Category Archives: Republicans Overseas Tax

Seeking Testimonials From Americans Abroad Who Have Been Subjected To Double Taxation

To U.S. Citizens Residing Outside The United States

Re: Continuing Efforts Of Republicans Overseas To End The Double Taxation Of Americans Abroad

Republicans Overseas continues to (1) recognize President Trump’s commitment to end the double taxation of Americans abroad and (2) remains committed to the goal of ending this double taxation. The goal cannot be achieved without the support and committment of the community of individual U.S. citizens living outside the United States.

Achieving changes of this magnitude is “NOT A Spectator Sport!”

Here is how the assistance of individual Americans abroad (wherever you may be) is required:

On behalf of Republicans Overseas, Republicans Overseas Tax Committee and Solomon Yue, I am reaching out to the community of U.S. citizens abroad seeking:

– written testimonials explaining how the U.S. tax code has resulted in double (and damaging) taxation in a manner that would NOT be experienced by U.S. residents

– examples could include: transition tax, GILTI, U.S. taxation of tax deferred retirement planning accounts, your pensions being unjustly taxed as foreign trusts, problems of using non-U.S. mutual funds for investing, PFIC, etc. We need specific testimonials describing exactly how the U.S. tax code imposed on Americans abroad leads to this result.

– penalties that have been unjustly levied on the failure to report (or late reporting) of the normal instruments of financial/retirement planning in your country of residence (Penalties imposed on TFSA, ISA, small business corps, etc.)

– taxation on phantom capital gains on the sale or refinancing of your home outside the United States

– having to pay the 3.8% Obamacare surtax on non-U.S. investment income while not being permitted to offset the foreign tax payable by using foreign tax credits

– being denied access to normal banking and brokerage accounts in your country of residence because of FATCA

– having your career opportunities limited because of a reluctance to hire, partner with, or invest with “U.S. persons”

– former U.S. citizens who feel they were forced to renounce U.S. citizenship because they could not afford the enormous compliance costs associated with U.S. citizenship or because the U.S. tax code limited their career opportunities

– other?

In other words, we want to document the actual damage!! I will assist you in drafting your testimonial so that it accurately explains HOW the U.S. tax code has resulted in double taxation.

Republicans Overseas is continuing its years long mission to end the unjust double taxation of Americans abroad. President Trump has committed to ending the unjust double taxation of Americans abroad. It is expected that there will be a second legislative opportunity in the fall of 2025.

Actual testimonials focusing on double taxation are critical. The testimonials are required by mid September 2025.

Please contact John Richardson if you are able to assist:

citizenshipsolutions@protonmail.com

Treasury’s Claim That The FEIE Is A Costly Expenditure, Whether True Or False, Is A Strong Argument FOR Tax Reform

Prologue

On January 29, 2025 a post by Keith Redmond on X.com suggested that Treasury had identified the Foreign Earned Income Exclusion (“FEIE”) – found in Internal Revenue Code 911 – as a tax expenditure costing the Treasury 5.6 billion dollars a year.

Keith’s post immediately generated discussion with CPA Phil Hogan. Phil noted that those Americans abroad who used the FEIE probably would not owe tax on income excluded by the FEIE. He noted that Foreign Tax Credits could be used to offset the taxes owed on the income excluded by the FEIE. Phil’s point (confirmed by CPA Kevyn Nightingale) is incredibly important.

(I have included, as an Appendix to this post an analysis of WHY many (if not most) Americans abroad who file using the Foreign Earned Income Exclusion would NOT owe U.S. tax, if the income excluded under the FEIE were included as U.S. taxable income. The short explanation is that if the income were INCLUDED on the U.S. tax return, taxes paid in the country of residence, would be used to effectively pay the U.S. tax on that included income. See the Appendix for further discussion).

Is The Claim That The Foreign Earned Income Exclusion Costs The U.S. Tax Revenue Really Credible?

Continue reading →

Republicans Overseas Announces President Trump Proposal To End Double Taxation Of Americans Abroad

October 2, 2024

Republicans Overseas today announced that former President Donald Trump wishes to end the double taxation of Americans abroad! Further details to follow …

For the moment, please reference the following tweets:

Republicans Overseas has a long history of advocating for Americans abroad. These initiatives include:

– 2014 FATCA Legal Action lawsuit

– 2017 House Hearings On FATCA

– 2018 Hugely influential in the development of the Holding Bill

– 2024 Announcement of Residence-based taxation proposal

– 2024 Announcement from President Trump

More to come …

John Richardson – Follow me on X.com @Expatriationlaw

Separating Citizenship From Tax Residency: The Republicans Overseas Tax Proposal

In 2024 the Republicans Overseas Tax Committee created the following proposal for separating U.S. citizenship from U.S. tax residency. The proposal is three parts which are:

1. A Legislative Fix – changing who is a tax resident from “individual” to “resident”.

2. A Regulatory Fix – changing the regulation to define “individual”in the Internal Revenue Code to mean “resident”

3. A Treaty Fix – narrowing the range of the treaty “saving clause” so that U.S. citizens who are tax residents of other countries can use the “treaty tie break” provision to be treated as nonresidents.

Ending the Unjust Taxation of Overseas Americans

A September 2024 twitter discussion of the proposal is here along with a link to a series of videos made by John Richardson and James Gosart:

John Richardson – Follow me on X.com @ExpatriationLaw

Town Halls: Tuesday Sept. 17/24 – @RepOverseasTax Introduces Its Tax Proposal For Americans Abroad And Invites Discussion

Update September 23, 2024:

Here is a link to the “Town Hall Discussion”

_________________________________________________________________________

There are two sessions coming up – both on X.com

Tuesday September 17:

North America – Note this 8 p.m. EDT

Rest Of World – Note this is 2 pm EDT

Feel free to attend either or both. Looking forward to discussion!

If you can’t make the town halls, here is a series of short videos created by John Richardson, Jim Gosart and Jonathan Constantine which explain why the cancerous tumor of citizenship taxation needs to be removed!!

Finally, here is the Republicans Overseas tax reform proposal for U.S. citizens living outside the United States.

Ending-the-Unjust-Taxation-of-Overseas-Americans-1

John Richardson – Follow me on X.com @ExpatriationLaw