burnspbesq says:

    @Calouste:

    A non-resident alien who is not physically present in the United States for 183 days during the taxable year is not subject to US tax on US-source capital gain. That’s the game Saverin is playing. Because Singapore doesn’t have a capital gains tax, any appreciation after the date he expatriated is “nowhere income.”

  130. 130
    Tom says:

    @Soonergrunt:

    No one forces expats to live abroad. It accrues nothing to the country for them to do so, and the fact that a lot of them do in fact choose to do so to lower their tax burden gives me no heartburn that it’s difficult to do so.

    Do you really think our country would be better of with no expats whatsoever around the world? Maybe we should stop exporting American products all together…

    Also, there are tons of expats who has to pay more taxes than before leaving the US. Countries like France, Norway etc etc are not exactly tax paradises. This, of course, does not include the necessary fees for a tax accountant to deal with the draconian reporting requirements for the IRS.

  131. 131
    Soonergrunt says:

    @Calouste: Heaven forbid that people would be subject to the laws in different countries they visit or live in.

  132. 132
    burnspbesq says:

    @Tom:

    I think you responded to the wrong person.

  133. 133
    Cacti says:

    Speaking of global citizens, Mitt could receive Mexican citizenship through his father if ever he had the notion to apply for it.

    I wonder why he never talks about that in his Hispanic outreach.

  134. 134
    I_D_Inuse says:

    Now wait a damn minute. We, as in “We The People”, have sanctioned much less allowed, this to happen and one cannot complain about laws, which you and me bubba, said not a word when they were passed… when Congress was and is allowed to have rule by law and not rule of law, you nor I have a leg to stand on. Snark is funny but it does not get the job of government by the people and for the people done. You, me and all of us are guilty and a few ugly Americans count on our snark,knowing we are to lazy to back our mouths.

  135. 135
    Suffern ACE says:

    @burnspbesq: Yeah. I’m not really getting the outrage here. The right for making him a tax hero, the left for the tax dodge. Hes paying what he owes. If he thinks that prospects are better for him in the far east, well duh, prospects probably are. If he really wanted to dodge taxes, he’d sit on the loot and slowly hide it, like every billionaire with an accountant does.

    It’s been a few hours since we’ve had pics of marsupial babies. Maybe I’ll get outraged when the baby animal withdrawal effect wears off.

  136. 136
    Tom says:

    @burnspbesq:

    I was just trying to add to your excellent comment.

  137. 137
    burnspbesq says:

    @Tom:

    Ok. I misunderstood.

  138. 138
    pseudonymous in nc says:

    @Soonergrunt:

    Those are the laws of the country. Obey them or not at your risk, both as a citizen or a foreign national living here.

    Those laws weren’t written on stone tablets by the finger of God. We argue about dumb laws all the time here — but apparently dumb laws about citizenship, largely made out of sight of voters and never a part of election campaigns, are sacrosanct?

    Anyway, I’ll look forward to you reporting yourself to the Treasury if you ever smoke a Cohiba outside the US. Because laws is laws.

    Why in the hell would Calouste want to become a US citizen if it’s so onerous a burden?

    You might want to go back and re-read the thread, because you’re putting words in Calouste’s mouth. In any case, the IRS treats long-term permanent residents (8 taxable years of the last 15 in the US) exactly the same as citizens when it comes to expatriation. Which, I’m guessing, is another law you didn’t know about.

    I just think there’s a naivety on display here (and a clinging to a mythology of immigration) that needs challenging. It’s 2012, not 1912: immigration no longer means getting on a boat to Ellis Island and spending the rest of your life here.

  139. 139
    Soonergrunt says:

    @Calouste: From your comments earlier about getting a passport.
    Why does a non-US-citizen need a US passport anyway? Is your home country passport not pretty enough? Obviously you’ve gotten in to the US (and gotten a green card) without needing one. So what benefits accrue to a US passport that do not accrue to the passport from your own country?

  140. 140
    burnspbesq says:

    @Suffern ACE:

    $366 million will cover a fair number of unemployment checks and Medicaid reimbursements.

  141. 141
    Omnes Omnibus says:

    As far as I am concerned, if the guy doesn’t want to be an American citizen, fine. People choose to come here and become citizens; why can’t someone choose to go somewhere else? As I understand it, he became a citizen at 16 through his parents; he never chose it for himself.

