On August 5, 2016 the United States Court of Appeals for the District of Columbia Circuits issued it’s decision in the Eshel case. This important case is here: FRENCH TAXES US COURT REVERSAL 5 AUG 2016 (1)
Information about the history of the case is here which includes:
A D.C. Circuit panel grilled the Department of Justice’s Tax Division on Tuesday for arguing a foreign tax dispute with dual U.S. and French citizens without first seeking input from the U.S. government, saying the case requires the court to interpret international treaties and examine other policy issues.
Are you “Coming To America” by entering the U.S. tax system as an American Abroad? The “How To Come Into U.S. Tax Compliance” book for Americans abroad John Richardson, LL.B, J.D.
“Coming Into Tax Compliance Book” – How Americans can come into U.S. tax compliance in a FATCA world https://t.co/NIB8L4Zlr1 | Should be required reading for stateside voters & everybody abroad w US connection. But many born abroad wl likely never get FATCA letter, never surface.
“deemed to be permanently resident in the United States for tax compliance and financial reporting purposes” …
“subject to the most complex aspects of the U.S. tax code regardless of any activity in the United States, and facing extraordinary compliance costs and disclosure risks even for nil returns”
Although Americans abroad are deemed to be resident in the United States, their assets are treated as “offshore”. In addition Americans abroad are subject to taxation in their country of residence. All of this means that:
1. Americans abroad are subject to the worst and most punitive aspects of the U.S. tax system (there is no Homelander who is treated as badly as an American abroad); and
2. Denied most benefits of the tax systems of their country of residence.
To put it simply, Americans abroad get the worst of all possible tax systems.
The most horrific aspects of the U.S. tax system are saved for Americans abroad. Prepare to be shocked. As one commenter at the Isaac Brock Society site recently said:
"So I totally agree with all of you who decided to renounce. I would have probably done the same in your situation." http://t.co/GO7fzZYknK
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 1, 2015