Americans Abroad And Taxes

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Prologue – The “Take Away” And Summary For Americans Abroad

A Mexico Land TRUST, is not a FOREIGN TRUST for IRS purposes – ("cannot be what it isn't"). But, a Liechtenstein “Stiftung” – private FOUNDATION with no reference to the word TRUST is a FOREIGN TRUST for IRS penalty purposes – ("would be what it isn't"). https://t.co/3qaB8NWrnF pic.twitter.com/iHkZMP8iAS

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 16, 2022

The general message is contained in the above twitter thread. Americans abroad are likely to have financial involvements with a number of different kinds of “entities” that are “local” to them and “foreign to the United States. Examples may include: pension plans, tax advantaged savings plans, small business corporations and more. The descriptive title of these “entities” is irrelevant to their classification under US tax rules.

Written by John Richardson | Posted in Americans Abroad And Taxes • TaxConnections

Note From TaxConnections CEO: After following John Richardson’s nearly 200 Blog Posts on our site, I can tell you John dug deep in his research to provide answers that lawyers would charge one thousand dollars an hour to give you. John Richardson knows what is happening to Americans Abroad and has the prescience to know what is about to happen to those now residing in America.

I asked John if I could post these questions and answers and also if he would help us pull together a selected group of the nearly 200 posts into an eBook we could give you all. It is coming soon! In the meantime, follow his well-researched and expert counsel. John Richardson is the best of the best!

Kat Jennings, CEO TaxConnections

1.What do I need to report as a U.S. taxpayer who renounces citizenship?

Renunciation of US citizenship triggers a reporting frenzy. Information regarding the rules governing information reporting when one relinquishes U.S. citizenship are found in the Internal Revenue Code 6039G. Read this article:

www.taxconnections.com/taxblog/individuals-treasury-the-state-department-and-irc-6039g-who-has-to-report-what-when-an-individual-renounces-u-s-citizenship

2. What are the U.S. Treasury’s Final Regulations on GILTI?

The U.S. Treasury final regulations (at least prior to the Biden administration) allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income(GILTI) computation on an elective basis. Read this article:

https://www.taxconnections.com/taxblog/treasury-final-regulations-confirm-that-foreign-income-subject-to-high-foreign-tax-be-excluded-from-definition-of-gilti/

Written by TaxConnections Admin | Posted in Americans Abroad And Taxes • Expatriate Tax Lawyer