Elizabeth Warren’s “Ultra-Millionaire Tax Act of 2021”: Coming Soon To A Neighbour (and maybe a nonresident spouse) Near You

The Contextual Background – Elizabeth Warren – January 28, 2021 Senator Elizabeth Warren plans to introduce legislation on Monday that would tax America’s wealthiest people. The proposed wealth tax would apply a 2% tax to individual net worth above $50 million and a 1% surcharge for net worth above $1 billion. https://t.co/fM6REHPM8o — The New […]

The S. 911 Foreign Earned Income Exclusion: It’s origins, journey, opportunities and limitations

This 1981 article on the S. 911 FEIE explains the purpose was to make it less expensive for US corps to hire US citizens. It was NOT motivated by any desire to help #Americansabroad. "THE FOREIGN EARNED INCOME EXCLUSION: REINVENTING THE WHEEL" on JSTOR https://t.co/QBSz1f84NS — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) […]

Treasury exempts applicable “tax-favored foreign trusts” from the Form 3520 (and therefore Form 3520A) requirement

Introduction – A small step for forms, one giant leap for “formkind” It’s true. Many Americans abroad may no longer be required to file Form 3520 and Form 3520A to report their lives abroad! Early indications appear that many Americans will (assuming their retirement vehicle does qualify as a trust) not be required to report […]

IRS Relief Procedures For Former Citizens Update – Relief For Former Green Card Holders Coming!

It's just become a lot easier for many #Americansabroad wishing to commit #citizide, but who are worried about tax compliance issues: "IRS Relief Procedures For Former Citizens Update – Relief For Former Green Card Holders Coming!" https://t.co/Ttu1k9Yply via @expatriationlaw — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 18, 2019 Introduction On December […]

Part 12 in series: The Emotional Toll of US Non-Resident Taxation and Banking Policies – “I Love the US but Feel Betrayed”

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Part 9 of series: How do US Tax Rules Constrain the Investment Choices of US Taxpayers Living in Australia?

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Part 8 of series: Former ACA Tax Director Jackie Bugnion recalls the 2014 Kirsch Schneider debate on "citizenship-based taxation"

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Part 7 of series: Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Part 6 of series: Why this Toronto based International Tax specialist always asks whether there are any U.S. taxpayers in the family

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Part 5 of series: What does U.S. "citizenship-based taxation" actually mean and to whom does it actually apply?

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]