Oliver Wagner, CPA and John Richardson – January 16, 2022
Americans abroad and the presumption of double taxation
Prologue: For whom the bell tolls …
Whether a US citizen lives in (and is a tax resident of) Mexico and works on a ship in international waters
International waters are not a foreign country. https://t.co/hnhfCddLb1
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 15, 2022
Or Whether A US citizen lives in (and is a tax resident of) Holland and is an airline pilot …
OMG imagine if @Ronald77171496 had known that he was a US citizen while he was flying planes across the Atlantic! Read this article which describes the nightmare imposed on "US citizen" airline pilots who have @taxresidency in other countries. (Applies to cruise ship people too!) https://t.co/gW8G30W9Vq
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 17, 2022
That US citizen, because and only because of the combination of US citizenship-based taxation coupled with living outside the United States, is likely to be subject to double taxation. The following discussion explains why.
A Summary Podcast …
New podcast: "Attention! Our Trip Is Entering International Waters: For #AmericansAbroad, Let The Double Taxation Begin!" https://t.co/Dz7s0uEDPO
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 21, 2022
Part A: Introduction – About Citizenship-based Taxation
Part B: How the Internal Revenue Code is designed to mitigate the effects of double taxation in certain circumstances
Part C: Determining what is “foreign source” income
Part D: The problem of international waters …
Part E: The effect of sourcing to the US income earned in international waters by dual tax residents
Part F: Deducting “foreign taxes” paid – although income from international waters may not be foreign, it is still subject to the payment of “foreign taxes”
Part G: Can a US citizen living abroad be saved by a tax treaty? Maybe if he/she lives in Canada****
Part H: Conclusion and the need for “Pure Residence-Based Taxation”