    That being said, it would be difficult to convince me that it isn’t for tax purposes. I hope they get every penny he owes and that he has to live with the other consequences, including exclusion.

    It’s his choice.

  142. 142
    pseudonymous in nc says:

    @Soonergrunt:

    Is your home country passport not pretty enough?

    Really? Don’t be a GS-11 level dick about this.

  143. 143
    Soonergrunt says:

    @pseudonymous in nc: When I was stationed overseas, we had commercials on official AFN television reminding US personnel that they had to smoke up or give away any cigars made in Cuba that they had bought as they could not bring them home. Other commercials reminded people to put their Persian rugs into the thrift shop for whatever they could get for them because importing Iranian products into the US was illegal.
    Right before my first team left Afghanistan we had a big party and smoked the last of their Cuban cigars. When I left, I did the same thing. The guy who tried to smuggle some Cubans got caught by the MP working dogs and got an Article 15 and held over for an extra 45 days for his trouble.
    I’m good to go on that. As far as banking goes, I lived off post in Germany and later in Italy, and never had a problem paying my bills or making purchases with a Visa check card and that was 15 and 20 years ago.

    As to the second part, I’ve addressed that at #139.

  144. 144
    Soonergrunt says:

    @pseudonymous in nc: Well, what is the benefit?
    Considering that there are places in the world where a US passport will get someone killed, what are the benefits? I can honestly see NOT getting a passport if one didn’t HAVE to do so for international travel, but what benefit is there for a non-citizen to have a US passport as opposed to a passport from another country?

  145. 145
    Soonergrunt says:

    @Omnes Omnibus: Pretty much EVERYTHING he said.

    @pseudonymous in nc: My paygrade is irrelevant, as my specialty is IT, not Consular Operations. Nobody paged you with the title ‘jerkass’ either, you know.

  146. 146
    Warren Terra says:

    All these people who are outraged that an American citizen living overseas is liable for US taxes, and for taxes on overseas income, are either ignorant or dishonest. We have treaties with basically the entire civilized world (read: those places that collect taxes) that make taxes paid overseas wholly deductible from your US liability. So, if you’re earning income anyplace the US wants to be sure you’re paying enough taxes on it – and if you aren’t paying those taxes elsewhere, the US will make you pay the taxes to them.

    All the stuff about how hard it is to open an account overseas and the “onerous reporting requirements” is all my balls. I opened a bank account in Germany when I was a dumb student, knew nothing, and wasn’t really fluent in the language. It took me several minutes. And if you find your reporting requirements to be “onerous” that means you have a sufficiently diverse, complicated, and ample income flow that you should probably STFU about your First World Problems. Also, you should probably pay a professional to do the paperwork for you.

    The point here is that Saverin isn’t some sort of bullshit “citizen of the world”: he made a fortune in the US, and stands to officially make a much bigger fortune in capital gains. By moving to Singapore (and yes, he did that a couple of years ago – but his eventual capital gains from Facebook weren’t exactly a secret a couple of years ago), he goes from paying absurdly low taxes on capital gains (the US prescription) to paying none at all. On wealth he made from the opportunities the US offered him. That’s pretty scuzzy.

  147. 147
    Mnemosyne says:

    @Warren Terra:

    IIRC, the complaints about the bank accounts are because of recent changes that were made because of anti-terrorism legislation, not because of immigration law.

  148. 148
    Omnes Omnibus says:

    @Mnemosyne: Is this the onerous reporting requirement that people are talking about?

  149. 149
    Raven says:

    @Soonergrunt: At Cam Rahn Bay Repo Deop there was an area on the perimeter where troops would go to smoke up all the bud they had before they rotated or went on R&R. Fucking great place to be!

  150. 150
    pseudonymous in nc says:

    @Warren Terra:

    I opened a bank account in Germany when I was a dumb student, knew nothing, and wasn’t really fluent in the language. It took me several minutes.

    And that was… when, exactly? Tthe reporting requirements post-9/11, especially in the last five years, are a fuckload different.

    @Soonergrunt:

    Right before my first team left Afghanistan we had a big party and smoked the last of their Cuban cigars. When I left, I did the same thing. […] I’m good to go on that.

