This post has been cross posted from RenounceUSCitizenship.
U.S. citizenship has been priced out of the market
The taxpayer, the IRS and the “cross border professionals” – where to go from here
U.S. citizens may have trouble finding qualified tax preparers
An inside perspective – Stacie Kitts, CPA:
“Choose A Tax Preparer That Has a Clue
Here it is, what all un-registered (non CPA’s, attorneys, or enrolled agent) tax preparers have been waiting for. The specs for the competency test that will award those who pass the title of “Registered Tax Return Preparer.”
Wowwee doesn’t it just give you the chills….
No – well maybe that’s because CPA’s and attorneys can sign tax returns even if they don’t have a single clue what they are doing. They get to do this without passing a test (other than the initial licensing exam which he/she could have taken a hundred years ago – so not even relevant today) or taking a single hour of tax related continuing professional education. You know, training that would keep you up to speed on the actual tax laws that apply to tax return preparation.
So what do you think the odds are that many of these licensed “professionals” would have a difficult time passing the new competency test?
Ya, scary jacked up regulation that leaves out a large number of people who are trusted to prepare your tax return.
Fixing the mistakes of these so called professionals is a large part of my practice. I guess I should be grateful instead of loosing my mind over the absurdity of it all.”
Gives you food for thought doesn’t it. Not all tax preparers are created equally and the one you choose better “have a clue”.
U.S. citizens and dual citizens living outside the United States
Few U.S. citizens living outside the United States will forget 2011. It was a year where many learned that they may not have been compliant with U.S. tax and/or information reporting requirements. If the IRS statistics are to be believed, the vast majority of U.S. citizens living outside the United States were not filing U.S. tax returns. Of those who had been filing tax returns virtually none of them were filing the FBAR (“Foreign Bank Account Report”). When it came to the FBAR (which is not a tax form and is not even to be mailed to the IRS), virtually nobody knew that it existed, virtually no tax professionals (if they knew of it) were educating people, and there was no reason to suspect such a form existed. Those those who HAD been filing tax returns had never been notified that an FBAR was required. Most U.S. expats are law abiding patriotic U.S. citizens. Most want to be in compliance. As a result, the viciousness of the IRS assault impacted their health, wealth and quality of life.
U.S. citizens living outside the United States seem to fall into one of the following groups:
- Never filed U.S. tax returns
- Stopped filing U.S. tax returns after having become a citizen of another country
- Filed U.S. tax returns on an ongoing basis, but had never filed information returns (“FBAR”)
- Filed all tax and information returns properly (I suspect that this small group was comprised of people with large incomes and large amounts of money to pay on tax and legal advice)
The 2011 Taxpayer Advocate Report to Congress reveal that “past compliance” has been low. It is also clear that the “past compliance” was inadvertent AND that (for the most part as they should), U.S. citizens living outside the United States,want to be in compliance! The conduct of the IRS has made compliance difficult. The irony is that although Commissioner Shulman claims that his objective is to “bring people back into the tax system”, the reality is that the conduct of the IRS (OVDI, threats, absence of clear guidelines) has made people frightened and reluctant to comply. The IRS has become an obstacle to compliance. U.S. citizens living abroad are like “deer frozen in the headlights” – they are paralyzed with fear and don’t know what to do.
Most taxpayers want to come into compliance – the question is how to do this
The conduct of the IRS has had a profound, permanent and irreparable effect on the lives of U.S. citizens living outside the U.S. A recent blog post titled: “Has your life been stolen from you by the IRS” revealed the true effect of recent IRS initiatives. By presuming that all taxpayers who entered OVDI were criminals, the IRS has eroded trust. The IRS cannot function without trust. This is tragic and was entirely unnecessary.
I repeat, the vast majority of U.S. expats want to be in compliance and just need to be told how. The time to file 2011 taxes is rapidly approaching. The IRS is making demands on the expat community but is not providing guidelines for how to comply. On January 9, 2012, when the IRS announced the reopening of OVDI, the IRS promised procedures for how to come into compliance. Those procedures have not been announced. Instead of asking taxpayers to “come clean”, the time has come for the IRS to “come clean” by revealing the promised procedures for U.S. citizens outside the U.S. to come into compliance. Time is of the essence – tax season is upon us.
U.S. tax and information return compliance –Choosing your dance partner – what kind of “cross border professional”?
