From @HelenBurggraf - taken to it's conclusion means that US citizens should renounce in order to avail themselves of the benefits of being a #nonresidentalien which include parking money in the USA away from the prying eyes of the rest of #CRS world. americanexpatfinance.com/news/item/971-…
Q. How can nonresident aliens (not US citizens or residents) use the USA as a privacy jurisdiction? Why does @TaxHavenUSA exist? A. Because, as noted by @TaxJusticNet, the USA as refused to join the Common Reporting Standard which requires reciprocal exchange of information.
While refusing to join the CRS and provide information to the rest of the world, the USA employs #FATCA to require information from the rest of the world. It's the American Way: You will give us everything and we will give you nothing. "Heads I win and tails you lose."
But, #FATCA has also allowed the US to expand its tax base into other countries and impose direct US taxation on the non-US source income earned by those with @taxresidency in those other countries. But, I digress a bit ... americanexpatfinance.com/opinion/item/2…
Commentators also claim that the USA won't join the CRS because it has #FATCA. IMHO this is confusing correlation with causation. I doubt the US would join CRS under any circumstances bc it would impose an obligation on the USA to provide info. US has no obligations under #FATCA
As goes migration, so goes history. The USA historically was a beacon for those freeing oppression and seeking liberty. Speaking of liberty, I am reminded of a famous poem related to the Statue Of Liberty ... "Give me your ... Your huddled masses" en.wikipedia.org/wiki/The_New_C…
The 21st Century rise of @TaxHavenUSA has made the USA a new haven for those seeking liberty and privacy. The allure of America is no longer personal freedom (highest incarceration rate in the world). It's the freedom afforded non-US individuals to shield assets from prying eyes.
Privacy aside, capital parked in the USA is often invested in various kinds of US situs assets including US stocks and US real estate. This has its own set of challenges while the investor is alive and is (more or less) subject to US taxation on the investment income
But, if a nonresident alien dies with US situs assets (real estate and US stocks) ... Their estate is subject to a 40% confiscation of the FMV of the asset!! (And yes I know that there are work arounds - foreign corps with all the extra costs, etc.) But, this is a big problem!
Which makes me wonder if the next big USA "Data Grab" will be to try to determine exactly who are the nonresident aliens who own all US situs assets. If they die owing US situs assets, it's a 40% asset confiscation just waiting to happen.
Re the claim that US is the Number 1 privacy jurisdiction in the world. There is disagreement on whether this is good or bad. Why should every person in the world be subject to the kind of scrutiny that the "Tax Justice Warriors" advocate? Perhaps a "Statue Of Privacy" is needed!
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