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Archive for Citizenship Based Taxation

What Does U.S. Citizenship-Based Taxation Actually Mean And To Whom Does It Actually Apply?

John Richardson - Citizenship Based Taxation

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows:

You are invited to submit your questions in advance. In fact, PLEASE submit questions. This is an opportunity to engage with Homelanders in general and the U.S. tax compliance community in particular.

I hope that this series of posts will give you ideas for questions and concerns that you would like to have addressed in the May 17, 2019 Tax Connections – Citizenship Taxation discussion.

Laura Snyder has graciously contributed four posts of this series. In her series of four posts, she has outlined the origins and requirements of U.S. citizenship-based taxation.

Ms. Snyder grew up in the United States and moved to Europe as an adult. The tone and pain reflected in her writing suggests that she truly identifies as being a citizen of the United States.

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The Great Debate On Citizenship Taxation: Defining Residence For Income Tax Purposes

Lets Debate 2

An article we posted recently by Professor Edward Zelinsky had the impact of a lightening rod and sparked considerable discussion and commentary. You can view the post by going to this posted link on Defining Residency For Income Tax Purposes. The post was a catalyst for a debate we have now scheduled on Citizenship Taxation.

On Friday, May 17th starting at 11:00 AM PST/2:00 PM EST
TaxConnections is hosting a live stream YouTube Event having invited legal scholar Professor Zelinsky to present his views for Citizenship Taxation. We have also invited John Richardson to present his views and opposition to Citizenship Taxation.

The education these gentlemen will provide on the issues surrounding Citizenship Taxation and FATCA are important to bring to light to the public. We want taxpayers to have the answers they need; we want the tax professional community to have accurate information; and we want to understand the issues that need to be resolved by the US government.

We invite you all to join us during this very lively and educational debate. Register to receive a complimentary invitation to view the debate online live stream through YOUTUBE.

 

 

 

Citizenship And Worldwide Taxation: Citizenship As An Administrable Proxy For Domicile (Part 1)

Edward Zelinsky ( Part I)

ABSTRACT: The United States’ worldwide taxation of its citizens is less different from international, residence-based norms than is widely believed and is sensible as a matter of tax policy. An individual’s citizenship is an administrable, if sometimes overly broad, proxy for his domicile, his permanent home. Both citizenship and domicile measure an individual’s permanent allegiance rather than his immediate physical presence. Because citizenship and domicile resemble each other, and because other nations often define residence for tax purposes as domicile, the U.S. system of citizenship-based taxation typically reaches the same results as the residence-based systems of these other nations, but reaches these results more efficiently by avoiding factually complex inquiries about domicile.

In contrast, the traditional justification of U.S. citizenship-based taxation, the putative benefits of such citizenship, is not persuasive. In this context, three models of U.S. citizenship are relevant, namely, the minimalist model, the psychological model, and the Tiebout/purchase model. None of these models justifies the worldwide taxation of U.S. citizens on a benefits basis. Rather, such taxation is persuasive because of administrative considerations, i.e., the close resemblance of domicile and citizenship that makes the latter an administrable proxy for the former.

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The United States Imposes A Separate And Much More Punitive Tax On U.S. Citizens Who Are Residents Of Other Countries

John Richardson April 10

Reposted Due To Upcoming Debate On Citizenship Taxation

On February 28, 2019 TaxConnections kindly posted my first post comparing the way that 19th Century Britain and 21st Century America Treated Its Citizens/Subjects. The post received a great deal of interest resulting in more than 120 comments (largely reflecting the frustration of Americans abroad and accidental Americans).

The purpose of that post focused largely on citizenship and the fact that the United States imposes worldwide taxation on U.S. citizens who are tax residents of other countries and do NOT live in the United States. What that post did NOT do was to focus on HOW the Internal Revenue Code applies to U.S. citizens who do NOT live in the United States.

The Bottom Line Is:

The United States is in effect imposing a separate and more punitive tax system on its citizens abroad. Strange but true. The purpose of this post is to explain how that works and to provide specific examples.

Prologue

Do you recognise yourself?

You are unable to properly plan for your retirement. Many of you with retirement assets are having them confiscated (at this very moment) courtesy of the Sec. 965 transition tax. You are subjected to reporting requirements that presume you are a criminal. Yet your only crime was having been born in America (something you didn’t even choose) and attempting to live as a U.S. tax compliant American outside the United States. Your comments to my recent TaxConnections Post reflect and register your conviction that you should not be subjected to the extra-territorial application of the Internal Revenue Code – when you don’t live in the United States.

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John Richardson And Edward Zelinsky: Register For Invitation To Live Stream Event On May 17th 2019 On Citizenship Taxation

Lets Debate

TaxConnections CEO Kat Jennings is happy to announce that both John Richardson and Edward Zelinsky have agreed to present their views on Citizenship Taxation on a live stream YOUTUBE event on Friday, May 17th 2019. The mission of this presentation is to provide both sides of the views on Citizenship Taxation.

We have asked the following question to both speakers:

“Should The United States Impose Worldwide Taxation And Reporting On People Who Are Residents Of Other Countries?”

TaxConnections Mission In This Livestream Presentation:

1. Presenting two opposing perspectives on FATCA compliance.

2. Educate taxpayers and tax professionals on FATCA and Foreign Assets.

3. Receive input and perspective from taxpayers and tax professionals.

4. Educate U.S. Congressional Representatives on the impact of FATCA.

5. Provide ideas and solutions to fix the problems associated with Citizenship Taxation on those who do not reside in U.S.

Please register for a complimentary invitation and updates on this very important and educational event for all. You can help us by sharing this blog post with everyone you know who may be affected by Citizenship Taxation or who want to learn from two leading experts on the subject.

Register Here For Complimentary Invitation To Watch Live Stream

https://www.taxconnections.com/livestream

 

 

Wisdom Of “Three Monkeys” Explains: Little Support For “Citizenship-Based Taxation” Makes Repeal Difficult

John Richardson, Citizenship Based Taxation

The uniquely American practice of “imposing direct taxation on the citizen/residents of other nations” (“citizenship-based taxation”) has NO identifiable group of supporters (with the exception of a few academics who have never experienced it and do not understand it).

The Uniquely American practice of imposing direct taxation on the citizen/residents of other nations has large numbers of opponents (every person and/or entity affected by it). In addition to the submissions of Jackie Bugnion, “American Citizens Abroad“, “Democrats Abroad“, Bernard Schneider there is significant opposition found in the submissions of a large number of individuals. It is highly probable that the submissions come from those who are attempting compliance with the U.S. tax system.

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