Discover and read the best of Twitter Threads about #americansabroad

Most recents (24)

All #Americansabroad should listen to Steve Hayes of @FairTaxOfficial where he explains the #FAIRTax. Whether you agree or disagree he makes important points and many observations about the role taxation plays in America. Join movement 4 @FairTaxAbroad!
@FairTaxOfficial @FairTaxAbroad Current tax system is complex, incomprehensible, used to punish some and reward others and has expensive compliance and penalty costs. People don't and can't know how much tax they pay. Compliance costs are a "tax on tax". Here is a poster from the Washington, DC Metro (subway). Image
The #FairTax is a simple consumption based tax. Some describe it as a 30% tax on the purchase price. Others describe it as 23% of the total expenditure. If you spend $100 to purchase an item $77 would be the price and $23 tax. Or see it as $77 + 30% of $77 which totals $100.
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Lunch with Jim Bennett (@jbennettatty) of @FairTaxOfficial fame and his wife Christine in Toronto. Jim's visit sparked hope for #Fairtax(ation) in Canada AND USA. @FairTaxAbroad would completely end the US tax nightmare for #Americansabroad. Learn more at Image
Great podcasts with Jim Bennett (@jbennettatty) of @FairTaxOfficial. Learn how the #FairTax helps ALL Americans and expecially #Americansabroad in an #FBAR and #FATCA world!…
@jbennettatty @FairTaxOfficial To learn why the #FAIRTax if particularly helpful #Americansabroad see the following discussion…
Read 4 tweets
How #FATCA IGAs relate to legislation in IRC: To be consistent with FATCA law and avoid the 30% US sanction, IGAs must require the FFIs to close the account of "US Persons" who fail to supply required data (without regard to local #GDPR law). Solutions?… Image
US #FATCA can accommodate Europe's #GDPR only by by excluding @USCitizenAbroad with @TaxResidency abroad from the definition of "U.S. Person". These two screen shots illustrate the problem ... Some thoughts on how this might this be achieved.… ImageImage
As the @DemsAbroadTax statement and @SEATNow_org states/implies this problem can be solved ONLY if the US joins the world in adopting residence as the criterion for @TaxResidency. Citizenship would no longer be relevant for taxation. NOT part of any current legislative proposal.
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An intelligent response which reinforces the #FATCA (sorry fact) that that the real problem is US @CitizenshipTax. The Decision in Belgium underscores that the sole purpose of the FATCA IGAs is to ensure Americans cannot leave the USA and acquire rights denied to US residents.
As the @DemsAbroadTax statement states/implies this problem can be solved ONLY if the US joins the world in adopting residence as the criterion for @TaxResidency. Citizenship would no longer be relevant for taxation. But, this is NOT part of any legislative proposal.
A second solution would be “A Regulatory Fix For Citizenship Taxation” Which would define “individual” as resident. As published by @TaxNotes here ……
Read 12 tweets
Ending @CitizenshipTax would mean fewer #Americansabroad caught in this #FATCA, #FBAR enforcement dragnet. What's truly "criminal" is unwillingness of US Gov to allow US citizens who live outside USA with @TaxResidency in other countries to avoid being caught in this crossfire.
Report goes on and on about Dan Horsky and a "The Family" (US residents) who used Credit Suisse to (presumably) evade US taxes. It concludes a vast conspiracy and uses this to condemn @DualCitizenship (pp 33 - 337)and justify the hiring of more IRS agents.…
What is really disturbing is how the Report focuses on US citizenship and NOT residence. This should be of great concern to #Americansabroad. Remember also how dissent by Justice Barrett in the Bittner #FBAR case focuses ONLY on US citizenship with NO other circumstance relevant!
