citizenshipsolutions

[citizenshipsolutions]

Shedding Light On The U.S. Citizenship Tax System And Prospects For Reform In Australia And More: Latife Hayson and Seth Hertz

Reproduced from SEATNow.org Introduction and purpose In the summer of 2025 Latife Hayson of The Interchange, an Australian living in the United STates included an episode about U.S. citizenship taxation. Although mainly from an Australian perspective, the video (and shorts) will be of interest to U.S. citizens living all over the world. Full Video: US Expat Tax Explained: Navigating Citizen-Based…

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From The OVDI Trauma Of 2011 To The Continuing Trauma Of U.S. Citizenship Abroad Today

"From The OVDI Trauma Of 2011 To The Continuing Trauma Of U.S. Citizenship Abroad Today" During the last week of August of 2011, many #Americansabroad were living in a state of terror. It's 14 years later. What has changed?https://t.co/M3Jhz3Sqnd — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) August 26, 2025 Prologue – August 2011 Today is August 26, 2025. This coming…

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Sacred Trust: Counseling Americans Abroad Through The Trauma Of A FATCA World

Introduction: Much of living as a U.S. citizen abroad is learning to cope with a life of trauma. Posts discussing the trauma are here and here and here. The U.S. extra-territorial tax, form and penalty regime reminds Americans that they are: “Subject to certain penalties, for uncertain conduct!” Those who do not file tax returns worry about the consequences of not filing. Those who do file tax…

[citizenshipsolutions]

Tax Law Professors Mason and Dagan: "Reconsidering Citizenship Taxation"

Introduction and purpose In 2010 few people even knew what citizenship taxation was. It is now 2025. Awareness of the existence of citizenship taxation has expanded. An understanding of WHAT citizenship taxation actually is (it’s the the U.S. applying its worldwide tax, reporting and penalty regime on non-U.S. source income received by nonresidents) and how the impacts the lives of Americans…

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Dan Duggan Part 2 - For The Sake Of Its Citizens And Sovereignty Australia Must Terminate The Extradition Treaty With The United States

Introduction and purpose: The US sees extradition treaties as a way to facilitate (at the cost of the treaty partner country) the application and enforcement of US law in an extraterritorial manner. The Duggan case is one such example. No country should sign an extradition treaty with the USA. — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) August 4, 2025 This is the…

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Seeking Testimonials From Americans Abroad Who Have Subjected To Double Taxation

To U.S. Citizens Residing Outside The United States Re: Continuing Efforts Of Republicans Overseas To End The Double Taxation Of Americans Abroad Republicans Overseas continues to (1) recognize President Trump’s commitment to end the double taxation of Americans abroad and (2) remains committed to the goal of ending this double taxation. The goal cannot be achieved without the support and…

[citizenshipsolutions]

Part 3: The Hurd Bill – H.R. 4501 May Not Be Based On The Problems Of U.S. Citizenship Taxation And Americans Abroad

Commentators may be misreading the motivation for H.R.4501 It’s human nature to view and interpret the world based on our own experiences. Therefore, many Americans abroad (and their advocacy groups) interpreted the Hurd bill H.R.4501 as a sign that Congressman Hurd recognized the problems of citizenship taxation. This may not have been true. I now believe that H.R.4501 may have been an attempt…

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John Richardson Opening Statement May 14, 2014 - House Of Commons FATCA FINA Committee Meeting

Purpose and introduction: Prior to Canada’s implementation of FATCA on July 1, 2014, the Canadian parliament held hearings. The hearings took place over two days in May of 2014. I appeared as a witness on Mary 14, 2014. What follows is a transcript of my opening statement. I think I would say the same thing today. https://www.ourcommons.ca/DocumentViewer/en/41-2/fina/meeting-35/evidence The Chair…

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Part 2: The Hurd Bill - H.R. 4501 Does NOT Protect Pope Leo From FBAR (And FATCA) Reporting

