Search Results for: GILTI

July 5/22: An Opportunity To Educate Resident Americans About The Horrors Of Citizenship Tax

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Updated July 5, 2022 … Great discussion with Bob Paxton and Bob Scarborough: Why #Americansabroad and @USVotersAbroad should be supporting the #FairTax and @FairTaxOfficial. Join @FairTaxAbroad! https://t.co/dvL1GfzynK — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 6, 2022 An Opportunity To Educate Resident Americans About The Horrors Of US Citizenship Tax .@USVotersAbroad: An […]

As Goes The “Fairness Of Taxation”, So Goes Civilization: It’s Time To Consider The “Fair Tax”

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Introduction #FairTax policy is good policy. Why @FairTaxOfficial means restoring "freedom and dignity of the individual" (as well as creating a "fairer" tax system). Imagine a world where #Americansabroad were no longer #GILTI and @citizenshiptax would be meaningless. https://t.co/NgjktVL4wu — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 30, 2022 I was recently […]

Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

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Today’s post, Part II, was written by Virgina La Torre Jeker, J.D. and John Richardson, J.D. Part I of this blog post discussed President Biden’s Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death. To recap, the major thrust of the Green Book […]

Biden 2023 Green Book: Six Ways The Proposals Would Affect Americans Abroad

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Update April 13, 2022 … Here is yet a seventh way – the treatment of gifts as capital gains – that the Biden Green book would impact Americans Abroad Introduction It’s The System Not The Parties! As long as the United States employs @citizenshiptax and #FATCA, changes in US tax laws will continue to have […]

The Road To Tax Reform For Americans Abroad: Part 2 – Citizenship Taxation And The Seven Deadly Sins

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Introduction Life is full of rude awakenings. More and more people are experiencing their OMG moment … The Twin Horrors Of FATCA And Taxation Based Citizenship as described by @Amy_From_Sydney https://t.co/SHxNUp37WR via @YouTube — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 20, 2022 This is Part 2 of the series. In Part […]

The Road To Tax Reform For Americans Abroad: Part 1 – The Problem Is The System And Not The Party

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Introduction – The First Of A Series Of Short Posts My name is John Richardson. I am a Toronto, Canada based lawyer. I am also a founding member of “SEAT” (“Stop Extraterritorial American Taxation”). I am an advocate for reforming the US laws which apply to US citizens who live outside the United States as […]

The Beyer “Tax Simplification For Americans Abroad Act”: A First Look

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Updates November 22, 2021: 1. I have also written a post on the SEAT site which compares (in a general way) the Beyer Bill of 2021 to the Holding Bill of (2018). Any attempt to solve this problem through amending the FEIE actually has the effect of strengthening citizenship based taxation. 2. With respect to […]

Eroding the tax base of other countries by imposing direct US taxation on the residents of those countries

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When I hear people say that the IRC 911 FEIE and/or the IRC 901 FTC rules mean that #Americansabroad don't pay taxes to the US, I am reminded of John F. Kennedy's 1962 Commencement speech at Yale where he said: https://t.co/N6sOOPL4vO — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) October 8, 2021 This […]

Treasury 26 CFR § 301.7701-2 – Business entity definitions discriminate against Canadian Controlled Private Corporations

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Synopsis: The power to regulate is the power to destroy! That's why the regulatory process should require careful consideration of how and to whom regs apply. It's time for Treasury to consider "A Simple Regulatory Fix for Citizenship Taxation" https://t.co/6dUqXjtUNo via @SEATNow_org — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 27, 2021 […]

Toward An Explanation For Why Some Americans Abroad Are Complacent About Citizenship Taxation

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US @CitizenshipTax AKA #Extraterritorialtax is greater than the self-interest of any one person. It affects you in ways that may not be obvious now. It affects your neighbours. It affects the sovereignty of your country of residence. It affects the future value of US citizenship — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) […]