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 […]

Article 4 paragraph 2 of the U.S. U.K. Tax Treaty: A clause preventing the use of the tax treaty tie breaker for some Green Card holders

Introduction – In The 21st Century The Most Important Thing About A Person Is His Tax Residency Interestingly the U.S. UK tax treaty appears to have created a "saving clause" […]

Considering the EB-5 Visa? The IRC S. 877A Expatriation Tax Demonstrates that "Not All US @TaxResidency Is The Same!"

Considering the EB-5 Visa? The U.S. S. 877A Expatriation Tax Demonstrates that “Not All @TaxResidency Is The Same!” https://t.co/QJnuiKmpQf — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 20, […]

Canada U.S. Tax Treaty – Article XXVIA: How the 5th Protocol Enhances protection for Canadian citizens

Canada U.S. Tax Treaty – Article XXVIA: How the 5th Protocol Enhances protection for Canadian citizens https://t.co/DMdIlHqMU7 — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 6, 2018 Introduction […]

On what date does an individual (other than a U.S. citizen) begin or end @USTaxResidency

This is an interesting and important question. This question is always important for determining how the Sec. 877A “Exit Tax” applies to “permanent residents” AKA “Green Card Holders” who with […]

Determining Tax Residency In the United States: Citizenship and other forms of deemed tax residence

Introduction The search for second passports and #offshore havens https://t.co/mFWja1CR87 via @FT – how the #CRS and #FATCA have created @TaxHavenUSA — John Richardson – lawyer for "U.S. persons" abroad […]

The Internal Revenue Code does NOT explicitly define "citizen", "citizenship" or require "citizenship-based taxation"

On the question of: What is a citizen?" https://t.co/ixtT45z3MB – suggests membership, rights, obligations, etc. — Citizenship Lawyer (@ExpatriationLaw) July 4, 2016   It is widely understood that the United […]

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 […]

Part 10: What God Hath Wrought – The #FATCA Inquisition (Review, Identify and Report on “U.S. Persons”) – But only those "Born In The USA"

The purpose of this post is to highlight: who are the targets of the “FATCA inquisition” under the FATCA IGA; and who will not turn up in the “FATCA inquisition” […]