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Archive for John Richardson

Establishing Same Country Exemption Through Legislation

John Richardson

The Maloney Approach

This is a continuation from a previous article, FATCA’s Same Country Exemption Won’t Work.

On April 25, 2017 Congresswoman Maloney introduced H.R. 2136: “To amend the Internal Revenue Code of 1986 to provide an exception from certain reporting requirements with respect to the foreign accounts of individuals who live abroad.”

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FATCA’s Same Country Exemption Won’t Work

John Richardson

Introduction: If you were to REPEAL FATCA

A previous post discussing the what exactly is meant by FATCA and the Mark Meadows “Repeal FATCA” bill, described:

FATCA is the collective effect of a number of specific amendments to the Internal Revenue Code which are designed to target both (1) Foreign Financial Institutions and (2) those “U.S. Persons” who are their customers.

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Green Card Holders: Tax Treaty Tiebreaker

John Richardson

Before a green card holder uses the Treaty Tiebreaker provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the Treaty Tiebreaker on:

A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?)

B. His/her status under Title 26 (will he expatriate himself under Internal Revenue Code S. 7701(b)) and subject himself to the S. 877A Exit Tax provisions?

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How Exactly Does The Meadow Bill Repeal FATCA?

John RIchardson

(This blog is continued from a longer set of posts which you can find here: Part 1: Introducing FATCA – What Does It Mean In Your Life? and Part 2: FATCA:  How Does The Meadows Bill Interact?)

I was asked to answer the question:

“What exactly would it mean to repeal FATCA?”

The short answer to the question is:

“We make FATCA go away by reversing all the changes to the Internal Revenue Code that collectively comprise FATCA.”

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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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