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" — John Richardson – lawyer for "U.S. persons" abroad (@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 […]

Republicans Overseas Begins Its Support and Advocacy for Pure Residence-based Tax

This is an incredibly significant development. See the following posts on their Facebook site. They also have a new Twitter feed. Follow them at @RepOverseas. Republicans Overseas position On What Pure Residence-based taxation means: Tax Talk 1 – November 22, 2021 Tax Talk 2 – November 29, 2021 Tax Talk 3 – December 10, 2021 […]

Toward A Movement For Residence-based Taxation For Americans Abroad

Part I – Pure Residency-based Taxation vs. Citizenship-based Taxation With A Carve Out 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 […]

Toward a definition of residence-based taxation for Americans abroad

Introduction .@SenateFinance @SenWhitehouse – please educate yourselves on the harmful effects of #FATCA by reading the submissions by the Democrats Abroad Taxation Task Force. We're not FATCATs – we're just average American citizens living abroad.#RBT not #CBT — Democrats Abroad Belgium (@demsabroadbe) May 24, 2021 The discussion of tax reform for Americans abroad […]

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 dual US/Canada citizens 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 — John Richardson – lawyer for "U.S. persons" abroad (@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 […]