John Richardson - Counsellor for US persons abroad Profile picture
Expatriation - #FATCA Letter - CRS - CFC - PFIC - @CitizenshipTax - US Citizenship Renunciation - @JustRenounce - Green Card Abandonment - @GreenCardTax

Apr 11, 2022, 9 tweets

Senators @RonWyden and Rob Portman propose legislation that (among other things) suspends the exchange of #FATCA information (which the US doesn't provide anyway) with Russia. finance.senate.gov/imo/media/doc/…

An interesting example of the US tax code being used as a method of @Sanctionslaw. With respect to US taxpayers subject to taxation by Russia: 1. No FTCs allowed 2. If not a CFC, income subject to tax by Russia is deemed to be CFC/Subpart F income - ensuring tax at high US rate.

Proposed legislation also includes a laundry list of specific denials of tax benefits to specific individuals. In all cases - specific provision intended to tax treaties.

For more details and the draft legislation see finance.senate.gov/chairmans-news…

More commentary here ... thehill.com/policy/finance…

Here is a link to the summary of the proposed @RonWyden legislation to use the Internal Revenue Code to sanction Russia and US persons who do business with Russia citizenshipsolutions.ca/wp-content/upl…

Here is a link to the actual proposed @RonWyden legislation to use the Internal Revenue Code to sanction Russia and US persons who do business with Russia citizenshipsolutions.ca/wp-content/upl…

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