Tag Archives: Republicans overseas

Seeking Testimonials From Americans Abroad Who Have Been Subjected To Double Taxation

To U.S. Citizens Residing Outside The United States

Re: Continuing Efforts Of Republicans Overseas To End The Double Taxation Of Americans Abroad

Republicans Overseas continues to (1) recognize President Trump’s commitment to end the double taxation of Americans abroad and (2) remains committed to the goal of ending this double taxation. The goal cannot be achieved without the support and committment of the community of individual U.S. citizens living outside the United States.

Achieving changes of this magnitude is “NOT A Spectator Sport!”

Here is how the assistance of individual Americans abroad (wherever you may be) is required:

On behalf of Republicans Overseas, Republicans Overseas Tax Committee and Solomon Yue, I am reaching out to the community of U.S. citizens abroad seeking:

– written testimonials explaining how the U.S. tax code has resulted in double (and damaging) taxation in a manner that would NOT be experienced by U.S. residents

– examples could include: transition tax, GILTI, U.S. taxation of tax deferred retirement planning accounts, your pensions being unjustly taxed as foreign trusts, problems of using non-U.S. mutual funds for investing, PFIC, etc. We need specific testimonials describing exactly how the U.S. tax code imposed on Americans abroad leads to this result.

– penalties that have been unjustly levied on the failure to report (or late reporting) of the normal instruments of financial/retirement planning in your country of residence (Penalties imposed on TFSA, ISA, small business corps, etc.)

– taxation on phantom capital gains on the sale or refinancing of your home outside the United States

– having to pay the 3.8% Obamacare surtax on non-U.S. investment income while not being permitted to offset the foreign tax payable by using foreign tax credits

– being denied access to normal banking and brokerage accounts in your country of residence because of FATCA

– having your career opportunities limited because of a reluctance to hire, partner with, or invest with “U.S. persons”

– former U.S. citizens who feel they were forced to renounce U.S. citizenship because they could not afford the enormous compliance costs associated with U.S. citizenship or because the U.S. tax code limited their career opportunities

– other?

In other words, we want to document the actual damage!! I will assist you in drafting your testimonial so that it accurately explains HOW the U.S. tax code has resulted in double taxation.

Republicans Overseas is continuing its years long mission to end the unjust double taxation of Americans abroad. President Trump has committed to ending the unjust double taxation of Americans abroad. It is expected that there will be a second legislative opportunity in the fall of 2025.

Actual testimonials focusing on double taxation are critical. The testimonials are required by mid September 2025.

Please contact John Richardson if you are able to assist:

citizenshipsolutions@protonmail.com

2025 @ExpatriationLaw – X.com Spaces: Understanding Tax Reform For #Americansabroad

Introduction

“It Takes A Village!”

As everybody (who even the slightest interest) knows there is:

1. A need to end the application of the U.S. citizenship tax regime to Americans abroad

2. An awareness of the issue – created primarily by President Elect Trump’s announcement to end the “double taxation” of Americans abroad (Shout out to the Republicans Overseas Tax Committee for their work over the years)

3. Tremendous work by various “groups” over MANY years including (without limitation) including ACA, AARO, SEAT, Dems Abroad Tax, Rep Overseas Tax, Association Of Accidental Americans and Tax Fairness For Americans abroad (resulting in the Lahood Bill)

4. Great commentary from individuals in the Social Media space

5. Support from blogs and Facebook groups, including without limitation: The Isaac Brock Society, Keith Redmond’s American Expatriates Facebook Group, Karen Alpert’s Fix The Tax Treaty Group and Anthony Parent’s IRS Medic Youtube channel.

