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John Richardson - lawyer for
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Nov 20 • 4 tweets • 4 min read
Podcast - A privilege to connect with @andygr to discuss: "The Decline Of The British Pound And Phantom Capital Gains For #Americansabroad Subject To @CitizenshipTax In The UK (a lose-lose situation)" podbean.com/ew/pb-q9vcz-13…
Highly recommend this 2014 interview with @andygr about the nature of US citizenship. How to get it. How to lose it. How to determine whether you have it.
Catching up with @andygr in 2016 where we discuss the problems of US citizenship in an #FBAR, #FATCA and @CitizenshipTax world
.@andygr is the author of the single best research project on #FATCA, #FBAR and how it impacts US
@CitizenshipTax
nyulawglobal.org/globalex/Fatca…

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More from @ExpatriationLaw

John Richardson - lawyer for
Nov 21
The question is not whether the #votefromabroad movement matters. The question is how @USVotersAbroad should best use their vote to best advance their interests in a @CitizenshipTax and #FATCA world.
.@TheDemocrats through their @DemsAbroad wing is working hard to harvest the votes of #Americansabroad. The Republicans are not. As the recent Pelosi message shows, the Democrats don't understand @CitizenshipTax or #FATCA problems, don't care or don't care that they don't care.
Now before people start saying "But what about the Republicans?" I remind you that the #FATCA of the matter is that Republicans are NOT out harassing you for your vote. Maybe they should be? It IS possible to discuss one party without discussing the other.
Read 9 tweets
John Richardson - lawyer for
Nov 16
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… Image
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… Image
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… Image
Read 8 tweets
John Richardson - lawyer for
Nov 13
This informative summary of the differences among U.S. state income taxes naturally leads to a discussion about the difficulty in severing @taxresidency from high tax states like CA, NY and Mass.
Whether constitutional or not I suspect that these high tax states will attempt to impose “Exit/Departure Taxes” on individuals who try to sever @taxresidency with the state.
As discussed in this WSJ article by Hank Adler California has already proposed a very “progressive” exit tax on people who sever @taxresidency. Great article here. wsj.com/articles/a-cal…
Read 13 tweets
John Richardson - lawyer for
Nov 2
Tuning in on the live argument in the Bitter #FBAR case. Will tweet some of my thoughts/impressions as this unfolds. supremecourt.gov/oral_arguments…
Suggestion that existence of "reasonable cause" mitigates against the threat of draconian penalties.
Judges suggesting that the quantum in the unreported accounts matters. "If you fail to do what the secretary required you to do then you are subject to a penalty of $10,000".
Read 48 tweets
John Richardson - lawyer for
Oct 31
The National Whistleblower Centre has filed an amicus brief in Bittner - TOTALLY DEVOID OF LEGAL ARGUMENT - arguing for per account #FBAR penalties because higher penalties would create incentives for Whistleblowers" to report @InFBARWeTrust violations. supremecourt.gov/DocketPDF/21/2… Image
As evidence of the significance of #FBAR violations (and therefore the need to incentivize whistleblowers) the brief cites statistics on the small number of FBARs filed in comparison to the far larger number of #Americansabroad (relying on info from @aaro). ImageImage
The brief seems to advocate that: 1. There is severe #FBAR noncompliance 2. The Government needs whistleblowers 3. Per account penalties will result in higher total penalties 4. The higher the penalty the more likely the whistleblowers will step in to assist the government. Image
Read 8 tweets
John Richardson - lawyer for
Sep 28
2022 FATCA Report: If US doesn't agree to amend #FATCA IGAs to include full reciprocity and respect GDPR (which it won't) options include: 1. Blocking law generally 2. Blocking law for @USAccidental 3. Deem #FATCA inapplicable to European residents period! europarl.europa.eu/RegData/etudes… ImageImageImage
The very last paragraph explains that #FATCA is not in the spirit of multilateral cooperation. Basically it saying that the US is essentially a 100% taken and a 0% giver. But, we know that Image
A "blocking" statute is a law that "blocks" the application of certain laws ... en.wikipedia.org/wiki/Blocking_….
Read 10 tweets

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