Share this page!

Enter Twitter Thread URL to Unroll

Needs to be the full URL like: https://twitter.com/threadreaderapp/status/1644127596119195649

How to get URL link on Twitter App

  1. On the Twitter thread, click on or icon on the bottom
  2. Click again on or Share Via icon
  3. Click on Copy Link to Tweet
  4. Paste it above and click "Unroll Thread"!
  5. More info at Twitter Help
John Richardson - lawyer for
@ExpatriationLaw
Jun 2 • 4 tweets • 4 min read Twitter logo Read on Twitter
How will the US respond to Belgium's claim that the #FATCA IGA violates the #GDPR? Here is my proposal for ending the tax treaty #savingclause which would allow @USCitizenAbroad to become treaty nonresidents for US tax (effectively ending @CitizenshipTax). youtube.com/live/KqtFhae4i…
See the "third solution" in the thread below which discusses a number of responses/solutions to this #FATCA and @CitizenshipTax problem
More questions answered about Belgium, #FATCA, #GDPR and @CitizenshipTax ...
@threadreaderapp unroll

• • •

Missing some Tweet in this thread? You can try to force a refresh
　

Keep Current with John Richardson - lawyer for "U.S. persons" abroad

John Richardson - lawyer for

Stay in touch and get notified when new unrolls are available from this author!

Read all threads

This Thread may be Removed Anytime!

PDF

Twitter may remove this content at anytime! Save it as PDF for later use!

Try unrolling a thread yourself!

how to unroll video
  1. Follow @ThreadReaderApp to mention us!

  2. From a Twitter thread mention us with a keyword "unroll"
@threadreaderapp unroll

Practice here first or read more on our help page!

More from @ExpatriationLaw

John Richardson - lawyer for
Jun 2
How #FATCA IGAs relate to legislation in IRC: To be consistent with FATCA law and avoid the 30% US sanction, IGAs must require the FFIs to close the account of "US Persons" who fail to supply required data (without regard to local #GDPR law). Solutions? law.cornell.edu/uscode/text/26… Image
US #FATCA can accommodate Europe's #GDPR only by by excluding @USCitizenAbroad with @TaxResidency abroad from the definition of "U.S. Person". These two screen shots illustrate the problem ... Some thoughts on how this might this be achieved. law.cornell.edu/uscode/text/26… ImageImage
As the @DemsAbroadTax statement and @SEATNow_org states/implies this problem can be solved ONLY if the US joins the world in adopting residence as the criterion for @TaxResidency. Citizenship would no longer be relevant for taxation. NOT part of any current legislative proposal.
Read 6 tweets
John Richardson - lawyer for
Jun 1
@AmerIronCurtain asks: 1. What would it take for Belgium to get out of the #FATCA IGA? 2. What would it take to get out of the #savingclause? 3. Does the Belgium decision mean that the #FATCAIGA is illegal? Interesting questions ...
1. Article 10 of #FATCA IGA contains a notice provision that allows each country to withdraw from the agreement. But, withdrawing from the agreement leaves Belgium "subject" (pun intended) to the direct application of FATCA rules in the IRC (1471 - 1474) home.treasury.gov/system/files/1… Image
2. Par 4 of Article 1 of US/Belgium treaty contains #savingclause. Belgium agrees US can tax US citizens (with exceptions) regardless of treaty. Change requires treaty amendment. But US could suspend and allow US citizens to be treated as nonresidents. irs.gov/pub/irs-trty/b… Image
Read 7 tweets
John Richardson - lawyer for
May 30
An intelligent response which reinforces the #FATCA (sorry fact) that that the real problem is US @CitizenshipTax. The Decision in Belgium underscores that the sole purpose of the FATCA IGAs is to ensure Americans cannot leave the USA and acquire rights denied to US residents.
As the @DemsAbroadTax statement states/implies this problem can be solved ONLY if the US joins the world in adopting residence as the criterion for @TaxResidency. Citizenship would no longer be relevant for taxation. But, this is NOT part of any legislative proposal.
A second solution would be “A Regulatory Fix For Citizenship Taxation” Which would define “individual” as resident. As published by @TaxNotes here … taxnotes.com/featured-analy…
Read 12 tweets
John Richardson - lawyer for
Mar 29
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!
Read 10 tweets
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

Did Thread Reader help you today?

Support us! We are indie developers!

This site is made by just two indie developers on a laptop doing marketing, support and development! Read more about the story.

Become a Premium Member ($3/month or $30/year) and get exclusive features!

Become Premium

Don't want to be a Premium member but still want to support us?

Make a small donation by buying us coffee ($5) or help with server cost ($10)

Donate via Paypal

Or Donate anonymously using crypto!

Ethereum

0xfe58350B80634f60Fa6Dc149a72b4DFbc17D341E copy

Bitcoin

3ATGMxNzCUFzxpMCHL5sWSt4DVtS8UqXpi copy

Thank you for your support!

Follow Us on Twitter!

Send Email!

:(