On what date does an individual (other than a U.S. citizen) begin or end @USTaxResidency

This is an interesting and important question. This question is always important for determining how the Sec. 877A “Exit Tax” applies to “permanent residents” AKA “Green Card Holders” who with to abandon their permanent residence. There are many other many other reasons why this matters. U.S. tax residency (which is an example of “deemed tax […]

The teaching of Topsnik 1 – 2014: Taxation for #GreenCard @TaxResidency and "tax treaty tiebreakers"

Introduction This is part of a series of posts on: (1) “tax residency“, (2) the use of “treaty tiebreakers” when an individual is a “tax resident” of more than one jurisdiction and (3) how to use “treaty tiebreakers” to end “tax residency” in an undesirable tax jurisdiction. Topsnik 1: It’s about the taxation (not expatriation) […]

Part 2 – The Warren “Ultra-Millionaire Tax Act of 2021” and The Wealth Of Other Nations

The fact that … The combination of @citizenshiptax and #FATCA are the enforcement mechanisms of this proposed @USWealthTax. The Warren "Ultra-Millionaire Tax Act of 2021" https://t.co/sMjgTP9uny via @TaxConnections — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 5, 2021 Leads to the obvious question of … Could @gabriel_zucman comment on how much of […]

Elizabeth Warren’s “Ultra-Millionaire Tax Act of 2021”: Coming Soon To A Neighbour (and maybe a nonresident spouse) Near You

The Contextual Background – Elizabeth Warren – January 28, 2021 Senator Elizabeth Warren plans to introduce legislation on Monday that would tax America’s wealthiest people. The proposed wealth tax would apply a 2% tax to individual net worth above $50 million and a 1% surcharge for net worth above $1 billion. https://t.co/fM6REHPM8o — The New […]

German tax authorities reported to be imposing German taxation on US military personnel stationed in Germany

Prologue This post draws heavily from the reporting of John VanDiver who has written a number of articles in Stripes. His most recent article is here: Opposition is building against attempts by Germany tax authorities to strong arm US troops into paying massive tax penalties. Germany is the only country where US forces face this […]

China does not have and is not moving toward US style citizenship-based taxation

Readers Digest Version: The Bottom Line Is … As reported by American Expat Finance, which discusses an interview with Dr. Bernard Schneider of Queen Mary … John Richardson Podcast: Dr Bernard Schneider, an expert in int'l tax law at Queen Mary U in London, says China does NOT have a US-style citizenship-based tax regime and […]

About #FATCA and @Citizenshiptax: Here is the @DemsAbroad Interview with @AmyKlobuchar on January 22, 2020

This is an interesting interview with an interesting candidate. But, it is very clear that Senator Klocbuchar (1) believes in FATCA and (2) has no interest in abolishing citizenship-based taxation. You can pick this up at the 27 minute mark. It’s interesting that the two candidates endorsed by the New York Times (Elizabeth Warren and […]

Part 9 of series: How do US Tax Rules Constrain the Investment Choices of US Taxpayers Living in Australia?

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Part 7 of series: Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows: "What Is The Future Of Citizenship-Based Taxation?" Prof. William Byrnes (Texas A&M Law), Prof. Edward Zelinsky (Cardozo Law), John Richardson […]

Article 4 paragraph 2 of the U.S. U.K. Tax Treaty: A clause preventing the use of the tax treaty tie breaker for some Green Card holders

Introduction – In The 21st Century The Most Important Thing About A Person Is His Tax Residency Interestingly the U.S. UK tax treaty appears to have created a "saving clause" for some #GreenCard holders – looks like they may have no residency tie breaker option (very bad!) Why should some Green Card holders be treated […]