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: https://t.co/N6sOOPL4vO — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) October 8, 2021 This […]

Treasury 26 CFR § 301.7701-2 – Business entity definitions discriminate against Canadian Controlled Private Corporations

Synopsis: The power to regulate is the power to destroy! That's why the regulatory process should require careful consideration of how and to whom regs apply. It's time for Treasury to consider "A Simple Regulatory Fix for Citizenship Taxation" https://t.co/6dUqXjtUNo via @SEATNow_org — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 27, 2021 […]

Toward An Explanation For Why Some Americans Abroad Are Complacent About Citizenship Taxation

US @CitizenshipTax AKA #Extraterritorialtax is greater than the self-interest of any one person. It affects you in ways that may not be obvious now. It affects your neighbours. It affects the sovereignty of your country of residence. It affects the future value of US citizenship — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) […]

US Senate Finance Hearing Affects Americans Abroad AKA Mini-Multinationals – Action Needed!

Introduction The background: The US Senate Finance Committee has begun hearings for the purpose of discussing further reform of the rules of International Tax. These reforms would appear to include raising the GILTI tax and raising US corporate tax rates in general. Each of these would have a massive negative effect on Americans abroad. The […]

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 […]

From Jackson-Vanik To The HEART Act – The Evolution Of American Hypocrisy

Introduction In 1974 Congress enacted Jackson-Vanik. By 2012 there was pressure to lift it. "U.S. trade representative urges repeal of law requiring U.S. to impose sanctions on itself" https://t.co/l2IjaUdCeN pic.twitter.com/6BttIRhgJH — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 3, 2020 The above tweet references a 2012 post from the Isaac Brock Society […]

Part 34 – 2019: Treasury Fails To Prevent @MonteSilver1 lawsuit against @USTransitionTax From Proceeding – Case To Be Heard On The Merits

What Happened Excellent! Congratulations to @MonteSilver1 for successfully resisting the US Treasury attempts to end his Section 965 @USTransitionTax lawsuit. Onward! Upward! Happy Holidays to US Person small business owners. Decision here: https://t.co/X81ShD2oap pic.twitter.com/rCqXILLm6x — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 24, 2019 The judgment is here. To see judgement, go […]

Of all the different kinds of residency, the one that matters most is your “tax residency”

Introduction In a world of information exchange (FATCA and CRS), fiscally challenged governments (United States and other Western Democracies) and expanding notions of taxation (GILTI, France Digital Tax, etc.), your “tax residency” matters. In fact, in the 21st Century the most interesting thing about a person is his tax residency (or residencies). At the same […]

Like FBAR, Form 8938, Form 3520 and Form 5471 – Canada has its own foreign asset reporting rules

Prologue Last week I received a call from one of the many Americans abroad living (not hiding out) in Canada. He did NOT know about his U.S. tax obligations. Therefore, he has not been filing U.S. taxes. Interestingly, he had a portfolio of U.S. stocks (foreign to Canada) which were providing him with a consistent […]

Part 15 in series: The Emotional Toll of US Non-Resident Taxation and Banking Policies – “I Just Wanted to Punch, Kick, Scream”

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 […]