Thread by @ExpatriationLaw

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"). casetext.com/case/rost-v-un…

Here is IRS Rev. Rul. 2013-14 which decided that certain Mexican Land Trusts are NOT trusts for IRS purposes irs.gov/pub/irs-drop/r…

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 casetext.com/case/rost-v-un…

#Americansabroad never know when their life activities may be subject to the US penalty regime. They live in fear of the Sword Of Damocles. The ancient Greeks anticipated the tyranny of Forms 3520, 3520A and the rest of the US tax, form and penalty regime

We see time after time the impossibility of understanding how the US IRC applies to various non-US AKA "foreign" financial arrangements. The impossibility of US @CitizenshipTax is explored in "Mission Impossible - Extraterritorial Taxation and the IRS" papers.ssrn.com/sol3/papers.cf…

We at @SEATNow_org believe that a "Regulatory Fix For Citizenship Taxation" is possible as described in this discussion with @TaxNotes

In conclusion ... “It would be so nice if something made sense for a change.”
― Lewis Carroll, Alice in Wonderland

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