It is becoming increasingly difficult to find competent “cross border” professionals. The cost of expat tax compliance is very high. So high, that U.S. citizenship has been priced out of the market. Everybody has different situations. Furthermore, there are at least two sets of issues:
- The possible issue of past non-compliance which may require the services of a lawyer
- The issue of “number crunching” and form completion which deals with more objective information
Compliance issues are more complex. The more complex the situation, the more you should consider a lawyer. At a minimum, compliance issues require the exercise of judgment that completing tax returns may not. Here is a “snapshot” of the different categories of people who you might turn to for assistance.
First, ALL “paid tax preparers” are required to have a PTIN number. The IRS is requiring all paid tax preparers to register with the IRS and to pass an exam. (If this applies to tax preparers outside of the United States, this regulation like FATCA is one more attempt of the U.S to impose its law outside of the U.S.) Note that this requirement applies to ALL paid tax preparers.
Second, there are two broad categories of “paid tax preparers”.
- Attorneys, CPAs and Enrolled Agents – have far greater privileges and responsibilities (including the ability to represent you before the IRS). Their conduct is governed by “Circular 230” which is a compilation of rules and ethics. Circular 230 is worth a read. You will see why so much of the advice is the same from CPA to CPA.
- Registered Tax Preparer– who is restricted to preparing tax returns and is required to pass a competency exam
All of these people cost lots of money. You will pay the most for Attorneys and CPAs. An Enrolled Agent will cost less than an attorney but more than a preparer.
These costs are such that “U.S. citizenship has been priced out of the market”.
When you seek the services of a “cross border professional” you need to understand the qualifications and limitations of the person you are dealing with. At the one extreme you have the attorney and at the other extreme you have the “Registered Tax Preparer”.
Your Four Choices Of Dance Partner – Understanding The Differences
1. Attorneys: If you use an Attorney make sure that it is one who specializes in tax compliance. If you use an attorney you will have the benefit of “attorney client privilege”. This means that once you retain the attorney, things you tell the attorney remain secret.
“What goes on in Vegas stays in Vegas”. This can be “priceless”.
2. CPAs: Assuming the CPA specializes in “cross border” issues, you should be fine. They are, in my experience just as expensive as the attorneys. That said, they do not come with “privilege”.
3. Enrolled Agent: Enrolled Agents have a very specialized knowledge in tax and IRS procedure. Like all professionals, they advertise their designation. Enrolled Agents market themselves (in part) on the basis that they cost less than attorneys and CPAs. They know what they are doing. It’s just that all they know is tax. You may have never heard of an “Enrolled Agent”.
An Enrolled Agent (EA) is a federally-authorized tax practitioner who has technical expertise in the field of taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all administrative levels of the Internal Revenue Service for audits, collections, and appeals.
What does the term “Enrolled Agent” mean?
“Enrolled” means to be licensed to practice by the federal government, and “Agent” means authorized to appear in the place of the taxpayer at the IRS. Only Enrolled Agents, attorneys, and CPAs may represent taxpayers before the IRS. The Enrolled Agent profession dates back to 1884 when, after questionable claims had been presented for Civil War losses, Congress acted to regulate persons who represented citizens in their dealings with the U.S. Treasury Department.
What are the differences between Enrolled Agents and other tax professionals?
Only Enrolled Agents are required to demonstrate to the IRS their competence in matters of taxation before they may represent a taxpayer before the IRS. Unlike attorneys and CPAs, who may or may not choose to specialize in taxes, all Enrolled Agents specialize in taxation. Enrolled Agents are the only taxpayer representatives who receive their right to practice from the U.S. government (CPAs and attorneys are licensed by their state).”
4. Registered Tax Preparer: What is this about?
The Internal Revenue services defines a “tax return preparer” as “an individual who, for compensation, prepares all or substantially all of a federal tax return or claim for refund.
What are the recent changes to become a Tax Preparer?
The IRS requires all paid tax preparers to sign up with the IRS, pay a registration fee and obtain a preparer tax identification number (PTIN). If you already have a PTIN you must still sign up under the new process. All paid preparers will be required to register and obtain a PTIN before April 18th, 2012 or they cannot prepare returns for compensation.
Beginning in November 2011, tax return preparers must pass an IRS Competency Exam to officially become an IRS Registered Tax Return Preparer. Tax return preparers who have PTINs before April 18, 2012 will have until December 31, 2013 to pass the IRS Competency Test and may take the test an unlimited number of times to pass it. There will be a fee to take the test and that fee will be due each time the individual attempts to pass the test. New tax return preparers will be required to pass the IRS Competency Test before they can obtain a PTIN. The IRS will require competency tests for all paid tax return preparers (except Attorneys, CPA’s, Enrolled Agents).
Unless you have a very simple return (only employment income and maybe a bit of interest income), I would seek somebody with greater competency than a “tax preparer”. On the other hand, it may be the only service you can afford.
