Part 14 – Calculating the Transition Tax: The 962 Election – getting credit for the tax the corporation has paid

The first thirteen posts in my “transition tax” series were: Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but “Compliance is impossible” Part 2: Responding to The Section 965 “transition tax”: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax” Part 3: Responding […]

Part 11: Responding to the Sec. 965 “transition tax”: Letter to the Senate Finance discussing the effects of the transition tax on Americans abroad

Full @SenateFinance HearingEarly Impressions of the New Tax LawDate: Tuesday, April 24, 2018 Time: 02:30 PM Location: 215 Dirksen Senate Office Building – My letter about @USTransitionTax @OrrinHatch on behalf of #Americansabroad — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 5, 2018 This is the eleventh in my series […]

Republicans Overseas asks for hearings on how the @USTransitiontax unfairly impacts Americans abroad

Congratulations to @SolomonYue and Republicans Overseas" for thisceffort on behalf of #Americansabroad "RO requests a House Hearing on the harmful impact of the @USTransitionTax" — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 26, 2018 I have previously written about the confiscatory effect of the “transition tax” on small business owners living […]

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 Internal Revenue Code vs. IRS Form 8854: the "noncovered expatriate" and the Form 8854 Balance Sheet

Introduction: For whom the “Form” tolls … I would not want the job that the IRS has. There are many “information reporting requirements” in the Internal Revenue Code. The IRS has the job (sometimes mandatory “shall” and sometimes permissive “may”) of having to create forms that reflect the intent of the Internal Revenue Code. The […]

PFIC taxation and Americans abroad

This post was originally written in February of 2014. It has been updated September 11, 2020 First, giving credit where credit is due … A superb “Readers Digest” summary of how the PFIC rules are understood to apply to individuals was prepared by PWC in 2017. You will find the report here and here: pwc-united-states-pfic-guidance-provides-new-reporting-exceptions […]

Some US tax issues of particular concern to US persons abroad

What you need to know about @TaxationAbroad, but didn't even imagine could exist: – #FBAR #FATCA #PFIC Pensions … — US Taxation Abroad (@TaxationAbroad) November 14, 2015   This page is to identify ways in which U.S. tax laws may affect the taxation and very lives of Americans abroad. The issue is identified along […]

What you should consider before contacting a lawyer

Just hearing about #FATCA #FBAR #PFIC and U.S. "place of birth" taxation? Don't panic. Information sessions available — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 11, 2014 The Reality of U.S. Citizenship Abroad Nobody denied that the unintended targets of Congressional legislation aimed at those who supposedly “owe allegiance” to the […]

@AmChamCanada Presents: November 18/21: Work From Anywhere

Thursday November 18, 2021 – “Work From Anywhere” – registration link: Join the @AmChamCanada "Work Form Anywhere" Webinar – 12:00 noon to 1:00 pm Full details and registration link — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 11, 2021 November Work From Anywhere Webinar Flyer Further details: On Thursday, November […]

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

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: — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) October 8, 2021 This […]