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Notice 2023-11: Temp relief provided to banks under Model 1 #FATCA IGAs who can't provide SSN numbers of #Americansabroad ("preexisting accounts only") if the gov joins banks in taking specific steps to educate individuals about FATCA + @citizenshiptax.…
Purpose of Notice 2023-11 is to ensure that banks in a Model 1 #FATCA jurisdiction won't be deemed to be "non-compliant" with the IGA if they can't provide a US SSN for "pre-existing accounts". The notice can be accessed and read in its entirety here ...…
Step 1: The relief is available to the banks in a Model 1 #FATCA IGA jurisdiction and ONLY if the government of the jurisdiction commits to engaging with (1) individual US citizens (2) the banks and (3) US Treasury to facilitate compliance.
Read 17 tweets
When flying over international waters or on a cruise ship in international waters, US citizens are indeed subject to double taxation bc and only bc of US citizenship. Explained by @1040Abroad and @Expatriationlaw here ……
To clarify it is US citizens with @taxresidency in another country that are subject to #doubletaxation. Think pilots, cruise ship employees and #Americansabroad who work on the plane. See this podcast with Jim Gosart of @RepOverseas where we discuss.
The #doubletaxation of income earned in intl waters is one more consequence of @citizenshiptax and another example of how #Americansabroad are taxed more punitively than US residents. Here is a series of podcasts with @RepOverseas explaining the problems…
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Almost all victims of the US extraterritorial tax AKA @citizenshiptax regime (enforced by #FATCA) agree that the practice of the US defining @taxresidency based on the "status" of citizenship alone must end. The plea is: End @citizenshiptax (enforced by #FATCA) and adopt #RBT.
When an organization or individual says they support #RBT or a political party includes #RBT in their platform, you must ask EXACTLY what do they mean by #RBT (Residence-based taxation)? Does their proposal leave citizenship in any way relevant to @taxresidency, #FATCA or #FBAR?
Do advocates of #RBT mean simply supporting a kinder more gentle (Eritrea style) of @citizenshiptax or do they mean making citizenship irrelevant to @taxresidency? Would #Americansabroad still remain US tax residents or do they cease having US @taxresidency for all purposes?
Read 27 tweets
Fifth Circuit Upholds Constitutionality of Passport Revocation Statute…
Apparently this "tax debt" was the result of a penalty for failing to file a Form 3520 to report a "foreign trust". #Americansabroad should be concerned. Clearly in America ALL rights are becoming subordinate to the tax and penalty regime. But, see the following comment ... Image
The gist of the decision which should be deeply troubling. Bottom line: Mr. Franklin's passport was revoked because he failed to file a 3520 reporting a foreign trust ... ImageImage
Read 6 tweets
Some Green Card holders and #Americansabroad living in Belgium are like Alice in her "Adventures In Wonderland". You see they have @taxresidency in the USA, but when they move to Belgium they "changed" to NOT being "residents of the United States" and are denied certain benefits.
Note that the standard "saving clause" confirms the right of the countries to tax their "residents" (as defined in Article 4) and "citizens" (without regard to anything). As always, there are certain exceptions to the "saving clause". Here is paragraph 4 of Article 1 ...
Next we move to Article 4 (the usual residency article) and note that US citizens and Green Card holders ARE defined as US tax residents under US law. Therefore, they are presumptively residents of the USA under the treaty ...
Read 5 tweets
The question is not whether the #votefromabroad movement matters. The question is how @USVotersAbroad should best use their vote to best advance their interests in a @citizenshiptax and #FATCA world.
.@TheDemocrats through their @DemsAbroad wing is working hard to harvest the votes of #Americansabroad. The Republicans are not. As the recent Pelosi message shows, the Democrats don't understand @citizenshiptax or #FATCA problems, don't care or don't care that they don't care.
Now before people start saying "But what about the Republicans?" I remind you that the #FATCA of the matter is that Republicans are NOT out harassing you for your vote. Maybe they should be? It IS possible to discuss one party without discussing the other.
