Former IRS Leaders Endorse Residency-Based Tax For Americans Abroad

Nearly a year ago, in the waning days of the 118th Congress, Representative Darin LaHood (R-IL) introduced a groundbreaking piece of legislation that sent ripples through the expatriate community and the international tax world: the Residence-Based Taxation for Americans Abroad Act (H.R. 10468). As I detailed in my earlier Forbes article, this bill represented a bold step … Continue reading Former IRS Leaders Endorse Residency-Based Tax For Americans Abroad →

FATCA 11 Years Later – US Still the Tax Haven?

Since the passage of the Foreign Account Tax Compliance Act (FATCA) in 2010, we’ve been inundated with mountains of information about this legislation including its implementing Treasury Regulations, Internal Revenue Service (IRS) announcements and notices, reams of articles, books, blog postings as well as a Twitter-verse awash with FATCA-esque tweets. Following FATCA’s roll-out, hordes of … Continue reading FATCA 11 Years Later – US Still the Tax Haven? →

Expatriation: Deferring Payment of the Exit Tax

I recently blogged about the debate between Prof. Edward Zelinsky and John Richardson as it pertained to the Exit Tax imposed on so-called "covered expatriates". This was in the broader context of the US income taxation model which is based on one's "citizenship" rather than one's residence. The thrust of my earlier blog post concerned … Continue reading Expatriation: Deferring Payment of the Exit Tax →

Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation

Recently, a debate took place on the merits of the United States' income tax regime which is based on "citizenship". This lively debate was between the esteemed John Richardson (a US and Canadian attorney) and Professor Edward Zelinsky (a tax scholar and professor at Cardozo Law School in New York City). You can watch the … Continue reading Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation →