John Richardson Tax Lawyer

07 May 2019

How Do I Protect Myself?: A Case Study In The Marginalization of Americans Living Overseas (Part 1 of 4)

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.

Thanks to Professor Zelinsky for his willingness to engage in this discussion. Thanks to Kat Jennings of Tax Connections for hosting this discussion. Thanks to Professor William Byrnes for his willingness to moderate this discussion.

Tax Connections has published a large number of posts that I have written over the years (yes, hard to believe it has been years). As you may know I oppose FATCA, U.S. citizenship-based taxation and the use of FATCA to impose U.S. taxation on tax residents of other countries.

Tax Connections has also published a number of posts written by Professor Zelinsky (who apparently takes a contrary view).

Written by John Richardson | Posted in Residence Based Taxation • TaxConnections • Worldwide Citizenship Taxation

09 Oct 2018

IRC Section 965 Transition Tax – Part 7

John Richardson - Transition Tax - Part 7

Why The Transition Tax Creates A Fictional Tax Event That Allows The U.S. To Collect Tax Where It Never Could Have Before

This is the seventh in my series of posts about the Sec. 965 Transition Tax and whether/how it applies to the small business corporations owned by taxpaying residents of other countries(who may also have U.S. citizenship). These small business corporations are in no way “foreign”. They are certainly “local” to the resident of another country who just happens to have the misfortune of being a U.S. citizen. Read More

Written by John Richardson | Posted in John Richardson Tax Lawyer • Transition Tax

21 Aug 2018

So You Have Received A Bank Letter Asking You About Your Tax Residence For Common Reporting Standards (CRS) Or Foreign Accounting Tax Compliance Act (FATCA) Part 1

John Richardson- Legal Tax Expert On FATCA And CRS

What’s this “tax residence” stuff about? What does “tax residence” mean?

I previously wrote a lengthy post describing “What to do if you receive a FATCA letter“. Information exchange under the Common Reporting Standard “CRS” has begun in 2018. As a result, I am writing this post which is to explain what the CRS is and how it relates to the FATCA letter. It is important to understand that the “CRS letter is actually a combined “CRS/FATCA” letter which is more likely to be received than the original FATCA letter. I urge that those who have received a letter of this type to read this post PRIOR to seeking professional advice!!!

Written by John Richardson | Posted in Canada • Common Reporting Standard • FATCA