Read 9 tweets
Podcast - A privilege to connect with @andygr to discuss: "The Decline Of The British Pound And Phantom Capital Gains For #Americansabroad Subject To @CitizenshipTax In The UK (a lose-lose situation)"…
Highly recommend this 2014 interview with @andygr about the nature of US citizenship. How to get it. How to lose it. How to determine whether you have it.
Catching up with @andygr in 2016 where we discuss the problems of US citizenship in an #FBAR, #FATCA and @CitizenshipTax world
Read 4 tweets
A Mexico Land TRUST, is not a FOREIGN TRUST for IRS purposes - ("cannot be what it isn't"). But, a Liechtenstein “Stiftung” - private FOUNDATION with no reference to the word TRUST is a FOREIGN TRUST for IRS penalty purposes - ("would be what it isn't").… Image
Here is IRS Rev. Rul. 2013-14 which decided that certain Mexican Land Trusts are NOT trusts for IRS purposes… Image
Here is the August 11, 2022 decision of the US Court Of Appeals - 5th Circuit that ruled that a Liechtenstein "Stiftung" (a German word meaning, roughly, "foundation" or "endowment.") ARE trusts for IRS purposes… Image
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Tuning in on the live argument in the Bitter #FBAR case. Will tweet some of my thoughts/impressions as this unfolds.…
Suggestion that existence of "reasonable cause" mitigates against the threat of draconian penalties.
Judges suggesting that the quantum in the unreported accounts matters. "If you fail to do what the secretary required you to do then you are subject to a penalty of $10,000".
Read 48 tweets
The National Whistleblower Centre has filed an amicus brief in Bittner - TOTALLY DEVOID OF LEGAL ARGUMENT - arguing for per account #FBAR penalties because higher penalties would create incentives for Whistleblowers" to report @InFBARWeTrust violations.… Image
As evidence of the significance of #FBAR violations (and therefore the need to incentivize whistleblowers) the brief cites statistics on the small number of FBARs filed in comparison to the far larger number of #Americansabroad (relying on info from @aaro). ImageImage
The brief seems to advocate that: 1. There is severe #FBAR noncompliance 2. The Government needs whistleblowers 3. Per account penalties will result in higher total penalties 4. The higher the penalty the more likely the whistleblowers will step in to assist the government. Image
Read 8 tweets
2022 FATCA Report: If US doesn't agree to amend #FATCA IGAs to include full reciprocity and respect GDPR (which it won't) options include: 1. Blocking law generally 2. Blocking law for @USAccidental 3. Deem #FATCA inapplicable to European residents period!… ImageImageImage
The very last paragraph explains that #FATCA is not in the spirit of multilateral cooperation. Basically it saying that the US is essentially a 100% taken and a 0% giver. But, we know that Image
A "blocking" statute is a law that "blocks" the application of certain laws ...….
Read 10 tweets
In her own words “Nancy” in a message to @DemsAbroad (1) fails to identify #Americansabroad as a priority while mentioning other groups (2) confirms that your value is ONLY in your vote. A vote for a Democrat anywhere is a vote against every American abroad everywhere.
@DemsAbroad Did @DemsAbroad assist in drafting this message? If yes DA confirms #Americansabroad are not a priority. If no @TheDemocrats confirm #Americansabroad not a priority.
Seriously, @DemsAbroad needs to respond to this “tone deaf” message from Nancy. You couldn’t invent a more offensive message if you tried. Maybe @DemsAbroadCan (home of so many potential voters) could/should respond?
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Lesson from @VLJeker: Some people may never be able to renounce US citizenship. Others may have capacity to renounce now but may not have the capacity to renounce in the future. The inability to renounce has implications for estate and life planning and should be taken seriously!
@VLJeker I have and do see cases where the aging process has eroded the capacity to form the intention to renounce. The result is that certain people are forced to continue to live and die as US citizens. While not a problem for US residents, it can be a big problem for #Americansabroad.
