cross-posted from citizenshipsolutions.ca Part F – A “U.S. citizen” cannot use a “tax treaty tie breaker” to break U.S. “tax residence”. How then does a “U.S. citizen” cease to be a “U.S. tax resident”? Q. I am a U.S. citizen. I do not live in the United States. I live in Canada. I am aContinue reading “So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 4 -Conclusion”
Tag Archives: extra-territorial taxation
So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 3
cross-posted from citizenshipsolutions.ca Part D – Different definitions of “tax residence” – Not all countries define “tax residence” in the same way Q. What is the criteria that different countries use to define who is a “tax resident” of the country? A. The circumstances that constitute “tax residence” will differ from country to country. GenerallyContinue reading “So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 3”
So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer Part 2
cross-posted from citizenshipsolutions.ca Part B – The Combined FATCA/CRS Letter This letter is particularly worrisome for Canadian residents (whether Canadian citizens or not) who were either born in the United States or are (otherwise) U.S. citizens or U.S. permanent residents (AKA Green Card Holders). Could this mean that they would be required to apply forContinue reading “So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer Part 2”
So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 1
cross-posted from citizenshipsolutions.ca So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer Introduction – So, what’s this “tax residence” stuff about? What does “tax residence” mean? During the #InvestmentMigrationForum 2018, @ExpatriationLaw discussed multiple #Tax residencies, tax treaties and tax treaty tier breakers in #CRS andContinue reading “So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer – Part 1”
Any Expats from Louisiana?
from American Expatriates FB group: Monte Silver Yesterday at 3:58 PM EXPAT FROM LOUISIANA? YOU CAN HELP get Americans abroad exempted from the Repatriation/GILTI taxes. If you are an expat from Louisiana and impacted by these taxes, or know someone that is, pls contact me. Thx http://www.americansabroadfortaxfairness.org
Legislative History Reveals FATCA Had Nothing To Do With Collecting Tax Revenue From U.S. Persons With Foreign Accounts Evading Taxes (Part I)
reprinted with permission from Tax Connections Prior to the enactment of FATCA, Congress and the Executive were in possession of concrete-evidence revealing FATCA would fail to collect any meaningful amount of tax-revenue from U.S. persons evading tax through offshore financial center holdings. Congress should have halted enactment of HIRE – if in fact, FATCA’s purposeContinue reading “Legislative History Reveals FATCA Had Nothing To Do With Collecting Tax Revenue From U.S. Persons With Foreign Accounts Evading Taxes (Part I)”
The Repatriation tax and the 962 Election for Americans with a U.K. corporation
by Monte Silver reprinted with permission of the author The U.S. 2017 tax reform has made it very problematic for an American residing in the UK to conduct business through a UK corporation. Operating through a UK corporation exposes the expat to two new taxes: Repatriation and GILTI. This article will discuss the little knownContinue reading “The Repatriation tax and the 962 Election for Americans with a U.K. corporation”
New Accidental American Groups
In the last little while, there are 4 new Accidental American groups which appear to be under the umbrella of Fabien Lehavgre’s group ( website , Facebook , Twitter . I don’t believe I have seen any of these mentioned here so want to be sure this information is available so people are awareContinue reading “New Accidental American Groups”
If you Decide to Comply, DON’T choose a Homelander Tax Compliance Professional
I was very surprised to receive the following email on Friday evening. I cannot recall ever getting anything like this before. I will not identify the author because it is not proper to publicly share an email without the permission of the sender. It is not anyone I have ever heard of before and IContinue reading “If you Decide to Comply, DON’T choose a Homelander Tax Compliance Professional”
Part 7: Responding to the Sec. 965 “transition tax”: Why the transition tax creates a fictional tax event that allows the U.S. to collect tax where it never could have before
cross posted from citizenshipsolutions by John Richardson Brilliant! @FinMusings explains how @USTransitionTax allows USA to collect tax on income that never would have resulted in U.S. tax payable! By changing timing and "frontrunning" USA creates a "fictional event" to tax CDN income before Canada can tax it! https://t.co/hnDu6x7y5K — John RichardsonContinue reading “Part 7: Responding to the Sec. 965 “transition tax”: Why the transition tax creates a fictional tax event that allows the U.S. to collect tax where it never could have before”
Citizenship Taxation 