John Richardson - lawyer for
#FATCA is: The USA should not impose worldwide taxation on people who are tax residents of and live in other countries.- DM's open - expatriationlaw@outlook.com
K Daruma Profile picture John Richardson - lawyer for 3 added to My Authors
Aug 7 6 tweets 14 min read
@AmerIronCurtain @BlognDog @AmExpatFinance @CrossBriton @tconsult @ACAVoice @CitizenshipTax 1. Look at the various lawsuits. Not a single one so far is focussed on ending @Citizenshiptax. 2. Look at @Demsabroad and @ACAVoice - neither has the slightest interest is severing citizenship from @taxresidency. 3. Individuals follow the various orgs. ... @AmerIronCurtain @BlognDog @AmExpatFinance @CrossBriton @tconsult @ACAVoice @CitizenshipTax @DemsAbroad @TaxResidency 4. Complexity: Very difficult to understand all the moving parts and how they integrate. 5. Unbelievable ignorance of the the tax compliance community (making claims like treaties prevent double tax and this form is only an information return which doesn't result in tax owing ...
Jul 27 8 tweets 4 min read
Space the final frontier. These are the voyages of the Star Ship Enterprise, it's five year mission to explore strange new worlds, to seek out new "individuals" to "Boldly Go" where no definition of @taxresidency has gone before The USA tax base is composed of "individuals". Will any carbon life form suffice? "Individuals" include, but are not limited to "residents".
Jul 26 12 tweets 9 min read
In 2022 a "Message in a bottle" from 2013 washes up on the shore as a reminder of US Treasury's " Myth vs. #FATCA isaacbrocksociety.ca/2013/09/20/fro… Walking further down the shoreline, I found a second "Message In A Bottle" - Circa 2015. A 192 page book documenting the "Facts" exposing US Treasury's 2013 "#FATCA Myths" (AKA "Stack-Of-Lies) which continue to this present day. Have a look at this. citizenshipsolutions.ca/wp-content/upl…
Jul 24 9 tweets 16 min read
@AccidentallyUSC @ConnecterIO @SEATNow_org "Uniting and organizing" assumes commitment to a principle that will allow all Americans to live ordinary lives. The ONLY thing that solves the problems of all people, all the time under all circumstances is ending @citizenshiptax -severing US citizenship from US @taxresidency. @AccidentallyUSC @ConnecterIO @SEATNow_org @CitizenshipTax @TaxResidency As long as #Americansabroad think in terms of solving "their problem" rather the "the problem" change is not possible. Everybody supports some specific change that helps them but leaves other problems intact. H.R 6057 - which helps some people - is a most insidious example.
Jul 17 6 tweets 4 min read
A Simple Regulatory Fix For The #FATCA (banking and other) problems for "some" #Americansabroad and others with @dualcitizenship from birth. citizenshipsolutions.ca/2021/06/29/a-s… via @expatriationlaw The obvious group that could benefit from this would be @USAccidental
Jul 12 28 tweets 19 min read
A recent archeological/twitterological dig uncovered a historical artifact from the Carter years (1977 - 1981) titled "Equitable Treatment by United States of Its Citizens Living Abroad" - a curious thing from a curious time. law.cornell.edu/uscode/text/22… The first law was Public Law 95 - 426 which became law on October 7, 1978. Sec. 611(a) and 611(b) of the "Foreign Relations Authorization Act, Fiscal Year 1979" created a law which acknowledged the existence and value of #Americansabroad. Specifically the mandated ...
Jul 7 15 tweets 6 min read
Next up Candidate Patel ... He says that he has had the personal experience of being double taxed as an American abroad. But, he first wants to discuss the principles of a "Liberal Democracy". Says, Trumpism is on the rise ...
Jul 7 11 tweets 6 min read
Listening to Congressman Maloney who was just asked whether she supports residence-based taxation. She went on for a while and at no time did she say that she supported a move to residence-based taxation. I think it's pretty clear that she does NOT support ending @citizenshiptax. A second question about taxation of overseas Americans. Rep Maloney commits to a commission or hearing studying #Americansabroad, but again: she will not commit to support the ending of @citizenshiptax and severing citizenship from @taxresidency.
Jun 26 5 tweets 8 min read
@AmerIronCurtain @NicklesLee @Keith__REDMOND @DemsAbroad @ACAVoice HR 5799 absolutely does NOT ease access to checking accounts for US citizens. Two points: 1. The Bill clearly states the banks can opt out. 2. The current #FATCA have exactly the same provision for depository accounts that do NOT exceed $50,000. See why: @AmerIronCurtain @NicklesLee @Keith__REDMOND @DemsAbroad @ACAVoice The most that HR 5799 could do is: 1. Potentially (if the banks will go along with it) for #Americansabroad to have depository accounts in excess of $50,000 USD and 2. To NOT be required to report those depository accounts on their individual #FATCA form 8938.
May 29 11 tweets 11 min read
Podcast: @Amy_From_Sydney and @Expatriationlaw discuss the dwindling prospects of a political solution to @citizenshiptax and the indifference @Demsabroad showed for #Americansabroad by failing to consider the @Demsabroadtax proposal for #FATCA repeal. Good news: @Demsabroadtax had the courage to propose #FATCA repeal/resolution to @Demsabroad as a whole. Bad news: At their May 22/22 meeting DA failed to consider the issue demonstrating total indifference to the plight of #Americansabroad.