    If it was after the September 2004 revision of 31 C.F.R. Part 515, then alas, no, and both your base and AFN got the law wrong: the Treasury asserts global jurisdiction over US citizens’ use and consumption of Cuban goods.

  151. 151
    Raven says:

    @pseudonymous in nc: They had jurisdiction over what we used and consumed too! Ha!

  152. 152
    Soonergrunt says:

    @Raven: LOL. The official doobie smoking area.
    Different times.

  153. 153
    Odie Hugh Manatee says:

    @Boots Day:

    Yes, and that was your choice to give it. Not only that but you knew exactly what info you were releasing.

    FB is all that and much, much more. Is your ski shop keeping track of everything you say and do in RL after the sale?

    No.

  154. 154
    bargal20 says:

    Wow, you Americans really get all butthurt when someone doesn’t see American citizenship as something sacred and holy grailish. We Australians didn’t burst into tears when Rupert Murdoch renounced his Australian citizenship for business reasons and became one of you.

    Grow up.

  155. 155
    Raven says:

    @Soonergrunt: But they did have those deadline barrels where you had one last chance to unass the goods!

  156. 156
    schrodinger's cat says:

    Don’t you have to be citizen of a country to get its passport.

  157. 157
    Soonergrunt says:

    @pseudonymous in nc: Oh. Well. I’ll get a lawyer. Probably one of the reservist lawyers I was with would do it.

  158. 158
    Soonergrunt says:

    @schrodinger’s cat: but what benefits are gained by getting a US passport if one has a perfectly valid passport from their own home country?

    And conversely, what benefits the US to grant a passport to a citizen of another country?

  159. 159
    Soonergrunt says:

    @Omnes Omnibus: It would seem so.

  160. 160
    Soonergrunt says:

    @bargal20: Actually, most of the people who are butthurt are so because of the rather obvious tax dodge.
    I for one don’t give two shits where he lays his head, but the whining about how unfair the law is to him is pretty pathetic. And most of the people on this board would like to see Rupert returned to Australia, I’m sure.
    If he were convicted of violating the Foreign Corrupt Practices Act, could his citizenship be revoked? Cause then Fox “news” would have to be sold off.

  161. 161
    Silver says:

    @Soonergrunt:

    To start with, you don’t have to renew the damn green card. You also aren’t liable for deportation for getting caught with weed…

  162. 162
    Soonergrunt says:

    @Raven: We had amnesty barrels at the bases in Iraq and Afghanistan, and more amnesty barrels in Kuwait and Manas, Kyrgyzstan.
    I can only guess at what was recovered from them.

  163. 163
    Brandon says:

    @Soonergrunt: Actually, what gets me is that he obviously wants to enjoy the fruits of the U.S., whether by visiting NYC to party with models during Fashion Week or using the institutions, i.e. the courts, that we all pay for to make himself rich and happy, but he just doesn’t want to pay taxes on it and he thinks its okay because he’s rich and thinks he can get away with it. What pisses me off most of all is that every day across the world there are tens of thousands of people looking the travel to the U.S. for legitimate reasons who are not rich but are denied that opportunity, like the mother of a friend of mine from graduate school was denied a visa to travel from Bolivia to see her daughters graduation. That’s what makes me sick. So I hope this f*cker is never allowed to set foot in the U.S. ever again. You don’t get to have it both ways.

  164. 164
    Mnemosyne says:

    @bargal20:

    Wow, you Americans really get all butthurt when someone doesn’t see American citizenship as something sacred and holy grailish.

    I think it’s the attempt to avoid paying $63 million in taxes to the US on money he’s going to make by selling the IPO of a US-based company on the US stock market that’s causing the butthurt.

    If he wants to become a citizen elsewhere, no one really cares as long as he pays the taxes he owes on his US-earned money instead of trying to dodge them by taking citizenship somewhere where he won’t owe those taxes.

  165. 165
    Warren Terra says:

    @Silver:
    Also, you can lose your green card if you aren’t in the US 183 days of the year.

    And the US passport is about the most useful in the world in terms of visa-free travel (I suspect the EU passport is equal or close – but not the Brazilian or Singapore passport). Similarly for consular access and general protection if you get arrested overseas, though I’m sure Savarin will have so many lawyers with him at all times this won’t matter.

    @pseudonymous in nc:
    I notice you didn’t attempt to defend your bullshit about it being awful that Americans have to pay taxes on overseas income, nor your crocodile tears about how awful it is to have to report your income.

    Let me reiterate: Saverin isn’t doing this because of an abiding fascination with Singaporean culture, nor because of all the exciting business opportunities in Asia. Saverin has enough money to travel to business opportunities, or for them to come to him; and I rather doubt he can speak or read three of the four official languages of Singapore. He’s moving there because they – unlike the US and unlike his native Brazil – have no capital gains tax. Our society has made him insanely wealthy, and by god he’s not giving any of that up. The only interesting thing about his choice is that he is trusting Singapore to be more amoral-plutocrat-friendly in the medium-to-long term than Dubai – or for that matter than London, which has its own inexcusable and execrable situation with wealthy foreigner (and in some case pseudo-foreigner) “non-doms” living in London and paying taxes nowhere. Or in Monaco or in the Channel Islands.

  166. 166
    Odie Hugh Manatee says:

    @bargal20:

    You can have him back, we didn’t ask for the asshole.

  167. 167
    Boots Day says:

    Is your ski shop keeping track of everything you say and do in RL after the sale?

    No, and neither is Facebook.

    It strikes me as kind of funny that the people who hate Facebook the most are the ones with no experience of it. I know plenty of people who went on Facebook and decided it wasn’t really for them, but none of those people have the full-on hatred for FB that non-FB users do.

  168. 168
    Mojotron says:

    shorter bargal20: you didn’t hear me complaining when I had my anal cyst removed, did you?

  169. 169
    lless says:

    The list of the wealthy who are excludable by the Attorney General numbers zero. Do the FOIA.

  170. 170
    pseudonymous in nc says:

    @Warren Terra:

    I notice you didn’t attempt to defend your bullshit about it being awful that Americans have to pay taxes on overseas income, nor your crocodile tears about how awful it is to have to report your income.

    Oh, do fuck right off. It’s a stupid, anomalous rule that the US actively opposes when other countries try it, and that now adds a fuckload of hassle for people of relatively modest means, or living off retirement income, while billionaires either pay the exit fee or get their lawyers to squirrel away their money and make deals with the IRS. (If you want to push the argument that it’s for consular services, then put a billing office at the entrance to every US mission, following the glorious principle of the American healthcare system.)

    And if you want to pretend that all expat Americans are bathing in gold like Scrooge McDuck, please go right ahead, but that’s no different than saying all gay men dress like it’s the Folsom Street Fair every day of the year and that all feminists are ugly man-haters.

  171. 171
    SiubhanDuinne says:

    @Tom:

    And today the U.S. is the only western country that taxes based on citizenship, not residency.

    I could easily be wrong, but I think Canada does too.

  172. 172
    Warren Terra says:

    @pseudonymous in nc:
    I’m all in favor of progressive taxes and income support for the poor. If an American citizen is living as a retiree overseas impoverished by their American taxes, well, I’m rather confused by that. The logical interpretation – given that they’re eligible for Social Security wherever they are, and for the standard deductions and the like – is that they’ve retired to some supposedly cheap place to live without making proper provisions or with unrealistic expectations. And if they’re in such straitened circumstances, their incomes are hardly going to be so complex as to make reporting a great burden. In general, the situation you describe is flat-out absurd, and amounts mainly to complaining that some people thought they could live for a song among the far-off lotus eaters, and have been brought back to reality. I suppose their American tax liabilities are a part of the tether returning them to reality, but the miscalculation in general is all their own doing. And if they’re living someplace that actually requires a respectable, taxable income, chances their American tax burden is in any case irrelevant.

    And none of this explains why you’re so determined to trot out all these ludicrous scenarios in the defense of the banditry of Saverin, to whom they definitely do not apply.

  173. 173
    pseudonymous in nc says:

    @Warren Terra:

    In general, the situation you describe is flat-out absurd

    “Why should I waste my beautiful mind on something like that?”

    If Americans, like the citizens of pretty much every other country, were not taxed on income earned abroad while living abroad, you wouldn’t be making such handwavy arguments (“the tether returning them to reality”, indeed) that they should.

    Here’s a post from Democrats Abroad noting the requirements of FBAR and FATCA, and the attempt to get the reporting thresholds raised.

    none of this explains why you’re so determined to trot out all these ludicrous scenarios in the defense of the banditry of Saverin

    I always find that it’s best not to put words in other people’s mouths. You should try that.

