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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More from @ExpatriationLaw

May 5
The more complex the system of laws, the more likely it will result in unfairness ... “How is he going to manage alone?” Mr. Ganesan said. “I was really devastated that just because of my country of birth, my son’s opportunities are very limited.” nytimes.com/2022/04/30/us/…
Barack Obama once claimed: "The circumstances of your birth should not determine the outcome of your life." One more example of individuals being victimized by the complexity of a system of laws (probably applying in ways that were never intended).
US tax and immigration laws appear to be (1) incredibly complex and (2) antiquated and archaic (3) based on assumptions that are not connected to the 21st Century.
Read 11 tweets
Apr 18
Interesting message from @EWarren indicates a "carve out" from @TheDemocrats core values for #Americansabroad (who actually are "working people" not mini-multinationals). Perhaps @DemsAbroadTax could educate @SenWarren about @CitizenshipTax and #FATCA. nytimes.com/2022/04/18/opi…
Exhibit A: "Standing up for the inherent dignity of everyone is a core American value, and Democrats are proud to do that every day."
Exhibit B: "Democrats win elections when we show we understand the painful economic realities facing American families and convince voters we will deliver meaningful change."
Read 11 tweets
Apr 15
Should the income tax be a "class tax" or a "mass tax"? - "Not Enough Americans Pay Income Tax. Should They?" via @YouTube
Apparently approximately 50% of US residents pay no income tax. Is this an argument for ending the income tax and moving to something more akin to a "mass tax" like @FairTaxOfficial?
Interesting discussion that suggests that taxation is an issue of "citizenship". What if you have a majority not paying income tax but voting how tax revenues are spent?
Read 7 tweets
Apr 11
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.
Read 9 tweets
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/…
Read 4 tweets
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

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