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Tag Archive for John Richardson

Toward A Definition Of Residence-Based Taxation For Americans Abroad

Toward A Definition Of Residence-Based Taxation For Americans Abroad

Introduction

The discussion of tax reform for Americans abroad is increasing in intensity. Whether through amendments to the Internal Revenue Code or a “Regulatory Fix To Citizenship-based Taxation“, Americans abroad are in desperate need of change. The US tax system as it impacts Americans abroad is forcing renunciations of US citizenship.

The language in the discussion for change reflects a desire (on the part of individuals and organizations) to move from the US system of “citizenship-based taxation” to a system of “residence-based taxation”. Various individuals and groups describe the goal using the language of “residence-based taxation” AKA RBT. It would be a mistake to assume that RBT means the same thing to different people. The purpose of this post is to describe definitions of RBT and and how those definitions may be defined for different individuals or groups.

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Americans Abroad: Benefit From Outstanding Lawyer Advice

Americans Abroad And Taxes

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/

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A Simple Regulatory Fix For The Problem Of US Citizenship Taxation

John Richardson

Background

In 2016 I first made the suggestion that citizenship-based taxation could be changed through Treasury regulation. In October of 2020 John Richardson, Dr. Karen Alpert and Dr. Laura Snyder completed a paper titled “A Simple Regulatory Fix For Citizenship Taxation”. The idea advanced is that:

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The USA Of The 21st Century Is Like Britain In The 19th Century

John Richardson And FATCA

(Reposted as a top blog on TaxConnections during 2019)

In 2018 Professor Lucy Salyer of the University of New Hampshire published “Under the Starry Flag” – a book largely about the 1868 Expatriation Act. The book describes a period in American history where Britain treated its “subjects” as having perpetual loyalty to the British Crown. To put it simply: One could NOT emigrate to America and expatriate. No matter what one did, those who were born British Subjects were destined to die British Subjects.

The above tweet links to an interview of Professor Lucy Salyer conducted on February 9, 2019. The interview is about Professor Salyer’s new book “Under the Starry Flag”. It is a fascinating (brilliantly researched) work. The publisher describes the book as:

The riveting story of forty Irish Americans who set off to fight for Irish independence, only to be arrested by Queen Victoria’s authorities and accused of treason: a tale of idealism and justice with profound implications for future conceptions of citizenship and immigration.

In 1867 forty Irish American freedom fighters, outfitted with guns and ammunition, sailed to Ireland to join the effort to end British rule. Yet they never got a chance to fight. British authorities arrested them for treason as soon as they landed, sparking an international conflict that dragged the United States and Britain to the brink of war. Under the Starry Flag recounts this gripping legal saga, a prelude to today’s immigration battles.

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IRS Provides Limited Tax Relief For Certain Individuals Renounced(ing) After March 18, 2010

John Richardson On Renouncing U.S. Citizenship

In what appears to be a response to how FATCA issues affect “accidental Americans” living outside the United States, the IRS has introduced a procedure providing limited tax relief, penalty relief and certainty for accidental Americans who need to renounce U.S. citizenship in a FATCA world. The problem is described in this recent article by Helen Burggraf at American Expat Finance. Note that March 18, 2010 was the date that the HIRE Act (of which FATCA was a revenue offset) was enacted – making it clear that this relief is tied to FATCA and NOT to “citizenship-based taxation” per se.

In a nutshell, it appears (I will read this in more detail again) to say that Individuals who:

1. Have NEVER filed a 1040 U.S. tax return

2. Have relinquished/renounced U.S. citizenship after March 18, 2010

3. File the five tax years in the year prior to relinquishment

4. File a tax return in the year of relinquishment

5. Have a net worth of less than 2 million USD at the time of relinquishment AND at the time of filing

6. Have a total of less than $25,000.00 in U.S. tax liabilities over the five year period

7. Certify that their failure to file was non-willful.

can file, avoid paying the U.S. taxes owed and NOT be a covered expatriate.

