Between March and May of 2023 I had three discussion/podcasts with “Vance” of MyLatinLife.com.
I have put them all in one post. They will be of interest to “Digital Nomads” and “Remote Workers” generally.
All 3 episodes from John Richardson (@ExpatriationLaw) & My Latin Life 🌴
1) https://t.co/NxVOnvfk79
2) https://t.co/swPgdvuwiH
3) https://t.co/fkiSyvYPg5— My Latin Life 🌴 (@MyLatinLife) July 6, 2023
Interview 1:
Interview 2:
Interview 3:
John Richardson – Follow me on Twitter @Expatriationlaw
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
International waters are not a foreign country. https://t.co/hnhfCddLb1
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 15, 2022
Or Whether A US citizen lives in (and is a tax resident of) Holland and is an airline pilot …
OMG imagine if @Ronald77171496 had known that he was a US citizen while he was flying planes across the Atlantic! Read this article which describes the nightmare imposed on "US citizen" airline pilots who have @taxresidency in other countries. (Applies to cruise ship people too!) https://t.co/gW8G30W9Vq
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 17, 2022
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 …
New podcast: "Attention! Our Trip Is Entering International Waters: For #AmericansAbroad, Let The Double Taxation Begin!" https://t.co/Dz7s0uEDPO
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 21, 2022
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”
Thursday November 18, 2021 – “Work From Anywhere” – registration link:
Join the @AmChamCanada "Work Form Anywhere" Webinar – 12:00 noon to 1:00 pm Full details and registration link https://t.co/96LOkbv5XF pic.twitter.com/mQcdCCfzzF
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 11, 2021
November Work From Anywhere Webinar Flyer
Further details:
On Thursday, November 18 from Noon-1:00PM, AmCham will be holding a webinar titled Work from Anywhere: Tax and Legal Considerations for Employers and Employees. This webinar, which was originally scheduled earlier this year and which follows from the successful webinar AmCham held addressing corporate tax issues, will analyze tax and legal matters that arise from the pandemic induced trend to have employees work from anywhere in the world.
This webinar will discuss pertinent topics in this area such as:
1. What are the recent trends regarding work from home arrangements in Canada and throughout the world?
2. What are some of the emerging issues associated with remote working arrangements? and
3. What are some of the practical steps businesses and executives may take to manage these risks?
The panel for this webinar features four knowledge leaders in the field of law and taxation.
They are:
* Michael Pereira, Partner, KPMG – Michael focuses on providing consulting and compliance services to high-net-worth individuals and senior executives with complex U.S. and Canadian tax issues. Michael specializes in intricate tax matters such as: 1) U.S. estate tax issues affecting U.S. citizens living in Canada and their U.S. citizen and/or U.S. resident children; 2) tax issues regarding foreign private equity structures, and 3) U.S. anti-deferral tax system for interests in foreign corporations, including the passive foreign investment corporation and controlled foreign corporation regimes. Michael is a Chartered Accountant and a Certified Public Accountant who earned a Masters of Science in U.S. Taxation from Wayne State University.
* Laura Tippett, Partner (Leader of Program Services – Regions East), KPMG – Laura has 15 years’ experience in Canadian and US personal tax and expatriate issues. Laura assists companies and their employees who are travelling cross-border, working with a variety of industries, including technology, defense, construction, consulting, energy, crown corporations and non-profit organizations. She works with employees who are on foreign assignment, travelling internationally on business, working remotely cross-border or relocating abroad. Laura has managed the Canadian/US expatriate programs for numerous multinational organizations, including overseeing several programs that have hundreds of Canadian-touching assignees annually.
* Kaley Dodds, Senior Manager, Employment & Labour Law, KPMG – Kaley’s is a management-side employment lawyer who represents private, public and institutional clients in a wide range of matters. Her practice covers employment, labour and human rights issues, ranging from litigation strategy, legal risk management, policy development, workplace training, to day-to-day employee relations and human resources advice. Kaley is called to the bar in Ontario and Alberta and has appeared before all levels of courts, arbitrators and human rights tribunals in both provinces.
* Ellen S. Kief, Principal and Managing Attorney at Kief Law – Ellen works with clients across Canada, the United States, and throughout the world addressing issues associated with U.S. immigration law. Ellen’s practice focuses on cross-border travel, business visas, investor visas, entertainment and sports, family visas, permanent residence and citizenship. Ellen is a national speaker and educator who has presented on numerous U.S. immigration topics including cross-border business travel, family immigration, inter-company transfers, and various types of immigrant and non-immigrant visas.
If you would like more information about this event, please see the flyer attached to this message. The flyer contains a link at the bottom where you may register to attend the event.
We hope you will be able to join us on November 18 for what should be a stimulating event. Thank you for your support of AmCham and its mission. Have a good day.
Registration link:
On June 3, 2020 I plan to do a podcast with Anthony Scaramucci of Skybridge Capital and SALT Conference fame. The June 3 podcast has its roots in the following @Scaramucci tweet which was the subject of discussion at the Isaac Brock Society.
Win Win for U.S./Many of the NINE million Expats who may start voting would forgo the relief checks (spent overseas)/They want Residency Based Tax as per Rep. Platform (Promise kept)/Most do not pay tax BUT pay expensive fees to file/Save $$ on checks/Google it
— Anthony Scaramucci (@Scaramucci) April 17, 2020
Mr. Scaramucci’s tweet generated a great deal of discussion. If you click on the tweet, you will see, what some of the responses were.
A third party individual has arranged for me to do a podcast with Mr. Scaramucci. This will take place on June 3. In order to provide background information for “citizenship taxation”, FATCA and how they impact Americans abroad, I would ask that you reply to the following tweet. It is your opportunity to contribute to the conversation.
Hi – yes I am scheduled to speak with @Scaramucci on June 3. I hope to discuss the trials and tribulations of #Americansabroad in a #FATCA and @citizenshiptax world. Would greatly appreciate everyones specific suggestions to highlight the injustices.
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 27, 2020
Feel free to leave a comment to this post. I will ensure that it finds its way into the twitter thread.
John Richardson – Follow me on Twitter @Expatriationlaw
This 1981 article on the S. 911 FEIE explains the purpose was to make it less expensive for US corps to hire US citizens. It was NOT motivated by any desire to help #Americansabroad. "THE FOREIGN EARNED INCOME EXCLUSION: REINVENTING THE WHEEL" on JSTOR https://t.co/QBSz1f84NS
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 12, 2020
I recently participated in a podcast discussing both the opportunities and limitations associated with the Section 911 FEIE (“Foreign Earned Income Exclusion”). It is short and explains why the FEIE is not the answer to the problems experienced by Americans abroad. You can listen to it here:
The podcast was the subject of a post at American Expat Finance. That post prompted me to explore more deeply, the origins of the FEIE. When was it enacted? What was it designed to do? I found a fantastic article that I thought I would/should share.
Great post on FEIE. Interesting that #digitalnomads have not objected to @ACAVoice proposal to abolish Foreign Earned Income Exclusion https://t.co/49CHkqqbi7
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 26, 2017
The above tweet references a post by Virginia La Torre Jeker describing the “Foreign Earned Income Exclusion” found in Internal Revenue Code S. 911. Her description of the Foreign Earned Income Exclusion includes:
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