  174. 174
    Beauzeaux says:

    I’m an american citizen living in Canada. The important word in the quote is “IF”:
    “…if my renunciation of United States citizenship is determined by the United States Attorney General to be motivated by tax avoidance purposes….”

    The gov’t is usually extremely careful NOT to use the “motivated by tax avoidance” unless they are absolutely sure they can’t get money out of this guy one way or another.

  175. 175
    Warren Terra says:

    @pseudonymous in nc:
    You sing this sad lament of Americans living overseas rendered destitute by the way American law requires them to pay taxes in the income they earn, either to the government with jurisdiction where the money was earned or to the US government (at least, this is usually the case, that treaties make the taxes paid where the income is earned completely deductible from American tax liability). You point out, accurately for all I can tell, that this requirement is so unusual as to be extraordinary, and imply that it’s unjust. But mostly you assert that there exists a class of people for whom it is a monstrous imposition rendering them impoverished. I say that is nonsense, that the numbers simply don’t add up – the places that don’t already levy taxes sufficient to make American taxes moot tend to have a sufficiently low cost of living to make American taxes moot.

    And in response, you whine about reporting requirements? Not about the burden of taxation? By all means, raise the lower limits on those reporting requirements. What that has to do with a damn thing quite escapes me. And the requirements sound perhaps excessively inflexible, with statutory penalties that sound dauntingly high – but the reporting itself sounds rather simple to do.

    And then you have the gall to act as if the case of Saverin were in some way irrelevant, that by pointing out your determination to avoid directly touching on it, in a thread about it, I’m putting words in your mouth. I’m not; I’m pointing out the absence of relevant words issuing therefrom, in a thread entirely predicated on the case of Saverin, in which you’re making the case that Saverin was right, that income received overseas by Americans should not be taxable (as if Saverin’s capital gains on the stock in the American company Facebook he received in America should even qualify as income received overseas).

  176. 176
    bargal20 says:

    @Soonergrunt: Do what you like to Rupert. He hasn’t been an Australian citizen since the 1980s, so if you revoke his US citizenship we don’t get him back. He’ll have to buy into some other country.

  177. 177
    SectarianSofa says:

    @bargal20:

    True. I’m pissed off at Rupert Murdoch every day — this fuckstick former friend of facebook really shouldn’t generate so much outrage. Though many clearly disagree. If I had a choice between kicking this guy in the nuts, or kicking Donald Trump in the nuts, I’d go with the Trump nut kick every time. Sane or rational? Probably not. Are we focusing on this dude just because it’s easier than trying to tackle something harder to solve? It’s like there’s a big fucking herd of the Corrupt thundering across the savannah, and this guy’s basically a slow, easy target, falling behind and into range of our claws because he’s not a full-grown shitheel yet. If he starts funding Cartels or Catholic Fondling Foundations, then I’ll be really pissed, getting my pitchfork ready. Right now, though, it just doesn’t seem remarkable enough. I wish he’d take some more folks with him to Singapore.

  178. 178
    Guy says:

    @Warren Terra: The individual filing requirements for FBAR and FATCA, while a pain in the ass, are not the main problem. FATCA’s bold experiment in the extraterritorial application of US tax law to foreign banks and other entities threatens to turn Americans into international pariahs. Rather than deal with the huge cost and legal complications (in some countries it would actually be illegal to comply) of compliance, many are simply dropping their US clients. People are finding that it is increasingly difficult to do the normal stuff of life like open a bank account, get a mortgage or insurance, find a business partner, etc. This, not a little extra paperwork for individuals is problem. If you think this is only a problem for expats, think again. The US government is essentially hanging a sign out in the world which says “avoid all entanglements with Americans”. I can’t help thinking this will be harmful to the US in general in the long run.

    Saverin is an outlier. It is unfortunate that all the media attention paid to cases like his distracts from serious and legitimate concerns.

  179. 179
    Soonergrunt says:

    @Guy: Now there’s some actual useful information.

  180. 180
    Tom says:

    I say that is nonsense, that the numbers simply don’t add up – the places that don’t already levy taxes sufficient to make American taxes moot tend to have a sufficiently low cost of living to make American taxes moot.