Problems of living/dying as @USCitizenAbroad include: 1. US @citizenshiptax regime while alive 2. Estate having to file US tax returns at death 3. Difficulties leaving assets to nonresident alien spouse 4. Possible Estate Tax 5. Estate Tax return to transfer certain US assets
Read 7 tweets
Supreme Court Asked to Consider if FBAR Penalty Is Excessive Fine…
Separately on Nov. 2/22, in Bittner, the US Supreme Court will hear the case on the issue of whether the non-willful civil #FBAR penalty (found in 5321) - can be applied (based on a reading of 5314) on a "per account" or on a per "form" basis. It's the season of @InFBARWeTrust!
So, Bitter is about the interpretation of penalty application under 31 USC 5314 and 5321. Toth (if the Supreme Court hears the case) is about whether there are constitutional limitations to any penalties imposed under 31 USC 5321.
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In 2022 a "Message in a bottle" from 2013 washes up on the shore as a reminder of US Treasury's " Myth vs. #FATCA…
Walking further down the shoreline, I found a second "Message In A Bottle" - Circa 2015. A 192 page book documenting the "Facts" exposing US Treasury's 2013 "#FATCA Myths" (AKA "Stack-Of-Lies) which continue to this present day. Have a look at this.…
Spent afternoon reading that 192 book absorbing the shocking atrocities committed by the USA against its diasporA. I then tripped, fell into a ditch, landing on a 3rd message Circa 2017 - about a #FATCA hearing - from @AndyGr delivered by @IsaacBrockSoc…
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@AccidentallyUSC @ConnecterIO @SEATNow_org "Uniting and organizing" assumes commitment to a principle that will allow all Americans to live ordinary lives. The ONLY thing that solves the problems of all people, all the time under all circumstances is ending @citizenshiptax -severing US citizenship from US @taxresidency.
@AccidentallyUSC @ConnecterIO @SEATNow_org @CitizenshipTax @TaxResidency As long as #Americansabroad think in terms of solving "their problem" rather the "the problem" change is not possible. Everybody supports some specific change that helps them but leaves other problems intact. H.R 6057 - which helps some people - is a most insidious example.
@AccidentallyUSC @ConnecterIO @SEATNow_org @CitizenshipTax @TaxResidency .@SEATNow_org was formed to educate and encourage people to unite under principle of ending @citizenshiptax - severing citizenship from @taxresidency. Truth is that most people/groups are NOT committed to this principle. They want their problem solved and don't care about others.
Read 9 tweets
A Simple Regulatory Fix For The #FATCA (banking and other) problems for "some" #Americansabroad and others with @dualcitizenship from birth.… via @expatriationlaw
The obvious group that could benefit from this would be @USAccidental
It should be emphasized that this can be achieved through "regulation" and NOT through "legislation" (which is more difficult). Here is an earlier analysis I did of this issue which refers to some earlier proposals coming from the Obama administration.…
Read 6 tweets
A recent archeological/twitterological dig uncovered a historical artifact from the Carter years (1977 - 1981) titled "Equitable Treatment by United States of Its Citizens Living Abroad" - a curious thing from a curious time.…
The first law was Public Law 95 - 426 which became law on October 7, 1978. Sec. 611(a) and 611(b) of the "Foreign Relations Authorization Act, Fiscal Year 1979" created a law which acknowledged the existence and value of #Americansabroad. Specifically the mandated ...
The second law was Public Law 96-60 which became law on August 15, 1979. SEC. 407 of that law amended "Subsection (a)(2) of section 611 of the Foreign Relations Authorization Act, Fiscal Year 1979" as follows ...…
Read 28 tweets
Next up Candidate Patel ...
He says that he has had the personal experience of being double taxed as an American abroad. But, he first wants to discuss the principles of a "Liberal Democracy". Says, Trumpism is on the rise ...
He is correct that @TheDemocrats need a new generation of leadership. True. But, I would really like to hear some mention of @citizenshiptax, #FATCA, etc. He is just criticizing the existing politicians. This guy doesn't understand his audience.
Read 15 tweets

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