June 23 - Pro wing of @Demsabroad hosted @USWealthTax advocate @Gabriel_Zucman: 1. Explains why he DOESN'T agree with CURRENT US @citizenshiptax AND why for MOST #Americansabroad current #CBT NOT justified. 2. Says #FATCA should be replaced with #CRS.
The rest of the discussion generally reinforced @Gabriel_Zucman's commitment to a @USWealthTax - he clearly believes that it is appropriate to "tax the rich". That said, there is no suggestion that this should generally apply to #Americansabroad.
There were some questions focusing on tax simplification and compliance for #Americansabroad. Generally, @Gabriel_Zucman agreed that compliance is far too difficult.
To be clear (my interpretation) many members of the progressive wing of @DemsAbroad clearly do NOT want to sever US citizenship from US @taxresidency. They are generally committed to a "shakedown" of the "rich" (whoever those people may be).
In addition to the @Gabriel_Zucman presentation the concluding discussion (among DA members) is VERY interesting and I strongly suggest listening to the complete video ...

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More from @ExpatriationLaw

Jun 25
Superb article: @Saunderswsj explains generally how inflation leads to higher taxation and specifically the Obamacare 3.8% NIIT. Because foreign tax credits can‘t offset the #NIIT, #Americansabroad pay #doubletax on non-US investment income. The treaty doesn’t protect #expats.
Strongly encourage reading Ms. Saunders - @Saunderswsj - article on how the #NIIT works and how inflation causes it to apply to more people (resulting in #doubletax of #Americansabroad). Link behind paywall wsj.com/articles/niit-…
@Saunderswsj As the @Saunderswsj #NIIT article points out, the Biden Green book proposed expanding the #NIIT to include tax on certain active business income (including partnerships). This would subject #Americansabroad to increase #doubletax. Inflation clearly means more tax for #expats.
Read 9 tweets
Jun 19
All #Americansabroad should listen to Steve Hayes of @FairTaxOfficial where he explains the #FAIRTax. Whether you agree or disagree he makes important points and many observations about the role taxation plays in America. Join movement 4 @FairTaxAbroad!
@FairTaxOfficial @FairTaxAbroad Current tax system is complex, incomprehensible, used to punish some and reward others and has expensive compliance and penalty costs. People don't and can't know how much tax they pay. Compliance costs are a "tax on tax". Here is a poster from the Washington, DC Metro (subway). Image
The #FairTax is a simple consumption based tax. Some describe it as a 30% tax on the purchase price. Others describe it as 23% of the total expenditure. If you spend $100 to purchase an item $77 would be the price and $23 tax. Or see it as $77 + 30% of $77 which totals $100.
Read 12 tweets
Jun 16
Lunch with Jim Bennett (@jbennettatty) of @FairTaxOfficial fame and his wife Christine in Toronto. Jim's visit sparked hope for #Fairtax(ation) in Canada AND USA. @FairTaxAbroad would completely end the US tax nightmare for #Americansabroad. Learn more at fairtax.org Image
Great podcasts with Jim Bennett (@jbennettatty) of @FairTaxOfficial. Learn how the #FairTax helps ALL Americans and expecially #Americansabroad in an #FBAR and #FATCA world! prep.podbean.com/e/rethinking-t…
@jbennettatty @FairTaxOfficial To learn why the #FAIRTax if particularly helpful #Americansabroad see the following discussion ...fairtax.org/videos/358-the…
Read 4 tweets
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
Jun 2
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
Read 4 tweets
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

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