6. Lawsuits including the ADCS-ADSC FATCA Canada lawsuit and the Republicans Overseas FATCA Legal Action Lawsuit.

7. The Republicans Overseas initiative which organized the 2017 Meadows FATCA hearing.

8. The 2018 Holding Bill which was the first bill introduced to relieve the plight of Americans overseas.

9. Congressman Beyer’s 2017 Tax Simplification For Americans Abroad Act.

10. Superhuman efforts from a number of individuals either in their personal capacity or representing their groups. Particular mention should go to those who have specifically associated their names with the need for change. These include (but are certainly not limited to: Solomon Yue, James Gosart, Laura Snyder, Rebecca Lammers and many others (you can leave comments adding more …) These people have been working while you were sleeping. They have always been working when you were awake. They invested incredible amounts of time and energy in solving this problem.

Bottom line: This is where we are. Congress will be thinking about tax reform in 2025.

President Elect Trump has made the pledge that it’s time to end the “double taxation” of Americans abroad.

This is the single most important pledge and acknowledgement of this problem. A statement from the President is the single most important acknowledgement. (See the video referenced in the following tweet.)

We still need to understand the scope of this pledge. What does it mean? How far does it go?

To put it simply, it’s time for ALL Americans abroad to “Seize The Day”!

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I have started a series of discussion on X.com “Spaces” to interact with interested people and to explore these issues. I have no idea how many I will do. I have no idea how long they will last. But, I thought it would be good to have a post the lists the discussions (previous and upcoming). So, that is the purpose of this post. You can bookmark this page and check back. Feel free to contact me X.com/ExpatriationLaw with comments or suggestions.

All of the “X Spaces” are summarized on Substack at:

https://expatriationlaw.substack.com

All of the “X Spaces” are summarized on Spotify at:

https://open.spotify.com/show/6LEpZEhGrK4Ap4qlU9Frlr

All of the “X Paces” are summarized on Apple podcasts at:
https://podcastsconnect.apple.com/my-podcasts/show/expatriationlaw-x-spaces-lives-discussions-ending-double-taxation-of-americans-abroad/d46b4dd0-8695-46de-a259-fc204f152781/episodes

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Double Taxation Of Americans Abroad Is Because Of Citizenship Based Double Tax Residency

What Is Meant By The Double Taxation Of Americans Abroad?

On February 12, 2025 I hosted an “X Spaces“. The intended purpose was to discuss Professor Avi-Yonah’s new paper “Should The United States Abandon Citizenship-based Taxation”? The paper is clearly in support of the continuation of U.S. citizenship taxation. The paper is here:

ssrn-5130868

You can listen to the discussion here:

At the end of the discussion we focused on the question of:

Q. What is meant by ending double taxation?

I suggested that the answer is:

A. Double taxation is the result of double tax residency. For U.S. citizens “double tax residency” is caused by U.S. citizenship taxation. It is ended by severing citizenship from tax residency.

Two previous discussions about ending Citizenship-based “double taxation”

I have included the “slides” that were prepared for each of these presentations. They (in my opinion) do a good job in explaining what citizenship taxation really is and what is required to end it.

Enjoy (or not).

July 10, 2024 – What is REAL(ly) Residency Taxation?

Here are the slides for the presentation:

RBT 2

July 12, 2024 – Republicans Overseas Tax Proposal

Here are the slides for the presentation:

Severing citizenship from tax residency 3

In conclusion …

I believe that these two presentaions (along with the slides) will assist in understanding:

1. What the double taxation of Americans abroad actually is; and

2. How the double taxation of Americans abroad can (and must) be ended.

John Richardson – Follow me X.com @ExpatriationLaw

Separating Citizenship From Tax Residency: The Republicans Overseas Tax Proposal

In 2024 the Republicans Overseas Tax Committee created the following proposal for separating U.S. citizenship from U.S. tax residency. The proposal is three parts which are:

1. A Legislative Fix – changing who is a tax resident from “individual” to “resident”.

2. A Regulatory Fix – changing the regulation to define “individual”in the Internal Revenue Code to mean “resident”

3. A Treaty Fix – narrowing the range of the treaty “saving clause” so that U.S. citizens who are tax residents of other countries can use the “treaty tie break” provision to be treated as nonresidents.

