Tag Archive for Citizenship-Based Taxation

How The “Assistance In Collection” Provisions In The Canada-U.S. Tax Treaty Facilitates “U.S. Citizenship Based Taxation”

John Richardson

I commented on an article titled: “Why is the IRS Collecting Taxes for Denmark?” which appeared at the “Procedurally Speaking” blog. The article is about the “assistance in collection” provision which is found in 5 U.S. Tax Treaties (which include: Canada, Denmark, Sweden, France and the Netherlands). I am particularly interested in this because of a recent post at the Isaac Brock Society.

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Part 15 – Understanding “Exit Taxes”

John Richardson 24
Interview with – Citizenship based taxation, PFIC, the S. 877A Exit Tax and #Americansabroad

On May 22, 2015 I was interviewed by Gordon T. Long. There is NO way to discuss U.S. “citizenship taxation” (which is primarily “place of birth taxation”) without discussing the S. 877A Exit Tax rules. During the month of April 2015, I wrote a 14 part series on “How the S.877A rules affect Americans abroad“. The interview with Mr. Long serves as a good reminder (or if you don’t want to read the posts) on:

– what it means to be a “covered expatriate

how the U.S. S. 877A “Exit Tax” rules operate to impose punitive “taxation” on non U.S. pensions (See the actual Read more

Internet Tax Summit – September 21, 2105 Comments – U.S. Citizens Living Abroad, Accidental Americans And Immigrants Coming To The U.S.

Kat Jennings - TaxConnections2

Just because I was put in the position to have to relinquish my citizenship does not in the least mean I feel this issue is over for me. There are others sorely impacted as well. I don’t think I will ever truly accept this episode in my life as just. Life is unfair and we must accept that however, these days every time I see some heinous criminal back in the U.S. on my television the thought always goes through my mind “Yes, but that person is not going to be put in the position to have to give up their citizenship no matter what they have done.” It seems childish, I admit but, I hope others will forgive somewhat my resentment over it. I do laugh at myself for having such knee jerk reactions but, I’ll allow myself some of that for a long while to come.  Read more

Making Citizenship-Based Taxation Reform Easy

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Making Citizenship-Based Tax Reform “Easy”

Heitor David Pinto wants to “make it easy” for Congress to move from citizenship-based taxation (CBT) to residence-based taxation (RBT).

Pinto thinks CBT is “absurd.” And he aims to help Congress change it.

Because of CBT’s complexity and because it’s a low priority for Congress, Pinto was concerned Congress might take a long time or might not do tax reform at all for Americans abroad.  But, Pinto hopes “if it’s mostly done already, they might do it faster.”

When the naturalized American citizen immigrated to the United States from Brazil a Read more