Part A – Purpose and Summary: This is my second post on H.R. 4501. My first post was a general introduction and is here: Colorado Congressman Jeff Hurd Recognizes Problems Of U.S. Citizenship Taxation The purpose of this post is to argue that H.R.4501 does NOT protect U.S. citizen Pope Leo from the invasive reporting obligations which are at the heart of what it means to be a U.S. citizen. The…

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Colorado Congressman Jeff Hurd Recognizes Problems Of U.S. Citizenship Taxation

Part A – Introducing H.R. 4501 Representative Jeff Hurd(CO-3), who is a Catholic, has introduced the Holy Sovereignty Protection Act H.R. 4501 to the US House of Representatives. The bill would prevent the United States from revoking the citizenship of any American elected Pope or taxing a sitting Pope. pic.twitter.com/hTQ530p7HE — Ted ☦️🐒 (@Tawadros15) July 29, 2025 H.R.4501 – To protect the…

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Accidental Americans, FATCA, The GDPR And The Netherlands Decision Of July 25, 2025

Prologue – It’s not about FATCA. It’s about U.S.citizenship taxation Toward An Argument That US Citizenship Taxation Violates International Law Captain Ronald Aries and the Dutch Accidental Americans On May 19 2025 a Netherlands court held a hearing to determine whether Article 18 of the GDPR prevented the transmission of the banking information of Accidental Americans to the IRS (as mandated by…

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U.S. Australian Tax Treaty: 1974 Original Treaty And 1997 Protocol

Introduction and purpose: The purpose of this post is to consolidate the 1974 Australian U.S. extradition treaty and the 1997 protocol to have the provisions in one place. Extradition is complicated. Changes in the law of one country can affect whether the extradition may apply. For example, here is a situation where a chnage in Mexico’s laws impacts whether the U.S. has rights of extradition…

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Effect Of The New "Seniors" $6000 Deduction On Americans In Canada

Summary: Part I – Possible payment of U.s. tax 1. The $6000 is per person and is an additional deduction from income. 2. In Canada: U.S. Social Security, Canada Pension Plan, OAS and certain other pensions are taxed ONLY by Canada. See the U.S./Canada tax treaty – Article XVIII 3. This means that a U.S. citizen living in Canada who is a “Senior” effectively has (explained by the AARP as…

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Update: 899 Penalty Tax Will NOT Go Forward - Secretary Bessent Claims Mission Accomplished!

Prologue I have written about the proposed IRC S. 899 Tax titled: “Enforcement Of Remedies Against Unfair Taxes” Take YOUR Money And Run: Understanding The Proposed § 899. ENFORCEMENT OF REMEDIES AGAINST UNFAIR FOREIGN TAXES The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship It now appears that the S. 899 tax will NOT be included in the “Big…

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The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship

Introduction – It’s The American (A)Way The United States tax system is designed to impose punitive tax, reporting and penalties on the non-U.S. income and assets of Americans abroad. Nonresident aliens (those who are neither U.S. citizens nor residents) are taxable ONLY on their U.S. source income. This reality has driven many U.S. citizens (living abroad) to renounce U.S. citizenship. It also…

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Highlights of @HelenBurggraf's American Expat Financial News Journal (2018 to 2023)

Introduction As the late Charles Adams would say: “As goes taxation, so goes civilization”. Helen Burggraf’s American Expat Financial News Journal (archived here) was an online newspaper/blog that existed from 2018 to 2023. It contained a wide range of articles – covering a wide range of topics – and reflected the frustrations of Americans abroad. Most of the site can be found at…

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Senate Finance Committee Response To The "Remittance tax" Proposed In The "Big Beautiful Bill"

Here is how I interpret the Senate proposed rules for the remittance tax found on page 388 of the Senate Bill (responding to the "Big Beautiful Bill"):https://t.co/KvSqazYSIu An overall reading confirms that the principle that: "It's expensive to be poor (and unbanked)." pic.twitter.com/pFOPkmdR1i — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) June 18, 2025 The Senate…