So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer

Prologue: In the 21st Century, The Most Interesting Thing About A Person Is His/Her Tax Residency Welcoming the world's most famous @USCitizenAbroad: "Little Archie's big tax problem" – — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 28, 2019 Introduction – So, what’s this “tax residence” stuff about? What does “tax […]

"Tax residence" for US Estate and Gift and "tax treaty tiebreakers with overlapping domicile

Introduction – Two kinds of tax systems – Two kinds of “tax residency” Title 26, the Internal Revenue Code of the United States is composed of twelve subtitles. Subtitle A deals with “Income Taxes”. Subtitle B deals with “Estate and Gift Taxes” AKA the “transfer tax regime”. The two subtitles are administered separately. They also […]

Part 2: OECD Common Reporting Standard ("CRS"): "tax residence" and the "tax treaty tiebreaker"

Part 1: Tax Treaties, determining "tax residence" and new OECD Common Reporting Standard ("CRS… via @ExpatriationLaw — Citizenship Lawyer (@ExpatriationLaw) May 21, 2017 This is Part 2 – a continuation of the post about “tax residency under the Common Reporting Standard“. That post ended with: Breaking “tax residency” to Canada can be difficult and […]

Determining Tax Residency In the United States: Citizenship and other forms of deemed tax residence

Introduction The search for second passports and #offshore havens via @FT – how the #CRS and #FATCA have created @TaxHavenUSA — Citizenship Lawyer (@ExpatriationLaw) May 20, 2017 The advent of the OECD Common Reporting Standard (“CRS”) has illuminated the issue of “tax residency” and the desire of people to become “tax residents of  more […]

Part 1: Tax Treaties, determining "tax residence" and new OECD Common Reporting Standard ("CRS")

Canada: Common Reporting Standard legislative proposals here – Report "tax residents" of "reportable jurisdiction" — Citizenship Lawyer (@ExpatriationLaw) August 23, 2016   The above tweet references an article from Stikeman Elliot which includes: For CRS purposes, the term “reportable person” generally refers to a natural person or entity that is resident in a reportable jurisdiction (excluding […]

Jackie Bugnion 2017 Residence Based Taxation: To Chairman Hatch's request for tax reform proposals

Introduction: It’s tax reform season and Senator Orrin Hatch wants to hear from you (again) As reported on the Isaac Brock Society and other digital resources for those impacted by U.S. taxes, you have until July 17, 2017 to tell Senator Hatch what you think needs to be changed in the Internal Revenue Code. After […]

More #Americansabroad will pay capital gains tax on sale of principal residence in Canada

Escalating housing prices in Toronto leave buyers with sticker shock and owners reaping capital gains @globeandmail — Citizenship Lawyer (@ExpatriationLaw) March 22, 2017 The price of Toronto real estate continues its upward trajectory. This morning I met with yet another (who could have known) Canadian resident who wishes to renounce U.S. citizenship. This person is […]

Green Card Holders and #Americansabroad: "Residence", "Long Term Residence" and the S. 877A "Exit Tax"

Tax jurisdiction and residential ties The two types of residential ties considered for all aliens When considering the meaning of “residence” for tax purposes, attempting to ascribe a place of “residence “to an individual, and imposing taxation on individuals, the Internal Revenue Code considers: A. The extent of “residential ties” to the United States; and […]

Part 8 – “The U.S. “Exit Tax vs. Canada’s Departure Tax – citizenship taxation vs. residence taxation”

Cdn Departure Tax has a logic to it. To have to pay a US "exit tax" when I left > 30 years ago, beggars belief. — Citizenship Lawyer (@ExpatriationLaw) April 8, 2015 The above tweet references the following comment: At least the departure tax has a sliver of logic to it, and an appropriate […]

Part 2 – Understanding "Exit Taxes" in a system of residence based taxation vs. Exit Taxes in a system of "citizenship (place of birth) taxation

This is Part 2 of a 9 part series on the Exit Tax. The 9 parts are: Part 1 – April 1, 2015 – “Facts are stubborn things” – The results of the “Exit Tax” Part 2 – April 2, 2015 – “How could this possibly happen? Understanding “Exit Taxes” in a system of residence […]