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Archive for John Richardson

FATCA: How Does The Meadows Bill Interact?

John Richardson

(This is a continuation of a previous post by John Richardson titled, “Introducing FATCA – What Does It Mean In Your Life?” It gives a great summary of FATCA and leads directly into this article.)

First, About the FATCA legislation …

2012 – The world according to FATCA – For the compliance industry: “The Gift That Just Keeps on Giving.”

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Introducing FATCA – What Does It Mean In Your Life?

John Richardson, FATCA,

Be patient. Settle in for the ride. Historians will write much about the role FATCA played in eroding America’s role as a world power.

There is no legislative record which explains the purpose of FATCA. FATCA appeared as an “offset provision” in the HIRE Act which was signed into law by President Obama in March of 2010. Some claim that FATCA was for the purpose of preventing Homeland Americans from “stashing their wealth” in unreported “foreign bank accounts” outside the United States.

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Digital Nomads Using The FEIE To Avoid Paying Income Tax

John Richardson, digital nomad, FEIE

Digital Nomads are entrepreneurs who run location independent business. Many digital nomads travel outside the United States with their laptops. Although they have a presence in other countries, they rarely stay long enough in any country to become tax residents of those other countries. They typically conduct their businesses through non-U.S. (foreign) corporations and draw a salary from those foreign corporations. By drawing a salary from those foreign corporations, they ensure that their income is foreign and they they avoid paying U.S. self-employment taxes.

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Form 8621 And 5471 Are Required Even If The Tax Return Isn’t!

John Richardson

The Internal Revenue Code of the United States requires two things:

1. The calculation of taxes; and

2. The reporting of information.

The Internal Revenue Code of the United States is based on three basic principles:

1. A dislike of all things “foreign”. (If you see the word “foreign” a penalty is sure to follow.)

2. A hatred of all forms of non-U.S. “tax deferral”

3. An attempt to stop the “leakage” of “U.S. taxable assets” from the U.S. tax base. (Examples include the U.S. tax treatment of the “alien spouse” and the U.S. S. 877A “Exit Tax” that may be payable when one makes the decision to renounce U.S. citizenship).

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Capital Gains Tax On Sale Of Principal Residence In Canada

John Richardson, capital gains tax, principal residence

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 renounce U.S. citizenship. This person is completely compliant with his U.S. tax obligations. He is renouncing for a very common reason.

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Did Mr. FBAR Pay A Surprise Visit To Canada?

John Richardson

This is one more of my posts about Mr. FBAR. Mr. FBAR is a mean, nasty vicious thug who has no place in any civilized society.

Thomas Jefferson once said:

Were it left to me to decide whether we should have a government without newspapers, or newspapers without a government, I should not hesitate a moment to prefer the latter.

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FATCA Inquisition For Canadians Applying For Life Insurance

John Richardson

Sad but true. It’s quite understandable that from a “U.S. Worldview” that a life insurance policy is nothing but a “sacred instrument of tax deferral” (and therefore of tax evasion). U.S. citizens are the most highly regulated people in the world. As such it is no surprise that the possible purchase of life insurance could trigger FATCA scrutiny. (In that “Shining city on the hill” those who purchase life insurance are clearly “up to no good” – “no good at all!”)

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Be Careful What You “Fix For” – Mr. Kentera Meets Mr. FBAR

John Richardson

The “unfiled FBAR” continues to be a problem for certain Homeland Americans with “offshore accounts” and all Americans abroad, who continue to “commit personal finance abroad”.

Introducing Mr. and Mrs. Kentara

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U.S. Taxation of the Australian Superannuation? – No!

John Richardson

I recently engaged in a discussion with people who are worried that they might be “U.S. Persons” living in Australia. Their primary concern (and understandably so) is the possible U.S. taxation of their Australian Superannuations. For many, the “Super” is considered to be their most important retirement planning asset.

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A Holiday Gift: What To Do About The Unfiled FBAR – Part 2

John Richardson

Yesterday, we started this blog post to hopefully encourage those with U.S. tax issues to consider whether they can deal with minor/unintentional FBAR violations as a “stand alone single problem”. There may be no need to escalate and expand one single problem into a multi-dimensional full blown tax problem that may end up with unintended and unanticipated costly professional fees as well as undue time spent! Read on and learn why. Keeping a calm head is most important, even if it is most difficult to do in the face of the scary situation of not being in compliance with the U.S. tax and regulatory regime.

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A Holiday Gift: What To Do About The Unfiled FBAR – Part 1

John Richardson

I suspect that history will show that that the growth in renunciations of U.S. citizenship (and abandonment of Green Cards) continued in 2016. Absent a change in the way that the United States treats its “U.S. Persons Abroad”, I suspect that the growth in renunciations of U.S. citizenship will continue.

The purpose of this post and a short summary:

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Tax Residency In Canada: Deemed VS. Factual Resident

John Richardson

Tax Residency is becoming an increasingly important topic. Every country has its own rules for determining who is and who is not a “tax resident” of that country. The advent of the OCED CRS (“Common Reporting Standard”) has made the determination of “tax residence” increasingly important.

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