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Canada's new "citizenship by descent" law will benefit many U.S. citizens in unanticipated ways

Introduction and purpose of this post https://x.com/ParvizMalakouti/status/1836492693826081022 In response to a 2023 Canadian court decision the Government of Canada is enacting a new law which will create an opportunity for certain U.S. citizens to become Canadian citizens at birth. Not only will this give them the usual benefits of citizenship (right to live and work in Canada), but it will…

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Expanding eligibility for Canadian citizenship: Bill C-71 opens up a possible never-ending chain of citizenship

Bill C-71 opens up a possible never-ending chain of citizenship by Policy Options. Originally published on Policy Options July 8, 2024 Bill C-71 sets out to allow Canadians to pass on their citizenship to any of their children born abroad past the first generation and expands “Lost Canadians” to cover a much larger number than before. It is fraught with potential unintended consequences. The bill…

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Town Halls: @RepOverseasTax Introduces Its Tax Proposal For Americans Abroad And Invites Discussion

There are two sessions coming up – both on X.com Tuesday September 17: North America https://twitter.com/RepOverseasTax/status/1834257645886177584 https://x.com/RepOverseasTax/status/1834257645886177584 Rest Of World Set a reminder for my upcoming Space! https://t.co/1kIvy7YJyK Join us to discuss our RBT proposal! — RepOverseasTax (@RepOverseasTax) September 12,…

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Instructions For Those Who Have A NEXUS Card And Are Renouncing U.S. Citizenship

Introduction and purpose Everything you need to know about NEXUS and Global Entry, but didn't know you should ask. https://t.co/YYIXx5ZvMx — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) August 28, 2024 I continue to assist many people with the relinquishment and renunciation of their U.S. citizenship. Many of the people who I assist live in Canada and have NEXUS cards…

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"Saving Clause" In U.S. Mexico Tax Treaty Informs Meaning Of "Renounced U.S. Citizenship For The Purpose Avoiding Taxation By The United States (Reed Amendment)"

Summary and purpose: This post is a continuation of my posts about the “saving clause” in U.S. tax treaties. For an introduction to the “saving clause” see: Croatia Agrees To Allow The US To Impose Tax, Forms And Penalties On Its US Citizen Residents This post will also identify how the 2003 Protocol to the U.S. Mexico tax treaty makes expatriation with an “intention to avoid taxation”, relevant…

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Moving From Canada To The USA? If You Owe Money To The Canada Revenue Agency - Will The IRS Collect For Canada?

A quick post based on the following tweet … CDN citizen moves to US with outstanding CDN tax debt. US collects tax debt for Canada under treaty. But, if the CDN had dual CDN/US citizenship then the treaty would preclude the US from assisting Canada. Worth remembering if considering renunciation. https://t.co/StMrGCPaIS — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw)…

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Renunciation of U.S. Citizenship And Taxation Of U.S. Social Security Benefits

Keeping it shot and sweet … Yesterday I had a conversation about renouncing U.S. citizenship. The personwas living almost entirely on U.S. Social Security benefits. The individual had not considered how renunciation (becoming a nonresident alien for U.S. tax purposes) might affect the U.S. taxation of Social Security benefits. In many cases renouncing U.S. citizenship (or abandoning the Green…

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US Tax Residency For Canadian Snowbirds: First You have It! But On Closer Connection You Don't

Question For Americans Abroad: Did you know that you can renounce your U.S. citizenship and then live up to 182 days in a year in the United States and not be taxable by the United States or have to file forms (including FBAR)? Read on!! – it’s all about having a “closer connection” to another country! Introduction – What is tax residency? Tax Residency – Who is subject to taxation? Individuals…

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All U.S. citizens relinquishing U.S. citizenship are required to be reported in the Federal Register "Name And Shame" list

Purpose of this post: The "Name And Shame List". The Federal Register publishes a list of some but not all of the names of individuals who renounced U.S. citizenship. What does if mean when someone is on the list? Is inclusion on the list a sign of wealth? Check it yourself! https://t.co/D8QOwzPzrZ pic.twitter.com/rFgz6ACtXx — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw)…

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Fahry Appeal Court Rules IRC 6038(b) Is An Assessable Penalty Without Regard To IRC 6201

Prologue: The Fahry decision in the Tax Court Per Arnold Porter: “Many penalties related to income tax filings are not assessable penalties. The IRS took the position that Section 6038 penalties are assessable penalties under IRC Section 6201(a). Farhy argued that the IRS had no authority for treating Section 6038 penalties as assessable penalties. The Tax Court agreed with Farhy, reasoning that…

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Why Treasury Should Exempt U.S. Citizens Living In Other Countries From FBAR Filing

OMB Control No: 1506-0009 / ICR Reference No: 202403-1506-001 / Federal Register: 2024-06697 Reports of Foreign Financial Accounts Regulations and FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) Outline: Part I – Introduction and Context- Understanding The April 29, 2024 Deadline For FBAR Commentary Submissions Part II – Comment: Statement Of Purpose Part III – Looking For…

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Monte Silver's Lawsuit Opposing The Procedural Aspect of #GILTI Regs Lives On

In summary – Monte Silver’s lawsuit against GILTI lives on! On April 19, 2024 the U.S. Court Of Appeals released a decision which included: Plaintiffs had objected before the district court that the Anti-Injunction Act did not apply in light of South Carolina v. Regan, 465 U.S. 367 (1984), because they had no other way to litigate their claims. The defendants argued that the Act barred the suit…

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Americans Abroad Have Until April 29, 2024 To Tell FinCEN Why They Should Be Exempt From FBAR

2012 – Looking For Mr. FBAR A 2016 blog post at the Isaac Brock Society noted that the Bank Secrecy Act give the U.S. Treasury that the full power to exempt Americans abroad from the FBAR requirement but has deliberately and consciously chosen not to. The 2016 post references an excerpt from the 2011 Federal Register which includes: With respect to the comments raised by United States persons…

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FATCA Is Not the Answer

Reposted from SEATNow.org. Are #americansabroad all #FATCA ts? Some think they are + should be punished for it. Our response "FATCA Is Not the Answer:" https://t.co/g0PT2aw8ei… #taxtwitter #citizenshiptax #HumanRights @ExpatriationLaw @FixTheTaxTreaty @TAPInternation — SEATNow.org – Stop Extraterritorial American Tax (@SEATNow_org) April 1, 2024 On February 26, 2024, Tax Notes Federal published…

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Considering Renunciation Part 2: Recognizing And Overcoming The Emotional Barriers

I recently wrote a post describing some of the objective tax, immigration and financial planning issues surrounding the renunciation of U.S. citizenship. For all people tax and financial planning issues should be objectively considered. But objective issues can take one only so far. We are all individual human beings who experience the world differently. We all ascribe various degrees of…

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Considering renunciation? The Problem is HOW To Make The Renunciation Decision

To Renounce Or NOT To Renounce: The Problem is HOW To Make The Renunciation Decision – @Expatriationlaw and @MyLatinLife #Podcast https://t.co/Y8GkuHMlTH — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) February 5, 2024 For Americans U.S. citizenship is an asset that depreciates with age. Obviously U.S. citizenship is more valuable for younger people beginning their…

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Aroeste v. United States - November 2023

Aroeste-v-United-States-Order-Nov-2023