Why Boris Johnson must relinquish US citizenship on the occasion of his appointment as British Foreign Minister

A recent post (July 7, 2016) on this blog began with: Prologue – U.S. citizens are “subjects” to U.S. law wherever they may be in the world … Boris Johnson as PM? US @USSupremeCourt judgment in Blackmer v. US https://t.co/KzMOCqBaL1 means he must obey USA https://t.co/pEWzZRJZFb — Citizenship Lawyer (@ExpatriationLaw) July 7, 2016 Yes, it’s […]

Physical presence as a necessary condition for being a US "resident" under the Internal Revenue Code

Introduction Every country in the world with the exceptions of Eritrea and the United States claim tax jurisdiction based on “residence”. Although the tests for “residence” may differ, “residence based taxation” means that it is possible to sever your tax connection to a country by severing residence. The nations of Eritrea and the United States […]

Tax Haven or Tax Heaven 4: Why bother "poaching capital" as a Tax Haven, if you can steal the capital using citizenship-based taxation?

Involuntary “poaching” of capital – “citizenship-based taxation” U.S. citizenship-based taxation ALSO results in the direct “poaching of capital” from other nations! A thoughtful post describing the cost of U.S. “poaching” to Canada is here. A Paper Detailing FATCA's Costs to Canada https://t.co/0amqvj3li8 – How the US uses #Americansabroad to "poach" "Wealth of Other Nations" — […]

#Americansabroad: Thoughts on the May 2/14 Toronto Conference on CBT vs. RBT – #FATCA #FBAR

#Americansabroad: @JackieBugnion of @ACAVoice comments on May 2/14 Toronto Conference/Debate on CBT vs. RBT https://t.co/SOVEjMwDaV #fatca — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 10, 2014 #Americansabroad: Mary-Louise Serrato of ACA Global discusses May 2 Toronto RBT v. CBT debate http://t.co/ECxjKwb2YM https://t.co/4OeFP0drg3 — Citizenship Lawyer (@ExpatriationLaw) July 10, 2014 ACA Global Foundation […]

Proposal by @JoeBiden to increase the GILTI tax has particularly vicious implications for #Americansabroad

Well look here, Biden proposes to double the #GILTI tax with no apparent exemption for small business. This is a declaration of war on the tax base of other countries (and of course #Americansabroad). https://t.co/uYjLB5ovFg pic.twitter.com/0Ewbc7ydHK — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 25, 2020 Introduction Proposal of @JoeBiden to raise […]

Like FBAR, Form 8938, Form 3520 and Form 5471 – Canada has its own foreign asset reporting rules

Prologue Last week I received a call from one of the many Americans abroad living (not hiding out) in Canada. He did NOT know about his U.S. tax obligations. Therefore, he has not been filing U.S. taxes. Interestingly, he had a portfolio of U.S. stocks (foreign to Canada) which were providing him with a consistent […]

More #Americansabroad will pay capital gains tax on sale of principal residence in Canada

Escalating housing prices in Toronto leave buyers with sticker shock and owners reaping capital gains @globeandmail https://t.co/AALQfnTVqg — Citizenship Lawyer (@ExpatriationLaw) March 22, 2017 The price of Toronto real estate continues its upward trajectory. This morning I met with yet another (who could have known) Canadian resident who wishes to renounce U.S. citizenship. This person is […]

Tales of renouncing citizenship: U.S. Senator Ted Cruz and London Mayor Boris Johnson

Tales of renouncing citizenship: U.S. @SenTedCruz and @MayorOfLondon Boris Johnson http://t.co/VJwqzRl6vA – It's about your "place of birth" — Citizenship Lawyer (@ExpatriationLaw) February 5, 2015 In September of 2014, I conducted a “Problems of U.S. Citizenship Session” in Montreal, Canada. As usual many of the attendees were in the midst of their OMG (“Oh My […]