TCJA and Expanding the definition of and number of "Controlled Foreign Corporations" subject to Subpart F

As goes the number of “Controlled Foreign Corporations“, so goes the size of the U.S. tax base. The “messaging” was that the United States was moving to a system of […]

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 […]

Some US Citizens And Green Card Holders Resident In Belgium Are Excluded From Benefits Under The Tax Treaty Available To US Citizen Residents

Prologue Some Green Card holders and #Americansabroad living in Belgium are like Alice in her "Adventures In Wonderland". You see they have @taxresidency in the USA, but when they move […]

Extradition Is One Way That Changes In Another Country’s Tax Laws May Change Your Tax Relationship With The US

Prologue It's not only changes in US law that affect taxpayers but also changes in laws of other countries. Examples: enforcement (treaties), whether tax is owed (Subpart F) and how […]

Buying Their Freedom: Toward A More Efficient Process Of US Citizenship Renunciation

Buying Their Freedom – A More Efficient Renunciation Process – The “Readers Digest” Version Of This Post … Q. Why are people getting rid of their US citizenship? A. It's […]

As Goes The “Fairness Of Taxation”, So Goes Civilization: It’s Time To Consider The “Fair Tax”

Introduction #FairTax policy is good policy. Why @FairTaxOfficial means restoring "freedom and dignity of the individual" (as well as creating a "fairer" tax system). Imagine a world where #Americansabroad were […]

Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

Today’s post, Part II, was written by Virgina La Torre Jeker, J.D. and John Richardson, J.D. Part I of this blog post discussed President Biden’s Green Book proposal that would […]

Biden 2023 Green Book: Six Ways The Proposals Would Affect Americans Abroad

Update April 13, 2022 … Here is yet a seventh way – the treatment of gifts as capital gains – that the Biden Green book would impact Americans Abroad Introduction […]