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Tag Archive for expatriate

IRC Section 965 Transition Tax: Resistance Is Futile

transition tax, americans abroad, expatriate, canada

“This legislation is being interpreted by a number of tax professionals to mean that individual U.S. citizens living outside the United States are required to simply “fork over” a percentage of the value of their small business corporations to the IRS. Although technically “CFCs” these companies are certainly NOT foreign to the people who use them to run businesses that are local to their country of residence. Furthermore, the “culture” of Canadian Controlled Private Corporations is that they are actually used as “private pension plans”. So, an unintended consequence of the Tax Cuts Jobs Act would be that individuals living in Canada are somehow required to collapse their pension plans and turn the proceeds over to the U.S. government” Read more

Tax Cuts And Jobs Act (TCJA): Changes For American Expatriates

Many American citizens who live outside the US have for years raised concerns about the United States’ Citizen-Based-Taxation System. They may have been hopeful when tax reform was being proposed but have been disappointed that their concerns have been ignored. The new tax reform bill Tax Cuts and Jobs Act called TCJA (pronounced tick-jah) has brought about massive changes in the way individuals are going to be taxed but not much has changed for American Expatriates.

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U.S. Expats In The UK And Brexit

In a referendum in June 2016, the UK voted to leave the European Union (EU). The result was a surprise to many, as experts had been lining up to say that the UK would be worse off economically if it left. Just over a year on, it’s still a divisive issue in the UK. However the government formally triggered the start of the two year leaving process in March 2017, so it’s definitely going to happen. While heated debate on the pros and cons of staying and leaving still rages among the Brits, many U.S. expats are wondering what the implications for them are. Read more

Exactly What Income Can U.S. Expats Exclude? FEIE

American expats are, unfortunately, still required to file U.S. taxes from abroad. Thankfully though, there are several exclusions that reduce or in most cases eliminate their U.S. tax liability. The foremost among these is the Foreign Earned Income Exclusion. Not owing U.S. taxes doesn’t exempt expats from having to file a U.S. tax return though, as the exclusions that reduce or eliminate U.S. tax liability for expats must be claimed each year when expats file their federal return. Read more

Expat Tax: Your Renunciation And When Your CLN Is Issued

John Richardson

Two questions that I frequently receive from people who have renounced U.S. citizenship are:

I. An immigration question: What if I attempt to travel to the United States during the period of time between my actual renunciation of U.S. citizenship and actually receiving my CLN (which is my proof of having renounced U.S. citizenship)? Read more

U.S. Expatriates Guide To Living In Greece

Living in Greece is an incredible experience for a number of reasons, including the friendly locals, the culture, history, architecture, climate, beaches and islands, not to mention easy access to the rest of Europe. As an American expatriate living in Greece though, what exactly do you need to know regarding filing U.S. expat (and Greek) taxes? Read more

Topsnik 2 : Green Card Expatriation And The Exit Tax

John Richardson

Introduction – Introducing Gerd Topsnik

“This case will be seen as the first of an (eventual) series of cases that determine how the definition of long term resident applies to Green Card holders. The case makes clear that if one does NOT meet the treaty definition of resident in the second country, that one cannot use that treaty to defeat the long term resident test. A subsequent case is sure to expand on this issue. Otherwise, the case confirms that the S. 877A Exit Tax rules are alive and well and that the 5 year certification test must be met to avoid non-covered status.”

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5 Key Considerations For U.S. Expats Living In The U.K.

Ephraim Moss

According to a report published by the United Nations, Department of Economic and Social Affairs, the number of Americans living in the United Kingdom was estimated at 212,150 in 2015. This represents a sizable group of Americans living in just one foreign country.

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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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Exposé On The Cost For An Accidental American Under FATCA

William Byrnes

An interesting read by the Telegraph that walks an Accidental American through the process of renunciation of American citizenship to avoid paying a life time of US taxes, penalties, interest, and potentially criminal offences for non-filing. Read it here. Excerpts below:

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Consequences of Internal Renenue Service Tax Compliance for Offshore Residents

Since the time the IRS announced the revised Offshore Voluntary Disclosure Program, there has been a consistent restlessness among American expats. At the forefront of this change is the inclusion of the Streamlined Compliance Procedure Program, which is available to U.S. individual taxpayers residing in the United States as well as those who live abroad.

The Streamlined Foreign procedures cater to those U.S. citizens or lawful permanent residents – i.e., expats – who satisfy the non-residency requirement. The non-residency requirement has two strands. First, the taxpayer must not have a U.S. abode. And second, the taxpayer must have lived outside of the U.S. for at least 330 full days in at least one (or more) of the most recent three years for which the U.S. tax return due date (or properly Read more

Making Citizenship-Based Taxation Reform Easy

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

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