    I know US expats who live in Norway, just as an example. Their US IRA’s are taxable there, not tax-deferred or tax-free as here. Not only that, they have tax rates in Norway which are far higher than the ones we have here in the US. And, of course, Medicare does not cover Americans abroad. It is not that easy sometimes to even be eligible to the foreign medical system, which may mean additional expense for private health insurance.

    And in response, you whine about reporting requirements? Not about the burden of taxation? By all means, raise the lower limits on those reporting requirements. What that has to do with a damn thing quite escapes me. And the requirements sound perhaps excessively inflexible, with statutory penalties that sound dauntingly high – but the reporting itself sounds rather simple to do.

    I have a friend who is a CPA. He said that he normally charged $500 for the expats regular tax return. But he had to double his fee to a $1,000 just to comply with the FBAR and the FATCA requirements.

    If you seriously think that every US expat is some kind of Saverin, then it is difficult to have a conversation with you. Most expats are just like people in the US, middle-class and struggling to make it. And the $1,000 for the reporting requirements are indeed major expenses. How would you feel about spending $1,000 when you know you don’t owe taxes anyway?

  181. 181
    pseudonymous in nc says:

    @Warren Terra:

    I’m pointing out the absence of relevant words issuing therefrom, in a thread entirely predicated on the case of Saverin, in which you’re making the case that Saverin was right

    I think I’ve made it pretty fucking explicit that I don’t give a fuck about Saverin, because he’s not going to be burdened. To make it even more fucking explicit, I very much regard the capital gains realised from his Facebook holding as taxable income, regardless of where he lives, and would prefer the law outlined by burnspbesq at comment 129 to be changed accordingly. (That said, the reporting suggests that he’ll probably retain his stake and use it as collateral for loans instead.)

    As Guy says, the impending imposition of FATCA means that foreign banks are closing accounts held by US citizens because they’d prefer not to deal with the IRS. (German banks are definitely doing this; Israeli banks are also urging US citizen account holders to close their accounts voluntarily before the law takes effect.) And as Tom says, the professional fees for tax preparation go up accordingly.

    My point all along has been that focusing on megarich assholes like Saverin makes it easier to perpetuate a set of stupid and anomalous rules against millions of American expats, a group that collectively has very little political influence, in part because of the kneejerking on display in this thread.

  182. 182
    Another Halocene Human says:

    @Tom:

    Also, there are tons of expats who has to pay more taxes than before leaving the US. Countries like France, Norway etc etc are not exactly tax paradises. This, of course, does not include the necessary fees for a tax accountant to deal with the draconian reporting requirements for the IRS.

    And those lucky duckies get paid more by their employers to “entice” them to go there. Oh boo hoo hoo, boodefuckinghoo.

    Londoners now pay about 12.5% tip when they go out thanks to rich, overtaxed American ex-pats throwing money around and changing the social climate.

  183. 183
    Another Halocene Human says:

    @Odie Hugh Manatee:

    FB is all that and much, much more. Is your ski shop keeping track of everything you say and do in RL after the sale?

    How do you know? Businesses sell customer’s data all the time, and it’s perfectly legal.

    Unlike Soshulist You’re Up, we only pass laws to constrain the government with regards to privacy (and sometimes we score own goals, like Sunshine Laws that make public employees private info public to everyone, like stalkers), but never, ever constrain the magic hand of bidniss.

  184. 184
    Another Halocene Human says:

    @Brandon:

    What pisses me off most of all is that every day across the world there are tens of thousands of people looking the travel to the U.S. for legitimate reasons who are not rich but are denied that opportunity, like the mother of a friend of mine from graduate school was denied a visa to travel from Bolivia to see her daughters graduation. That’s what makes me sick. So I hope this f*cker is never allowed to set foot in the U.S. ever again. You don’t get to have it both ways.

    Exactamundo. This is a rich-vs-poor, 1% of 1% vs the proles issue. The concern trolls are showing their true colors on this one. The right-wing fsckally conservative talking points have been flying fast and furious.

  185. 185
    Another Halocene Human says:

    @Warren Terra:

    Our society has made him insanely wealthy, and by god he’s not giving any of that up. The only interesting thing about his choice is that he is trusting Singapore to be more amoral-plutocrat-friendly in the medium-to-long term than Dubai – or for that matter than London, which has its own inexcusable and execrable situation with wealthy foreigner (and in some case pseudo-foreigner) “non-doms” living in London and paying taxes nowhere.

