Presumptions, tax residency and presumptions of tax residency: Nonresident alien status in a FATCA world

Introduction – All The World Is A Multiple Choice Test Q.1 – A tax resident of the United States is taxable on his worldwide income. According to the Internal Revenue […]

Green Card holders who have moved from the United States without properly severing US tax residency

Here is the scenario that this post is addressing: An individual becomes a permanent resident of the United States (meaning that he has a Green Card). He lives in the […]

Domicile as a basis for tax residency: How to have @taxresidency where you may not live

What is domicile? About domicile … Domicile is an old “common law” concept. Domicile is NOT the same as “residency” (although it might include residency). Domicile is NOT the same […]

Determining Tax Residency In the United States: Citizenship and other forms of deemed tax residence

Introduction The search for second passports and #offshore havens via @FT – how the #CRS and #FATCA have created @TaxHavenUSA — Citizenship Lawyer (@ExpatriationLaw) May 20, 2017 The advent […]

Determining Tax Residency in Canada: Deemed resident vs. factual resident

How #taxresidency in Canada is understood by @OECDTax for the Common Reporting Standard — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 21, 2016 Let’s begin with […]

Tax residency vs. physical presence: The four questions you must ask before making a country your home

An introduction to “tax residency” … Most people equate residency with physical presence. They assume that where you are physically presence determines where you live. They further assume that where […]

Take 1: Digging The Foundation To Build The House Of US Residency-based Taxation

Thanks to @Tpsmyth01 for help in "Take 1: Digging The Foundation To Build The House Of US Residency-based Taxation" – Hosting a zoom call to discuss proposal and related matters […]

Part 19 – Comments from those with @TaxResidency in other countries about the effects of @USTransitionTax & #GILTI

Designed for Google and Amazon and applied to individual Americans abroad … USA: Hands Off CCPCs! MT @ExpatriationLaw @ADCSovereignty 2 USA: PLS don’t harm CDNs w/retrospective tax on CCPCs […]