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John Richardson - lawyer for
@ExpatriationLaw
Mar 29 • 10 tweets • 8 min read Twitter logo Read on Twitter
Ending @CitizenshipTax would mean fewer #Americansabroad caught in this #FATCA, #FBAR enforcement dragnet. What's truly "criminal" is unwillingness of US Gov to allow US citizens who live outside USA with @TaxResidency in other countries to avoid being caught in this crossfire.
Report goes on and on about Dan Horsky and a "The Family" (US residents) who used Credit Suisse to (presumably) evade US taxes. It concludes a vast conspiracy and uses this to condemn @DualCitizenship (pp 33 - 337)and justify the hiring of more IRS agents. finance.senate.gov/imo/media/doc/…
What is really disturbing is how the Report focuses on US citizenship and NOT residence. This should be of great concern to #Americansabroad. Remember also how dissent by Justice Barrett in the Bittner #FBAR case focuses ONLY on US citizenship with NO other circumstance relevant!
Clearly @SenFinance views US citizenship as a property interest that the government has in the citizen. Citizenship is the primary vehicle to control and punish. #FATCA is FFIs are absolutely correct in cutting ties with any customers with US citizenship - it's not worth the risk
And then we have @SenWarren of "I support @CitizenshipTax" fame who has announced she is running to be reelected in Mass. Even @BostonGlobe readers think this is ridiculous. @TheDemocrats are a clear threat to #Americansabroad and @DemsAbroad should not be trolling for votes.
Bottom line: This report focuses on Horsky and one family. From that argues for increased IRS enforcement, links @DualCitizenship to the problem and pleads for more #FBAR enforcement. @SenFinance should be embarrassed by this.
It would be good if @DemsAbroadTax wrote a public letter to @SenFinance (controlled by @TheDemocrats) asking for an apology to all the patriotic #Americansabroad with @DualCitizenship. Next call you get from @DemsAbroad asking for your vote: Ask what they thin of this report!
Next proposal from @SenateFinance will probably be to follow Russia's law and require reporting of @DualCitizenship under threat of penalties and incarceration. So much of this would be solved by ending @CitizenshipTax! info.stmgroupplc.com/reporting-requ…
As long as this absolute stupidity continues (the whole report is about Dan Horsky and one US resident family): "All Roads Lead To Renunciation!"
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More from @ExpatriationLaw

John Richardson - lawyer for
Mar 29
Canada’s new #FHSA has different kinds. US citizens resident in Canada should avoid those administered by trustee (possibly creating foreign trust for US tax purposes). Stick with the basic “bank account” FHSA with no trustee and no (#PFIC) mutual funds. canada.ca/en/revenue-age…
General features of Canada’s new #FHSA: max contribution $8000 per year and $40,000 lifetime. Contributions tax deductible. Growth in plan not taxable. Distribution not taxable if used to buy first home. US citizens in Canada will need special planning. canada.ca/en/revenue-age…
A ”self-directed” #FHSA is possible which does NOT appear to be a “trust”. This would be good for US citizens (and all CDN residents) who want to invest in individual stocks. US citizens must avoid CDN mutual funds. canada.ca/en/revenue-age…
Read 6 tweets
John Richardson - lawyer for
Feb 17
@RepBrianHiggins launches campaign seeking "carve out" from Canada's @VacantHomeTax for US citizens. He argues that this CDN tax (based on citizenship) violates US/CAN tax treaty and #USMCA. What about US @citizenship tax and #FATCA imposed on CDNs? higgins.house.gov/media-center/p…
Although @RepBrianHiggins is reinforcing the image of "The Ugly American" by his bullying tactics and viewing the world ONLY through his interests, this may be an opportunity to bring a discussion of US @citizenshiptax and #FATCA as applied to CDN residents into public domain.
Read 13 tweets
John Richardson - lawyer for
Jan 18
Post from @1040abroad (includes) attempts to define who is an ”Accidental American” (not defined in US law). US Treasury has made consistent attempts to help them without defining them. How should “Accidental American” be defined? taxconnections.com/taxblog/being-… via @TaxConnections
The first recognition of the problem of "Accidental Americans" is found in the 2015 Obama budget proposal discussed here ... See the screen shots for what was proposed. citizenshipsolutions.ca/2015/02/08/the… ImageImage
The second recognition of the problems of "Accidental Americans" appeared to result in the 2019 "IRS Relief Procedures For Former Citizens" as discussed here ... citizenshipsolutions.ca/2019/12/18/irs… ImageImage
Read 9 tweets
John Richardson - lawyer for
Dec 31, 2022
Notice 2023-11: Temp relief provided to banks under Model 1 #FATCA IGAs who can't provide SSN numbers of #Americansabroad ("preexisting accounts only") if the gov joins banks in taking specific steps to educate individuals about FATCA + @citizenshiptax. home.kpmg/us/en/home/ins…
Purpose of Notice 2023-11 is to ensure that banks in a Model 1 #FATCA jurisdiction won't be deemed to be "non-compliant" with the IGA if they can't provide a US SSN for "pre-existing accounts". The notice can be accessed and read in its entirety here ... irs.gov/pub/irs-drop/n…
Step 1: The relief is available to the banks in a Model 1 #FATCA IGA jurisdiction and ONLY if the government of the jurisdiction commits to engaging with (1) individual US citizens (2) the banks and (3) US Treasury to facilitate compliance.
Read 17 tweets
John Richardson - lawyer for
Dec 30, 2022
Lots of discussion on "reciprocity" question. What does "reciprocity" mean? Q. Is it possible for there to be "reciprocity" when "obligations" are in the form of an agreement (possible contract) or where the contract is the result of duress? Consider the following examples ...
What if Mr. A makes Mr. B "an offer he can't refuse"? Mr. B agrees to the obligation. Is this "reciprocal" or is this an agreement under duress? Can one really say this "classic" staple of American culture - is an example "reciprocity? Is it thuggery?
A second example ... neither Roxie nor Mamma Morton is behaving in a spirit of kindness/generosity. What is called "reciprocity" is about avoiding sanction (which is why all governments entered into #FATCA IGAs).
IRC 1471 imposes sanctions. Reciprocity?
Read 10 tweets
John Richardson - lawyer for
Dec 29, 2022
Excellent article by @HelenBurggraf explaining that the new Argentina IGA (like previous #FATCA IGAs) is NOT reciprocal. An earlier and lengthy expose explaining in detail why #FATCA IGAs are NOT and likely will never be reciprocal agreements is here ... citizenshipsolutions.ca/2022/07/24/the…
The remarks from Ambassador Stanley are clearly designed to suggest the US Argentina #FATCA IGA is "reciprocal". Whether by accident or design this statement is not accurate.
It is useful to examine the exact text of the US Argentina #FATCA IGA to determine what Argentina is required to do and what the US is required to do and decide whether the agreement is reciprocal. home.treasury.gov/system/files/1…
Read 10 tweets

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