Moral of the story: You want to be in tax compliance. Be thoughtful and discriminating in who you retain. In the same way that there are different kinds of taxpayers, there are also different kinds of tax preparers. Your choice of “cross border professional” is important.
The 2011 Taxpayer Advocate Report To Congress confirmed that the renunciation of U.S. citizenship is a growth industry (who wouldn’t renounce if the IRS won’t tell you how to come into compliance while threatening you with big fines for not being in compliance). You will have to be in tax compliance in order to renounce. Many of you will have to pay an Exit tax to renounce U.S. citizenship. Your choice of “cross border” professional should include this consideration.
If you survived the vicious assault of 2011, your goal may be to:
Renounce U.S. citizenship, reclaim your stolen life and rejoice!
Welcome @john. You might want to read up here so as to be more familiar with the background to this situation, and the terms, forms and acronyms when you speak with HRBlock. It is not as straightforward as when filing US taxes as a US resident, or when filing Canadian taxes as a Canadian resident. I am not trying to alarm you by my comments below, but you need to be informed in order to protect yourself and get the right help you may need with filing.
One of the biggest problems is how the US treats all our Canadian everyday bank accounts and savings as ‘foreign’ accounts similar to the ‘offshore’ ones that US residents have opened in the Caymans, and not declared. The IRS refuses to acknowledge that if we live in Canada, we have to have local accounts. They view them punitively as ‘foreign’ (i.e. non-US) accounts, and insists that we file complicated forms reporting them – and have invented all sorts of potentially huge penalties for not reporting, or for errors – not just on any interest that might be taxable, but on the actual balances and values – out of all proportion – even if no US tax was ever owed.
You particularly want to read up about how the US demands different types of reporting (ex. FBAR, 3520/3520A) on any bank accounts, savings and investments held outside the US – which they consider ‘foreign’ accounts – merely because they are not held inside the US. In this case, all Canadian accounts and savings and investments are considered ‘foreign’. And also any other non-US accounts where we have the power to co-sign, even if non-personal (ex. power of attorney for finances – for advance planning purposes). For most of us with modest incomes, it has not been our actual ‘income’ and wages that are the problem – since often with the application of the FEIE, we owed no actual US taxes. The bigger issue has been the ‘foreign bank account reporting’ FBARs, and how the IRS treats RRSPs (needs an annual election form to be treated by the IRS as non-taxable – under the reciprocal Canada/US tax treaty), and also, the 3520 and 3520A forms for other registered accounts (RESPs, RDSPs, TFSAs, and now PRPPs) which the US calls ‘foreign trusts’, and considers taxable. Currently they are NOT covered under the treaty unfortunately. Canadian mutual funds are also a problem – and require yet another special, complex form. The reporting for these must be accurate and precise because the IRS has instituted draconian penalties which they may apply – just for not having reported them – even though they are legal and compliant under the Canadian tax system.
Another common potential pitfall is selling your primary residence – which is non-taxable in Canada, but which the US considers taxable.
You may want to read this thread: http://isaacbrocksociety.ca/2012/01/23/attorney-cpa-ea-or-registered-tax-preparer-your-choice-of-dance-partner-tax-compliance/
and this one:
The situation is in flux, and the new ‘streamlined’ compliance process has only been in force since September 1st, 2012. We have not heard how the IRS is treating those submissions. I don’t know if that is the process that HRBlock described to you.
Because the IRS refuses to provide information or clarifications – particularly to the public, we have no idea how harsh or narrowly they will treat returns and forms submitted under that process. Much depends on your specific individual facts and circumstances. For some people, the tax preparer chains may not be appropriate. The preparer must have experience with US forms and taxes – not just be a data entry person in other words. US taxes for those working and living outside the US are very different from Canadian taxes, and very different from filing from inside the US. They are much more complex, and there are forms and reporting required from those US person living outside the US that do not apply to US residents who live, earn and bank entirely there.
The preparer should be able to answer your questions knowledgeably. And be able to discuss any potential snags or unknowns. And in the end, you are relying on them to know what to ask you to provide – and then to know must be filed, how to complete it, and to do it correctly – because any even inadvertent errors can result in a lengthy and potentially expensive process to correct.
Your best protection is to read up on this as much as you can, and also not to panic and not to do anything without feeling you have gathered information and looked at your situation first.
Good luck – hope it is resolved for you with a minimum of pain and cost.
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The IRS just lost this case in a Federal Court! Wow! Of course they will appeal.
