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John Richardson - lawyer for
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Apr 11 • 9 tweets • 4 min read
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…
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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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More from @ExpatriationLaw

John Richardson - lawyer for
Apr 10
The Play: "Act 1 - To have UK @taxresidency (allowing her to be a treaty nonresident for US tax purposes and avoid US tax on non-US source income). Act 2 - To not be UK domiciliary (non-dom status allows for the avoidance of UK tax on non-UK income)." theguardian.com/politics/2022/…
dailymail.co.uk/news/article-1…
Read 4 tweets
John Richardson - lawyer for
Apr 7
In 21st century the most interesting thing about a person is his/her @TaxResidency. For UK residents "non-dom status means #territorialtax! For UK doms there is #worldwidetax and #RBT. For US citizens there is #worldwidetax, @CitizenshipTax and #FATCA. theguardian.com/politics/2022/…
.@TaxResidency is often confusing and often has a huge impact on ones life. In simple terms, you are a #taxresident of a country which has the right to impose the full force of its tax rules on you. This is different from HOW and on WHAT sources of income tax residents are taxed.
What income is subject to taxation: Terms like "worldwide taxation" (wherever the income is earned) and "territorial taxation" (income earned only in the country) describe HOW and ON WHAT income #taxresidents are taxed. These terms do NOT describe @TaxResidency (who is taxed).
Read 35 tweets
John Richardson - lawyer for
Apr 6
Let's start with the "self evident truth" that US citizenship - conferred mostly by birth and the US constitution - has attributes making it superior to other citizenships. What are those attributes? What obligations/rights do they imply? Voting? Taxation? Military service? ???
Recent discussions have identified voting and taxation as inseparably linked with US citizenship. Many have suggested that voting, taxation and the rights and obligations of citizenship are somehow linked. Is this true? Was it ever true? What is the source of a right/obligation?
A constitutional right is different from a right created by statute. A constitutional right exists to put the right beyond the reach of governments. In other words, the right exists, no matter what the gov of the day says. Statutory rights: created by and can be changed by gov.
Read 16 tweets
John Richardson - lawyer for
Apr 5
Good @DemsAbroadCan podcast with @AbroadRebecca about US @citizenshiptax. Would be interesting to host Rebecca and @MaxSteinerCA together to discuss: "Should taxation be an incident/characteristic of US citizenship?" open.spotify.com/episode/71oy7e…
"To Whom much has been given, much is expected." Perhaps exceptional citizenship implies exceptional obligations. But, what is it about US citizenship that makes it so exceptional?
Apparently 50% of US residents do not actually pay US federal taxes. Nobody suggests they are "tax cheats". But aren't the non-payers then "citizenship cheats"? Clearly they are availing themselves of the benefits of US citizenship for free (aren't they)?
Read 14 tweets
John Richardson - lawyer for
Mar 30
The @ACDSovereignty #FATCA appeal has started and in the early moments. The plaintiff/Appellant's lawyer Greg D. is off to a good start ...
Three arguments: 1. Standard Of Review 2. Confusing the S. 8 test of unreasonable search with S. 1 "reasonable limits" 3. Question of whether the Appeal court can conduct a hearing on the S. 1 issue.
Is the ITA of Canada a regulatory statute or a criminal statute? #FATCA info can be sent to the USA for the purposes of a criminal prosecution. Judge seems to be suggesting that the criminal aspect was not raised at trial ...
Read 78 tweets
John Richardson - lawyer for
Sep 20, 2021
A must read! #Americansabroad need to raise enough money to hire a well connected accounting firm to facilitate "A Regulatory Fix To @Citizenshiptax" - How Accounting Giants Craft Favorable Tax Rules From Inside Government nytimes.com/2021/09/19/bus…
After watching the laughable town hall with Carolyn Maloney today, it's perfectly clear that "It's not that they don't care. It's that they don't care that they don't care." Without legislators with a reason to enact residence-based taxation a LEGISLATIVE solution is difficult.
A LEGISLATIVE solution is possible only if political parties know that ignoring @citizenshiptax will cost them votes. The Democrats seem to think that the overseas vote resulted in wins in Georgia and Arizona. If #Americansabroad delivered for @TheDemocrats this can be reversed.
Read 15 tweets

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