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Tag Archive for John Richardson

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

 

 

In The 21st Century The Most Important Thing About A Person Is Tax Residency

John Richardson- Residency Determines Tax

Green Card holders are deemed to be U.S. tax residents under the Internal Revenue Code. In most circumstances Green Card Holders are also treated as U.S. tax residents under U.S. tax treaties.

U.S. Green Card holders have traditionally been able to use tax treaties to sever “tax residence” with the United States. This decision carries both burdens and benefits and should never be undertaken without competent professional advice. (For Green Card holders who are “long term residents“, the use of a “tax treaty tie breaker” will result in expatriation. Expatriation may trigger the imposition of the Sec. 877A Expatriation Tax.)

The tax treaty tie breaker is available if and only if the individual is, according to the tax treaty, a tax resident of BOTH the United States and the treaty partner country.

Typically the tax treaty tie breaker is a mechanism where one uses the provisions of the tax treaty to assign tax residency to one and only one country according to the tax treaty.

To repeat: a condition precedent to the use of the tax treaty tie breaker is that the individual be a tax resident of both countries according to the tax treaty.

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WOW! A Big Reaction To The Article Posted Yesterday Called “USA Of The 21st Century Is Like Britain In The 19th Century”

John Richardson About Americans Citizens Abroad

Yesterday, we posted an article called The USA Of The 21st Century Is Like Britain In The 19th Century written by John Richardson of Citizenship Solutions in Canada. John is an internationally recognized expert on the subject of dual citizenship and accidental Americans. The post created a significant amount of reaction and response which I want to bring to your attention today. It is important to understand the impact of U.S. tax laws and how they are affecting Americans who moved long ago to another country, or may have just been born here but do not reside in the United States.

It is a great article and the commentary continues to highlight the issues faced by many. You can read the article and the comments at this link:

https://www.taxconnections.com/taxblog/the-usa-of-the-21st-century-is-like-britain-in-the-19th-century/#.XHkuBqJKiJA

Your comments are welcome to continue enlightening the world.

Kat Jennings, CEO TaxConnections

 

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

John Richardson And FATCA

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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View An Astonishing Achievement By These Tax And Business Professionals For 9 Million Americans Abroad

Kat Jennings - Thank These Gentlemen

This is an important post that we encourage you forward on to any person you know who is an American working and living abroad; or any accidental Americans who are caught up in this tax legislation. Please watch this video where John Richardson interviews Jim Gosart, Olivier Wagner and Solomon Yue about their work on behalf of all Americans Abroad. Although many other significant contributors have helped along the way, these gentlemen have been greatly instrumental in getting tax legislation H.R. 7358 to Congress.

If you have followed any of the initiatives to get this bill in front of Congress, you must know what they have accomplished is astonishing. The goal has always been to make the tax treatment of Americans Abroad fair. The new bill presented in Congress is appropriately called “Tax Fairness For Americans Abroad Act of 2018″ and you should follow it closely.

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