Category Archives: DST

The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship

Update – June 27, 2025 – The 899 Penalty Tax has been removed from the “Big Beautiful Bill”:

Introduction – It’s The American (A)Way

The United States tax system is designed to impose punitive tax, reporting and penalties on the non-U.S. income and assets of Americans abroad. Nonresident aliens (those who are neither U.S. citizens nor residents) are taxable ONLY on their U.S. source income.

This reality has driven many U.S. citizens (living abroad) to renounce U.S. citizenship. It has also caused many Green Card holders to abandon their green cards. This is the consequence of U.S. citizenship-based taxation – a system that defines tax residency in terms of one’s citizenship (one may not reside in one’s country of citizenship) – regardless of one’s actual residence. (Green Card holders are deemed to be U.S. tax residents regardless of their residence.)

The United States taxes ALL U.S. source income regardless of the recipient of the income. Therefore, the practical impact of citizenship taxation is to impose U.S. taxation on the non-U.S. source income of individuals who do NOT reside in the United States. To put this in visual terms:

A person born in the United States, with no U.S. source income, is subject to U.S. tax, reporting and penalties on income received from the country where that individual lives.

A Summary Of How Different People Are Subject To U.S. Taxation

1. The United States taxes ALL individuals – regardless of citizenship or residence – on U.S. Source income.

2. The United States taxes its RESIDENTS – regardless of citizenship – on worldwide income.

3. The United States taxes U.S. citizens – regardless of residence – on worldwide income. The United States is the only major country that taxes its citizens on their worldwide income when they do not live in the country.

4. The United States taxes nonresident aliens (those who are neither citizens nor residents) on U.S. source income.

The 2025 “Big Beautiful Bill” proposes a new S. 899 of the Internal Revenue Code. This new section would impose a more punitive U.S. tax regime on the U.S. source income, received by some, but not all, nonresident aliens. The more punitive regime would be imposed on nonresident aliens who are tax residents of countries that are described as “offending foreign countries”. “Offending foreign countries” are countries that the U.S. deems to impose unfair taxes on U.S. corporations or persons. To be clear, the tax paid imposed on the individual, would be based on the tax policies of the country where the individual is resident for tax purposes!

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Take YOUR Money And Run: Understanding The Proposed § 899. ENFORCEMENT OF REMEDIES AGAINST UNFAIR FOREIGN TAXES

Update – June 27, 2025 – The 899 Penalty Tax has been removed from the “Big Beautiful Bill”:

Update – June 22, 2025:

The Senate version of the Big Beautiful has been released. The full text is here:

https://www.finance.senate.gov/imo/media/doc/finance_committee_legislative_text_title_vii.pdf

In general, the Senate version retains the substance and principles of the House version.

The Senate version begins on page 138.

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Attention (At Least) Residents Of Countries With DSTs (“Digital Services Tax):

The Trump administration’s “Big Beautiful Bill” includes a provision to impose punitive taxes on nonresident aliens, with U.S. source income, who are residents of countries that have “Digital Services Taxes” (and other taxes applying to U.S. persons that they deem to be unfair).

This is “pretty rich” coming from the one country in the world that through it’s “citizenship tax” regime imposes taxation on the non-U.S. source income of received by people who don’t live in the United States!

At present the following countries (including Canada) impose DSTs. Note that the imposition of certain kinds of taxes (in addition to DSTs) may subject individual nonresident aliens to punitive taxation.

Generally, the law would impose, in addition to the existing U.S. tax, an additional tax, ranging from an additional 5% to an additional 20%.

Bottom Line:

Nonresident aliens who hold U.S. securities, U.S. real estate or have income that is effectively connected to the United States (“ECI”) may want to consider liquidating these investments.

My initial reaction and analysis suggests that Canadian residents will be particularly impacted by this measure. I will update this post as necessary and appropriate. Nevertheless:

“To Be FORMWarned Is To Be FORMArmed!”

This will not effect immediately. You have time to ponder this and understand it. This will not take effect immediately.

To understand the reasons, tax and general methodology for this conclusion, read on …

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