cross-posted from citizenshipsolutions blog by John Richardson Beginning with the conclusion (for those who don’t want to read the post) … For the reasons given in this post, I believe that there are grounds to argue that the imposition of the Sec. 965 “transition tax” on Canadian resident/citizens DOES violate the Canada U.S. taxContinue reading “Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax””
Category Archives: Treaty Issues
Can the Common Law “Revenue Rule” be used to stop Enforcement of #CBTax on non-US Residents?
cross-posted from Storify/Expatriation Law INTRODUCTION In 1775 Lord Mansfield proclaimed “no country ever takes notice of the revenue laws of another.” In common parlance this means that the courts of one country will not enforce the tax laws of another country. It is articulated in the “The Conflict of Laws, Rule #3Continue reading “Can the Common Law “Revenue Rule” be used to stop Enforcement of #CBTax on non-US Residents?”
Topsnik 2 : Green Card Expatriation And The Exit Tax
reposted from Tax Connections Blog Written by John Richardson | Posted in International John Richardson Introduction – Introducing Gerd Topsnik “This case will be seen as the first of an (eventual) series of cases that determine how the definition of long term resident applies to Green Card holders. The case makes clearContinue reading “Topsnik 2 : Green Card Expatriation And The Exit Tax”
Poll: Is it common for #Americansabroad to have a higher U.S. income tax bill than a comparably situated Homelander?
Reblogged from the Renounce U.S. Citizenship blog. How does the U.S. tax bill of an American Abroad compare to the U.S. tax bill of a comparably situated Homelander? https://t.co/BvJsffMgp2 — Citizenship Taxation (@CitizenshipTax) February 18, 2017 //platform.twitter.com/widgets.js Imagine the following two people: We are comparing “Homelander Ted” to “Expat Benedict Arnold”. Assume thatContinue reading “Poll: Is it common for #Americansabroad to have a higher U.S. income tax bill than a comparably situated Homelander?”
The U.S. Saving Clause Facilitates the Expatriation Tax in 877A
What is evident is that our governments do not understand the effects of citizenship-based taxation. They did not believe us when we told them it was not just an issue of possibly not owing annual income tax. They did not believe us when we told them our tax-deferred accounts would be taxed. They didContinue reading “The U.S. Saving Clause Facilitates the Expatriation Tax in 877A”
Solving U.S. Citizenship Problems-with special guest Andrew Grossman Montreal Monday December 5, 2016
A very special meeting for “U.S. Born People” or those who are otherwise “U.S. Persons” !(Naturalized U.S. citizens or Green Card holders) Joining John Richardson will be Andrew Grossman Discussing the “hot topic” of U.S. citizenship (including its liabilities in a FATCA and FBAR world) In addition to focusing on the problems faced by thoseContinue reading “Solving U.S. Citizenship Problems-with special guest Andrew Grossman Montreal Monday December 5, 2016”
Dual Citizens of Sweden, France, Netherlands, Denmark & Canada take note! Your Country WILL NOT Collect for the U.S.
Last week in my email was a link to an article by Michael J DeBlis (unable to determine whether it was the father or the son). It runs in my memory that prior to the launch of the Tax Connections website, the younger Michael had started a blog that was specifically about expatriate issues andContinue reading “Dual Citizens of Sweden, France, Netherlands, Denmark & Canada take note! Your Country WILL NOT Collect for the U.S.”
How the “assistance in collection” provisions in the Canada US Tax Treaty facilitates “US citizenship based taxation”
cross-posted from Citizenshipsolutions 5 US Tax Treaties where "treaty partner" agrees 2 assist US 2 collect taxes on residents of treaty partner country https://t.co/sxElCTAvlr — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) October 19, 2016 The above tweet references the comment I left on an article titled: ” Why is the IRS CollectingContinue reading “How the “assistance in collection” provisions in the Canada US Tax Treaty facilitates “US citizenship based taxation””
Do Canadian (or Australian etc.) Tax Attorneys Advising Canadian Clients on United States IRS Compliance Typically Comply With The “Professional Code of Conduct” of Their Law Societies?
cross-posted from Isaac Brock Society In a recent post I mentioned the situation of a “Caroline” who seeks advice from a Canadian tax attorney (let’s say in B.C.) regarding a question of (IRS) tax compliance with a country foreign to Canada. How should the Canadian tax attorney advise this frightened Canadian citizen– specifically, regarding theContinue reading “Do Canadian (or Australian etc.) Tax Attorneys Advising Canadian Clients on United States IRS Compliance Typically Comply With The “Professional Code of Conduct” of Their Law Societies?”
Citizenship Taxation 