When flying over international waters or on a cruise ship in international waters, US citizens are indeed subject to double taxation bc and only bc of US citizenship. Explained by @1040Abroad and @Expatriationlaw here … citizenshipsolutions.ca/2022/01/20/air…
To clarify it is US citizens with @taxresidency in another country that are subject to #doubletaxation. Think pilots, cruise ship employees and #Americansabroad who work on the plane. See this podcast with Jim Gosart of @RepOverseas where we discuss.
The #doubletaxation of income earned in intl waters is one more consequence of @citizenshiptax and another example of how #Americansabroad are taxed more punitively than US residents. Here is a series of podcasts with @RepOverseas explaining the problems citizenshipsolutions.ca/2021/11/30/rep…
US @citizenshiptax (enforced by #FATCA) is a system that taxes people based on WHO they are rather than WHERE they are. Only a complete severance of citizenship from @taxresidency will solve the problems of all people, all the time and under all circumstances.

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More from @ExpatriationLaw

Dec 9
.@NYTimes author @AmandaTaub discusses Brittney Griner trade for Victor Bout. The following excerpt suggests Russia may not see the trade as "an arms dealer for a minor drug offender". Russia may see the trade as securing the return of a person victimized by unfair US process.
@nytimes @amandataub The recent @AmandaTaub article referenced in above tweet is here ... …saging-custom-newsletters.nytimes.com/template/oakv2…
Interesting discussion of the Victor Bout charge and trial here ... latimes.com/world/la-xpm-2…
Read 7 tweets
Dec 4
Almost all victims of the US extraterritorial tax AKA @citizenshiptax regime (enforced by #FATCA) agree that the practice of the US defining @taxresidency based on the "status" of citizenship alone must end. The plea is: End @citizenshiptax (enforced by #FATCA) and adopt #RBT.
When an organization or individual says they support #RBT or a political party includes #RBT in their platform, you must ask EXACTLY what do they mean by #RBT (Residence-based taxation)? Does their proposal leave citizenship in any way relevant to @taxresidency, #FATCA or #FBAR?
Do advocates of #RBT mean simply supporting a kinder more gentle (Eritrea style) of @citizenshiptax or do they mean making citizenship irrelevant to @taxresidency? Would #Americansabroad still remain US tax residents or do they cease having US @taxresidency for all purposes?
Read 27 tweets
Dec 2
Fifth Circuit Upholds Constitutionality of Passport Revocation Statute procedurallytaxing.com/fifth-circuit-…
Apparently this "tax debt" was the result of a penalty for failing to file a Form 3520 to report a "foreign trust". #Americansabroad should be concerned. Clearly in America ALL rights are becoming subordinate to the tax and penalty regime. But, see the following comment ... Image
The gist of the decision which should be deeply troubling. Bottom line: Mr. Franklin's passport was revoked because he failed to file a 3520 reporting a foreign trust ... ImageImage
Read 6 tweets
Nov 27
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.
Read 6 tweets
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
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

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