Ending the Unjust Taxation of Overseas Americans

A September 2024 twitter discussion of the proposal is here along with a link to a series of videos made by John Richardson and James Gosart:

John Richardson – Follow me on X.com @ExpatriationLaw

Town Halls: Tuesday Sept. 17/24 – @RepOverseasTax Introduces Its Tax Proposal For Americans Abroad And Invites Discussion

Update September 23, 2024:

Here is a link to the “Town Hall Discussion”

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There are two sessions coming up – both on X.com

Tuesday September 17:

North America – Note this 8 p.m. EDT

Rest Of World – Note this is 2 pm EDT

Feel free to attend either or both. Looking forward to discussion!

If you can’t make the town halls, here is a series of short videos created by John Richardson, Jim Gosart and Jonathan Constantine which explain why the cancerous tumor of citizenship taxation needs to be removed!!

Finally, here is the Republicans Overseas tax reform proposal for U.S. citizens living outside the United States.

Ending-the-Unjust-Taxation-of-Overseas-Americans-1

John Richardson – Follow me on X.com @ExpatriationLaw

The Five “Americans Abroad” Obama Would Meet In Heaven – How Taxation “Slices and Dices” Americans Abroad

Reminder:

US citizenship abroad information/discussion sessions in January of 2024:

1. London, UK – Wednesday January 17, 2024 – 18:00 – Location: The Sutton Arms – first floor wine room – 6 Carthusian Street, London – EC1M 6EB

2. Prague, Czech Republic – Sunday January 21, 2024 – Brix bar & Hostel, Rohacova 132/15, Prague 3 Žižkov
– 200CZK – includes lunch

3. The Prague session will be livestreamed on the IRSMedic Youtube Channel. Check there for how to join.

Further details here.

Outline, table of contents and purpose of this post.

Because U.S. citizenship taxation impacts different groups in different ways, it is hard to garner a significant mass of people to committed to the mission of ending citizenship taxation. There are five different groups who are impacted by citizenship taxation. Yet they would seem very different if you were to meet them in heaven.

Part A – “The Five People You Meet In Heaven” – the notion of interconnectedness
Part B – Barack Obama and the revival of citizenship taxation – how did his administration “slice and dice” Americans abroad?
Part C – Different kinds of Americans abroad with different attitudes toward the taxation of Americans abroad
Part D – Fault Lines Among Americans Abroad – The discussion in Keith Redmond’s American Expatriates Facebook group
Part E – The Five Types Of Americans Abroad Obama Would Meet In Heaven
Part F – Conclusion

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Republicans Overseas Begins Its Support and Advocacy for Pure Residence-based Tax

This is an incredibly significant development. See the following posts on their Facebook site. They also have a new Twitter feed. Follow them at @RepOverseas.

Republicans Overseas position On What Pure Residence-based taxation means:

Tax Talk 1 – November 22, 2021

Tax Talk 2 – November 29, 2021

Tax Talk 3 – December 10, 2021

Tax Talk 4 – December 15, 2021

Tax Talk 5 – December 20, 2021

Tax Talk 6 – December 27 2021

Tax Talk 7 – January 3, 2022

Tax Talk 8 – January 21, 2022

Tax Talk – January 24, 2022

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

I have previously written about the confiscatory effect of the “transition tax” on small business owners living outside the United States here and here. This is a “tax” – based on the Subpart F regime – on certain shareholders of “controlled foreign corporations“. For Canadians this “tax” represents a U.S. partial confiscation of their pensions. Interestingly the recent “Tax Cuts and Jobs Act” has significantly increased both the number of “United States Shareholders” and the number of “Controlled foreign corporations”.
All of this is taking place in the context of more countries enacting CFC (“Controlled Foreign Corporation”) rules. For example, Russia recently enacted its own “Controlled foreign corporation rules. In general the worldwide climate toward corporations is becoming more and more hostile.
The advocacy of Republicans Overseas is a welcome development. It is hoped that the leadership of Republicans Overseas will encourage other groups that claim to represent non-U.S. residents to join the fight against “non-resident taxation”.
Their official announcement is here and a copy of their submission is here.
To read a copy of their submission …
RO-Transition-Tax-Overview
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