May 24 7 tweets 3 min read
A post of particular relevance for those #Americansabroad who have activities that may require international info returns (5471, 3520, 3938, etc). Make sure that your tax preparer has an expertise in this specific area. See post from @TaxConnections ... taxconnections.com/taxblog/irs-ta… The US clearly sees penalties as an important and deliberate "form" (pun intended) of raising revenue. A cynic might say that Treasury wants to be able to levy penalties. See this interesting excerpt ... Image
May 21 7 tweets 3 min read
In the 1700s Adam Smith wrote "The Wealth Of Nations" - the great powers (France and the USA" understood that to mean "The Wealth Of OTHER Nations. Here is "Confiscation: Haiti Edition" nytimes.com/interactive/20… nytimes.com/2022/05/20/wor…
May 17 12 tweets 6 min read
From @HelenBurggraf - taken to it's conclusion means that US citizens should renounce in order to avail themselves of the benefits of being a #nonresidentalien which include parking money in the USA away from the prying eyes of the rest of #CRS world. americanexpatfinance.com/news/item/971-… Q. How can nonresident aliens (not US citizens or residents) use the USA as a privacy jurisdiction? Why does @TaxHavenUSA exist? A. Because, as noted by @TaxJusticNet, the USA as refused to join the Common Reporting Standard which requires reciprocal exchange of information.
May 5 11 tweets 3 min read
The more complex the system of laws, the more likely it will result in unfairness ... “How is he going to manage alone?” Mr. Ganesan said. “I was really devastated that just because of my country of birth, my son’s opportunities are very limited.” nytimes.com/2022/04/30/us/… Barack Obama once claimed: "The circumstances of your birth should not determine the outcome of your life." One more example of individuals being victimized by the complexity of a system of laws (probably applying in ways that were never intended).
Apr 18 11 tweets 12 min read
Interesting message from @EWarren indicates a "carve out" from @TheDemocrats core values for #Americansabroad (who actually are "working people" not mini-multinationals). Perhaps @DemsAbroadTax could educate @SenWarren about @CitizenshipTax and #FATCA. nytimes.com/2022/04/18/opi… Exhibit A: "Standing up for the inherent dignity of everyone is a core American value, and Democrats are proud to do that every day."
Apr 15 7 tweets 3 min read
Should the income tax be a "class tax" or a "mass tax"? - "Not Enough Americans Pay Income Tax. Should They?" via @YouTube Apparently approximately 50% of US residents pay no income tax. Is this an argument for ending the income tax and moving to something more akin to a "mass tax" like @FairTaxOfficial?
Apr 11 9 tweets 4 min read
Senators @RonWyden and Rob Portman propose legislation that (among other things) suspends the exchange of #FATCA information (which the US doesn't provide anyway) with Russia. finance.senate.gov/imo/media/doc/… An interesting example of the US tax code being used as a method of @Sanctionslaw. With respect to US taxpayers subject to taxation by Russia: 1. No FTCs allowed 2. If not a CFC, income subject to tax by Russia is deemed to be CFC/Subpart F income - ensuring tax at high US rate.
Apr 10 4 tweets 2 min read
The Play: "Act 1 - To have UK @taxresidency (allowing her to be a treaty nonresident for US tax purposes and avoid US tax on non-US source income). Act 2 - To not be UK domiciliary (non-dom status allows for the avoidance of UK tax on non-UK income)." theguardian.com/politics/2022/… dailymail.co.uk/news/article-1…
Apr 7 35 tweets 14 min read
In 21st century the most interesting thing about a person is his/her @TaxResidency. For UK residents "non-dom status means #territorialtax! For UK doms there is #worldwidetax and #RBT. For US citizens there is #worldwidetax, @CitizenshipTax and #FATCA. theguardian.com/politics/2022/… .@TaxResidency is often confusing and often has a huge impact on ones life. In simple terms, you are a #taxresident of a country which has the right to impose the full force of its tax rules on you. This is different from HOW and on WHAT sources of income tax residents are taxed.
Apr 6 16 tweets 5 min read
Let's start with the "self evident truth" that US citizenship - conferred mostly by birth and the US constitution - has attributes making it superior to other citizenships. What are those attributes? What obligations/rights do they imply? Voting? Taxation? Military service? ??? Recent discussions have identified voting and taxation as inseparably linked with US citizenship. Many have suggested that voting, taxation and the rights and obligations of citizenship are somehow linked. Is this true? Was it ever true? What is the source of a right/obligation?
Apr 5 14 tweets 5 min read
Good @DemsAbroadCan podcast with @AbroadRebecca about US @citizenshiptax. Would be interesting to host Rebecca and @MaxSteinerCA together to discuss: "Should taxation be an incident/characteristic of US citizenship?" open.spotify.com/episode/71oy7e… "To Whom much has been given, much is expected." Perhaps exceptional citizenship implies exceptional obligations. But, what is it about US citizenship that makes it so exceptional?