Monthly Archives: January 2022

Americans Abroad And Financial Planning In A FATCA And FBAR World – LJ Eiben

The Importance Of Financial And Retirement Planning – It’s Not Easy For Americans Abroad

Americans abroad are severely disabled by the US tax and regulatory regime. As a result they need to plan more carefully and they have fewer options that those who are not US citizens.

I reached out to LJ Eiben of Raymond James to discuss various aspects of the “US Citizenship Dilemma”. Both US Social Security and Canada Pension Plan are part of the equation. I first spoke with LJ in November of 2021 about US Social Security.

Here are three podcasts …

November 11, 2021 – US Social Security For Canadian Residents

January 26, 2022 – Canada Pension Plan And Old Age Security For Canadian Residents

February 4, 2022 – Raymond James: A Permanent Investing Solution For People With Lives And Investments In Both Canada And The US

2022 Financial Planning Facts For Tax Residents Of Canada

Have a look at the following …

2022 Financial Planning Facts ENG

Finally …

Required Disclaimer: The information contained in these slides was obtained from sources RJA and believed to be reliable; however, we cannot represent that it is accurate or complete. It is provided as a general source of information and should not be considered personal investment advice or solicitation to buy or sell securities. The views expressed are not necessarily those of Raymond James (USA) Ltd. Raymond James (USA) Ltd. (RJLU) advisors may only conduct business with residents of the states and/or jurisdictions for which they are properly registered.

Raymond James (USA) Ltd. is a member of FINRA / SIPC

John Richardson – Follow me on Twitter @Expatriationlaw

Airline and cruise ship employees: how income earned in international waters may lead to double taxation for (only) Americans abroad

Oliver Wagner, CPA and John Richardson – January 16, 2022

Americans abroad and the presumption of double taxation

Prologue: For whom the bell tolls …

Whether a US citizen lives in (and is a tax resident of) Mexico and works on a ship in international waters

Or Whether A US citizen lives in (and is a tax resident of) Holland and is an airline pilot …

That US citizen, because and only because of the combination of US citizenship-based taxation coupled with living outside the United States, is likely to be subject to double taxation. The following discussion explains why.

A Summary Podcast …

Part A: Introduction – About Citizenship-based Taxation
Part B: How the Internal Revenue Code is designed to mitigate the effects of double taxation in certain circumstances
Part C: Determining what is “foreign source” income
Part D: The problem of international waters …
Part E: The effect of sourcing to the US income earned in international waters by dual tax residents
Part F: Deducting “foreign taxes” paid – although income from international waters may not be foreign, it is still subject to the payment of “foreign taxes”
Part G: Can a US citizen living abroad be saved by a tax treaty? Maybe if he/she lives in Canada****
Part H: Conclusion and the need for “Pure Residence-Based Taxation”

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Considering renouncing US citizenship? Interesting discussion with Buffalo lawyer @JoeGrasmick

In 2018 I had a discussion with Buffalo Immigration Lawyer Joe Grasmick about a number of issues including renouncing US citizenship. The discussion was videoed as part of my “Retain Or Renounce” series. It was a very interesting and balanced discussion. (We also discussed some of the dos and don’ts of Green Card abandonment.)

I wanted to share Joe’s LinkedIn post today (December 31, 2021). His post reinforces the reality that (although Americans abroad are clearly suffering from the tax and regulatory regime) US citizenship does have value.

I completely agree with Joe that the consequences of renouncing US citizenship (notwithstanding the problems) should be fully understood and appreciated.

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