This post is a sequel to "Expatriation – Giving up US Citizenship – Will I be Banned from Re-entering the USA?" my earlier blog post analyzing the so-called "Reed Amendment". As discussed in that post, since the statutory language of the Reed Amendment applies only to those who “officially renounce” United States citizenship it may be … Continue reading Divorcing the United States: Two Methods – Renunciation and Commission of an Expatriating Act with “Intent”
Well, the numbers of individuals renouncing US citizenship is apparently reaching epic proportions. It has been reported that 5,816 Americans gave up their citizenship in the first six months of 2020 and that this represents a 1,210% increase from the prior six months ending December 2019, when only 444 cases were recorded. Most clients I … Continue reading Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?
“Foreign” pension or similar plans are a very common feature in the lives of US expats residing and working abroad. As used here, the word “pension” is only a general term. While pensions in the United States often refer to defined benefit retirement plans, my use in today’s blog post refers to a pension as … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part I)
2020 looks promising in more ways than one. First, on a professional level I was delighted and proud to be named, for the 4th year running, to Forbes Top 100 Must Follow Tax Twitter Accounts for 2020. Please do encourage your friends and colleagues to follow me on Twitter and to subscribe to my US … Continue reading Expatriated? But Failed to File Form 8854? IRS Provides a Fix!
In September 2019, the Internal Revenue Service (IRS) announced new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished (or are relinquishing) their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed; nor will … Continue reading IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?
Well, if my dream last night has anything to do with reality, the world is in for a big shakeup. In my dream, President Trump came to me for US tax advice on expatriation - that is giving up one's US citizenship (or, green card in the case of long term residents). What a bizarre … Continue reading President Trump – Expatriating?
The Internal Revenue Service (IRS) announced today new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed, or any penalties or interest! It sounds … Continue reading Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!
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
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
One Country, Two Citizenships: John Richardson Interviews Virginia La Torre Jeker. Most people don’t know that the US has two kinds of citizenship – “Immigration” citizenship and “Tax” citizenship. Tax citizenship, the monkey on your back, is hard to shake off! Watch the interview, here. All the US tax information you need, every week … Continue reading USA: One Country, Two Citizenships