IRS Loses Lawsuit Challenging Authority to Regulate Tax Preparers
In a stunning blow to the Internal Revenue Service’s efforts to regulate the tax preparation profession, a federal judge struck down the IRS’s licensing requirements for tax preparers on Friday, including testing and continuing education.
DOugie’s gonna have to update his resume.
Where to share my latest frustration, but here on the Isaac Brock site.
I consulted with three tax lawyers regarding my affairs, and have reported on that elsewhere on this site. I was not charged for any of these consultations, though in each case offered to pay for the service. I chose to work with the firm that my Victoria-based accounting firm recommended, the tax lawyer is based in Seattle.
Then, out of the blue, in February, I got a call from the Calgary firm that I had initially consulted. I had a phone message that said they “had the opportunity in another context to look at the issue again, and think that they had likely identified what may be a fairly straightforward and easy solution for me that would not involve a significant amount of filing and tax compliance”. (I became a Canadian in 1985, have lived only as a Canadian, and have a relinquishment appointment in Calgary in May). I was curious so phoned back. The explained that I could likely relinquish. I said that I already had a relinquishment appointment in Calgary. The lawyer said he thought there might be a problem – my relinquishment appointment was on a Friday. He phoned the consulate, who then contacted me and told me you had to book a relinquishment appointment by email, not on line, and that appointments were only on Tuesday, Wednesday and Thursday. I rebooked for May.
I asked the Calgary lawyer what services his firm could provide with reviewing the relinquishment forms, and I asked about their experience with this. They had experience with renounciations, not relinquishments, and suggested the process was similar (I know the differences). I said I’d be interested in having someone review the form, and asked about their rates. His rate was $350 per hour. The lawyer then sent me an email saying he’d need to put together an engagement letter, and go through the whole evaluation – full meal deal – of my tax situation. We NEVER talked about their firm doing anything related to my taxes as they know that I have already engaged a tax lawyer with another firm. I wrote back, saying I was going to work with my existing tax lawyer. They said we will need to send a bill for the time spent to date…I figured that I might get a bill for one hour, since they phoned the consulate on my behalf – bill estimate $350.
I got a bill for $2587. I was furious, and incensed. I created my own chronicle of time spent and what we talked about and sent it back. They called to ‘negotiate a settlement’. The result – I am left paying $560 because they made one call to the US consulate on my behalf. The bill included 1.6 hours related to this one task, and two phone calls with me about the change in appointment at the consulate. The bill also included 4 hours of time for their internal consulations on my tax matters – which is not something I asked them about, or asked them to do. I am disgusted and angry, and feel I’ve been dupped.
While I beleive the firm does have good expertise on tax matters, their professional practice completely contradicted their stated promise on their website of “no surprise fees”. They called me, I did not call them. Lesson learned – don’t return calls to a tax firm that is trying to resolicit your business. And assume that tax lawyers will bill you for activities they have undertaken, whether you instructed them to do this or not.
Ugh….OK, I feel better now, getting that off my chest. A friend said, don’t pursue this any further, you don’t need to invest emotional energy in this. I agree. But I do want to warn others, so no one else gets hit with an unexpected bill.
The legal firm I am dealing with in Seattle has been extraordinarily professional, and no surprises.
If you relinquished in 1985 ,why do you need a tax lawyer?We have established that you have no filing obligation.
Tell the Calgary lawyers that in return for them trying to screw you out of $2600 they will have to settle for $250.
I once got a bill from a lawyer for $50 for forwarding a letter to me. I sent him a cheque for 50 cents-the cost of a stamp-they cashed the cheque and that was the end of it.
@Lagoon, I see no reason for anyone to waste money on a lawyer for renunciation or relinquishment. The process is easy, and by now very routine for all the Canadian consulates. On a side note I have been following the blog for some time now, Calgary seems to have gone from one day a week, then two days a week, and now three days a week. More evidence that renunciations are on the increase.
@true north, what I know now, thanks to this site, and what I knew two months ago, are different things…lessons learned, and thank goodness for this community
@KalC, love your solution
I’m so glad I trusted my genuine account’s advice that she didn’t think I needed an attorney, at least not initially. If the IRS or Ficen had turned really nasty (such as having F-bar penalties assessed), then I probably would need to hire a lawyer but am hoping and praying that the SOL will pass smoothly… so far, almost two years but still up to four to go, though should be through the danger window in about a year which isn’t too long…
Why pay anything at all to those criminals? If you haven’t signed anything indicating you wanted to engage them, why be concerned with their invoice at all?
