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 […]

Taxation of #AmericansAbroad in the 21st Century: "Country of birth" Taxation vs. "Country of Residence" Taxation

Update January 2018: This post has been updated with some new links and discussion. Prologue – The “Story Of The Century 200,000 Saudi US citizens liable to pay taxes | Arab News — Saudi Arabia News, Middle East News: via @Arab_News — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 3, 2014 […]

H.R. 5800 – To establish a commission to study how Federal laws and policies (except US Citizenship Taxation) affect United States citizens living in foreign countries

The Readers Digest Version Yes, this post is a bit long. If you don’t want to read it, here is the “Readers Digest” version in the form of a tweet: H.R. 5800 (establishment of a commission to study the issues of Americans does NOT prioritize (or even recognize) US @citizenshiptax as the problem. This problem […]

The Road To Tax Reform For Americans Abroad: Part 2 – Citizenship Taxation And The Seven Deadly Sins

Introduction Life is full of rude awakenings. More and more people are experiencing their OMG moment … The Twin Horrors Of FATCA And Taxation Based Citizenship as described by @Amy_From_Sydney via @YouTube — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 20, 2022 This is Part 2 of the series. In Part […]

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 International waters are not a foreign country. — […]

The Beyer “Tax Simplification For Americans Abroad Act”: A First Look

Updates November 22, 2021: 1. I have also written a post on the SEAT site which compares (in a general way) the Beyer Bill of 2021 to the Holding Bill of (2018). Any attempt to solve this problem through amending the FEIE actually has the effect of strengthening citizenship based taxation. 2. With respect to […]

Eroding the tax base of other countries by imposing direct US taxation on the residents of those countries

When I hear people say that the IRC 911 FEIE and/or the IRC 901 FTC rules mean that #Americansabroad don't pay taxes to the US, I am reminded of John F. Kennedy's 1962 Commencement speech at Yale where he said: — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) October 8, 2021 This […]

How The World Should Respond To The US FATCA Driven Attack On The Tax Base Of Other Countries

#FATCA helps US erode tax base of other countries in two ways: 1. Attracting foreign capital to @TaxHavenUSA 2. Imposing direct tax on residents of other countries: "FATCA: The 2010 'tax evasion law' that's 'now an extra-territorial money-sucking machine'" — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) October 7, 2021 This purpose […]