The proper care and feeding of the Green Card – An interview with "long term resident" Gary @Clueit

Introduction The Internal Revenue Code of the United States imposes worldwide income taxation on ALL individuals who are U.S. citizens or who are otherwise defined as “residents” under the Internal Revenue Code. “Residents” includes those who have a visa for “permanent residence” (commonly referred to as a Green Card). A visa for “permanent residence” is […]

"Non-citizenship" has its privileges: An overlooked reason why a Green Card holder may NOT want to become a U.S. citizen

“Non-citizenship” has its privileges: An overlooked reason why a Green Card holder may NOT want to become a U.S. citizen https://t.co/yzxRjFikhp — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 30, 2018 U.S. Tax Residency – The “Readers Digest” Version Last week I participated in a “panel discussion” titled: “Tax Residency In A World […]

The Green Card and the "Oh My God" Moment: You know you want to leave the USA? Not so fast!

One more day! One more #GreenCard holder chased out of America – Can't understand what is required of him https://t.co/tp09EMhTHP pic.twitter.com/IukTr1Mfo3 — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) August 25, 2017 Well he won the lottery. Specifically he won the “Green Card” lottery. He and his wife came all the way from […]

Green card holders: the "tax treaty tiebreaker" and eligibility for Streamlined Offshore

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

Green card holders, the "tax treaty tiebreaker" and reporting: Forms 8938, 8621 and 5471

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

Green card holders: the "tax treaty tiebreaker" rules and taxation of Subpart F and PFIC income

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

The US "expatriation tax" and the the incentive to apply for a Green Card and/or remain in the USA

America doesn’t really need skilled immigrants, or does it? Staple a "Green Card" to every PhD – Don't fall for this! Don't immigrate to the U.S. https://t.co/hHefrflU2v via @USCitizenAbroad — Citizenship Lawyer (@ExpatriationLaw) September 24, 2016 The above tweet references a post that references a comment by Victoria Ferauge:

Is Form 8938 required by "Green Card Holders" who are nonresidents by "treaty tie breaker"? – Any exemption is the result of "IRS grace"

Summary: @Vljeker interview with Bill Yates about the creation of IRS Form 8938 https://t.co/TLhSkdrYoq — Citizenship Lawyer (@ExpatriationLaw) September 23, 2016 The context: Form 8938 was created by the IRS to meet the reporting requirements mandated by Internal Revenue Code S. 6038D. S. 6038D was mandated by S. 511 of the HIRE Act. On March […]

Welcome to Citizenship Solutions (and Green Card solutions) – John Richardson

Welcome to Citizenship Solutions – The blog of John Richardson The Burden of Citizenship Based Taxation https://t.co/mMI1nWmm3P #FATCA #FBAR #Expat #TaxReform @ExpatriationLaw @taxreformer pic.twitter.com/vDRaA3KzbZ — A. S. Alexander (@asalexanderdesk) September 19, 2016 I am guessing (actually I know for sure) that you arrived here because of some aspect of being a U.S. citizen living outside […]

Green Card Holders and #Americansabroad: "Residence", "Long Term Residence" and the S. 877A "Exit Tax"

Tax jurisdiction and residential ties The two types of residential ties considered for all aliens When considering the meaning of “residence” for tax purposes, attempting to ascribe a place of “residence “to an individual, and imposing taxation on individuals, the Internal Revenue Code considers: A. The extent of “residential ties” to the United States; and […]