    So, basically, the Florida of the international jet set.

    Enjoy your grifters, murderers, and thieves, Singapore!

  186. 186
    Tom says:

    @Another Halocene Human:

    And those lucky duckies get paid more by their employers to “entice” them to go there. Oh boo hoo hoo, boodefuckinghoo.

    Do you really think all of the expats have employers that “entice” them to go there as you put it? I know several who are just trying to get by.

  187. 187
    Another Halocene Human says:

    @Tom:

    I know US expats who live in Norway, just as an example. Their US IRA’s are taxable there, not tax-deferred or tax-free as here. Not only that, they have tax rates in Norway which are far higher than the ones we have here in the US. And, of course, Medicare does not cover Americans abroad. It is not that easy sometimes to even be eligible to the foreign medical system, which may mean additional expense for private health insurance.

    But, but, American exceptionalism! We have the highest and most burdensome taxes! We do! I know we do!

    Tom, I think you missed the bit about how your furrin taxes are deductible before you start paying US tax. (Same thing with state tax, by the freaking way. And yet the high tax states STILL toss more in the fed coffers than lowtax, low anything resembling economic activity states. For which the cure is LESS TAXES. It’s LOGIC, you can’t argue with that, Libs!)

    Soooo, I’m guessing Norway is not a safe haven for parasites who made their money in US or another country and want to runaway somewhere else to enjoy the fruits of their ill gotten gains in low tax peace. Gosh, it must really pain them, what with their top five standard of living and peaceful society.

  188. 188
    Another Halocene Human says:

    @pseudonymous in nc: Your point has been to derail the topic at hand, for which I say congratulations. Also, your moving of the goalposts in this discussion has been noted and logged.

    Good day.

  189. 189
    Another Halocene Human says:

    @Tom: You have friends who were forced by their employers to hoof it overseas with their families and are now beating on the gates of poverty?

    Do tell.

  190. 190
    Tom says:

    @Another Halocene Human:

    Tom, I think you missed the bit about how your furrin taxes are deductible before you start paying US tax.

    This is simply not true for all taxes. In Norway for example, an American has to pay ordinary capital gains tax on any gain in his IRA’s. This would not be deductible in the US. You don’t have to believe me if you don’t want. They checked with their CPA.

    The friend I have had a pre-existing condition and could not get health coverage here in the US. He eventually married someone from Norway and due to his health condition he got coverage in Norway. I guess you think he is a parasite, too…

    Have a nice day!

  191. 191
    Another Halocene Human says:

    Tom says:

    The friend I have had a pre-existing condition and could not get health coverage here in the US. He eventually married someone from Norway and due to his health condition he got coverage in Norway. I guess you think he is a parasite, too…

    Nice, he got health coverage. Nice country, Norway.

    But earlier, Tom says:

    And, of course, Medicare does not cover Americans abroad. It is not that easy sometimes to even be eligible to the foreign medical system, which may mean additional expense for private health insurance.

    Which is it, Tom? Onerous high taxes or niggardly, inaccessible healthcare systems? You mean the high taxes and the generous health care go hand in hand?

    WHOCOOODANODE???????

  192. 192
    pseudonymous in nc says:

    @Another Halocene Human:

    Good day.

    You need to work on your overdramatic flouncing.

  193. 193

    […] if I can characterize it as a position, is that Saverin deserves his own special circle in hell. Mistermix over at Balloon Juice is outraged. Josh Marshall at TPM is scandalized, and is still devoting […]

  194. 194

    […] After years of reaping the benefits of a society that does reasonably well at preventing kidnapping, he became a billionaire. Then he moved to Singapore. Then, standing to make billions on Facebook’s IPO, he renounced his U.S. citizenship. […]

Trackbacks & Pingbacks

  1. […] After years of reaping the benefits of a society that does reasonably well at preventing kidnapping, he became a billionaire. Then he moved to Singapore. Then, standing to make billions on Facebook’s IPO, he renounced his U.S. citizenship. […]

  2. […] if I can characterize it as a position, is that Saverin deserves his own special circle in hell. Mistermix over at Balloon Juice is outraged. Josh Marshall at TPM is scandalized, and is still devoting […]

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