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 is the fourth of a series of posts about international tax reform generally and how FATCA, CRS, citizenship-based taxation, GILTI, etc. work together.
The first three posts were:
US Tax Treaties Should Reflect The 21st Century And Not The World Of 100 Years Ago
The Pandora Papers, FATCA, CRS And How They Have Combined To Create Tax Haven USA
How The World Should Respond To The US FATCA Driven Attack On The Tax Base Of Other Countries
This fourth post continues where the third post – How The World Should Respond To The US FATCA Driven Attack On The Tax Base Of Other Countries – left off. That post described in a general way that FATCA facilitated the US taxation of residents of other countries. The purpose of this post is to give a small number of important examples. To repeat:
The imposition of FATCA on other countries means that …
The United States has effectively expanded its tax base into other countries by claiming residents of other countries as US tax residents. This is a direct attack on and the erosion of the tax base of those other countries.