Update – Podcast July 17, 2022

Podcast: @FixTheTaxTreaty @TapInternation @Expatriationlaw: Some Americans have @DualCitizenship at birth: Is A "Certificate Of Loss Of Nationality" really Required To Lose U.S. Citizenship For #FATCA and U.S. @taxresidency if "Born Dual"? We think not. https://t.co/ohnoZ7Fd05

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 17, 2022

"Dual citizens from birth" are "preferred citizens" of the USA. Oh well, people do NOT choose their parents or the place they were born. https://t.co/8bZ44wDfMh pic.twitter.com/8fC6OVjlVi

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 29, 2021

Prologue

It is clear that the US extraterritorial tax regime, which imposes taxation on the non-US source income of US citizens living outside the United States, is an outrageous violation of the sovereignty of other nations. It is also an extreme injustice inflicted on US citizens living outside the United States. The US has successfully exported the extraterritorial tax regime to the world through a combination of (1) The US Internal Revenue Code (2) the FATCA IGAs (hunting down US citizens) and (3) the saving clause in US tax treaties (Country X agrees that the US can impose tax on any individual who has been identified as a US citizen and is tax resident of Country X). To understand the interplay between (1), (2) and (3) above see the following article I wrote for the American Expat Finance News Journal.

#FATCA: The 2010 'tax evasion law' that's 'now an extra-territorial money-sucking machine' https://t.co/1DYJJ7TYeX

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 23, 2021

The three groups most visibly impacted by the US Extraterritorial tax regime (in different ways) and its enforcement outside the United States include:

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