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Former ACA Tax Director Jackie Bugnion Recalls The 2014 Kirsch Schneider Debate On Citizenship-Based Taxation

John Richardson CBT

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

This is part of a series of post I have written as a run up to the May 17, 2019 Tax Connections discussion about U.S. citizenship-based taxation.

Introducing Jackie Bugnion …

Jackie Bugnion was an important part of “American Citizens Abroad” for many years. She has an unusually nuanced understanding of the problems that citizenship-based taxation inflicts on Americans abroad. She was (and continues to be) a tireless advocate for the principle that the United States must transition to a system of residence-based taxation. When she retired she was the Tax Director at ACA. She was the author of some of the very best articles about citizenship-based taxation.

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TaxConnections Hosts Worldwide Citizenship Taxation Debate: You Are Invited To Attend Friday, May 17th 2019

Lets Debate 2

Lawyers John Richardson and Edward Zelinsky will present their views on Worldwide Citizenship Taxation on a live stream YOUTUBE event hosted by TaxConnections on Friday, May 17th 2019. The mission of this presentation is to provide important views on Worldwide Citizenship Taxation.

We have asked the following question to both speakers:

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

TaxConnections Friday, May 17th Livestream Presentation Will Focus On:

1. Presenting two opposing perspectives on Worldwide Citizenship Taxation.

2. Educate taxpayers and tax professionals on worldwide citizenship taxation.

3. Provide perspective from taxpayers and tax professionals globally.

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

Register Here For Complimentary Invitation To Watch Live Stream

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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It Hurts My Heart: The Case For Fairer Taxation Of Non-Resident U.S. Citizens (Part 2 of 4)

John Richardson Part 2

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join us 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).

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Live Stream Event Friday, May 17th 2019: Is Citizenship And Worldwide Taxation Morally Justified or Unjustified?

Citizenship Taxation: Is It Morally Justified Or Unjustified?

You are invited to a livestream YouTube event on Friday, May 17th 2019 hosted by TaxConnections. Two highly educated and lawyers will present opposing positions on Citizenship And Worldwide Taxation.

Date: Friday, May 17th
Time: 2:00PM EST/1:00PM CT/12:00PM MT/ 11:00AM PST
(World Time Zones)
Hosted By: TaxConnections Inc.
Moderator: William Byrnes
For Citizenship Taxation: Edward Zelinsky
Against Citizenship Taxation: John Richardson

Get A Great Education… It’s Free!

REQUEST YOUR FREE TICKET TO EVENT HERE

 

You Are Invited To TaxConnections YouTube Live Stream Event: What Is The Future Of Citizenship Based Taxation?

TaxConnections is privileged to announce the upcoming event on Citizenship Taxation will be hosted by William Byrnes of Texas A&M University, College Station, Texas. Our very distinguished speakers are John Richardson of Citizenship Solutions in Toronto, Canada and Edward Zelinsky of Cardozo School of Law in New York, New York. Mr. Zelinsky will speak in support of Citizenship Taxation and Mr. Richardson will speak out against Citizenship Taxation. Given the large number of expatriates who come to TaxConnections to discuss and seek answers to questions on FATCA and Citizenship Based Taxation, we are delighted to have these legal experts educate our expatriate and tax professional audience.

The Future of Citizenship Taxation

Citizenship Taxation: Is It Morally Justified Or Unjustified?

The future of Americans Abroad is greatly impacted by Citizenship Taxation. You are invited to a livestream YouTube event hosted by TaxConnections with two highly educated and distinguished lawyers discussing their position on Citizenship Taxation.

Date: Friday, May 17th
Time: 2:00PM EST/1:00PM CT/12:00PM MT/ 11:00AM PST
(World Time Zones)
Hosted By: TaxConnections – Meet The Experts
Moderator: William Byrnes
For Citizenship Taxation: Edward Zelinsky
Against Citizenship Taxation: John Richardson

Get A Great Education… It’s Free!

REQUEST YOUR FREE TICKET TO EVENT HERE

 

 

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