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John Richardson - lawyer for
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Nov 27 • 6 tweets • 3 min read
There is "Only US Territory Without Birthright Citizenship" ... Although entirely arbitrary, those born in this territory are @citizenshiptax free and don't know how lucky they are! nytimes.com/2022/11/25/wor…
As per IRC 931 residents of American Samoa are NOT taxable on income earned in American Samoa. law.cornell.edu/uscode/text/26…
This is a "Same Country Exemption" for income earned by US citizens and Green Card holders who are bona fide residents of American Samoa. But, residents of America Samoa who are are neither US citizens nor US tax residents are taxed as nonresident aliens on US source income.
This means that: 1. A US citizen who is a bona fide resident of America Samoa (a US possession) is NOT tax by US on income earned there. 2. A US citizen who is a bona fide resident of Canada (NOT a US possession) is taxed by US on income earned in Canada. #YouCantMakeThisUp!
IRS commentary on this ... irs.gov/individuals/in…
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More from @ExpatriationLaw

John Richardson - lawyer for
Nov 27
Some Green Card holders and #Americansabroad living in Belgium are like Alice in her "Adventures In Wonderland". You see they have @taxresidency in the USA, but when they move to Belgium they "changed" to NOT being "residents of the United States" and are denied certain benefits.
Note that the standard "saving clause" confirms the right of the countries to tax their "residents" (as defined in Article 4) and "citizens" (without regard to anything). As always, there are certain exceptions to the "saving clause". Here is paragraph 4 of Article 1 ...
Next we move to Article 4 (the usual residency article) and note that US citizens and Green Card holders ARE defined as US tax residents under US law. Therefore, they are presumptively residents of the USA under the treaty ...
Read 5 tweets
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 20
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
Read 4 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

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