@Lagoon, sorry to hear about your experience and good that you at least have found another firm that can be trusted. Unfortunately Obama`s tax terroism on expats has created a layer of dubious tax and CPA firms that have no problem milking your bank account. I have never understood why there is not a tighter regulation/control regarding “billable hours“ or “phone transcripts“ when it comes to the services performed by tax lawyers. I.m.o there is a lot of undetected fraud because you as the client have very little proof or means to detect fluff,double billing, overbilling or plain fraud. In your example 1.6hours to the US consulate is plain and simple a lie – but you are not alone there are many commenters here that had similiar experiences when they looked at their monthly bill from their tax lawyer . It is appauling when I see that these tax lawyers pretent to be the “good cop“ when in fact they are COCKROACHES using OVDI/P,VD as a fee annuity to draw on whenever they feel the need –
a good read about those “prominent tax attorneys“ …. why are so many located in California 🙂
another good read about those “prominent tax attorneys“…. why are so many coming from California ? http://www.taxproblemattorneyblog.com/2013/03/prominent-tax-attorney-found-l.html?goback=%2Egde_3694878_member_225106941
It’s a racket; there in bed with the lobbyists and IRS: P
Your experience brings back bad memories of years of intermittent abuse by one of the Big 4 accounting firms. This included (1) Wondering about charitable deductions and getting a few pages of “research” boilerplate with a big bill (2) Having scarcely-timely returns prepared as exercises by junior new hires with repeated big mistakes sticking out in stuff I didn’t understand too well which was why I was seeking their “services” in the first place (3) Questions about their own mistakes or possible mistakes routinely regarded as further billable “consultation” (4) Billing for unasked for year-by-year recalculation of RRSP contributions that only confirmed the summary I had already provided to them (5) Unasked for “proactive” out-of-the-blue multi-year “review” of some detail based on change in US policy – after I had already done the checking myself and determined I had no problems. Bad bad memories. You get Big by chomping up any fodder that you can rustle or cook up. These folk are shameless. Commiserations. We can well guess who that Calgary firm is.
@ all, thanks for your reassurances.
I had a great call this morning with the legal firm I am working with out of Seattle, they provide exeptional services and understand relinquishment cases inside and out. I am needing guidance on how to deal with financial matters related to my support for my aging mother, who is 85. This includes joint bank accounts and estate planning matters related to inheritance of an IRA by me a Candian citizen. They don’t always bill me for the calls, and so I reaffirmed that I expected a bill for this consultation – such a night and day experience with tax lawyers for me.
I want to thank whoever it was (Badger? Mike?–I cannot find the original comment in this forum) who suggested that I obtain professional advice from firstname.lastname@example.org.
This tax professional provided good advice on issues that I would never have figured out or acted on my own. There was a charge for the telephone consult which I felt was reasonable.
Consider this to be a limited endorsement from one customer with all possible disclaimers.
IRSCompliantForever, glad you found competent help. It wasn’t me who recommended them.
Unfortunately I can’t provide a recommendation.
I echo this comment and experience that usxcanada described March 22, 2013 at 2:12 pm …”(3) Questions about their own mistakes or possible mistakes routinely regarded as further billable “consultation””.
In my case, among other expensive yet shoddy work – one lawyer contradicting another on a significant aspect of the case status – but both working the same file, and both billing for it. When asked to explain the contradiction – junior lawyer offers up an off the cuff bs answer – which was confirmed as such by the IRS itself to me later on. So much for the IRS consultations and ‘research’. Didn’t even do the simple returns and FBARs without obvious errors – and erroneous (random?) information entered (bearing zero relationship with my records) – and strangely, passed through several layers of billable ‘review’ (admin/data entry, preparer, enrolled agent, lawyer, etc.) intact.
I could have achieved the same lack of quality on the multiple returns and forms, with a similar consistency of error from using one of the seasonal chains in my local mall if that was my goal. For far less.
It is possible that the person/company preparing or assisting you in your tax returns might require you to sign an “indemnification” clause that could result, in certain conditions, in your paying unlimited attorney fees, costs.
Read the clause carefully and consider the maximum harm that could be caused to you by signing such an indemnification clause.
I personally would never agree to sign these typically one-sided indemnification agreements.
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In my experience it shouldn’t matter whether you’re a registered tax preparer, enrolled agent, CPA, CA (now Canadian CPA) or CGA. What matters is the amount of cross border tax experience your professional has and whether he or she has the appropriate support and resources at their disposal.
It’s easy for sole practitioners to develop a false sense of competency in preparing cross border returns. Especially if their returns are not being reviewed by someone else, and considering the IRS, unlike CRA, doesn’t review tax returns very often, it’s likely that your tax return is not properly prepared.
When possible choose a firm with a long history of cross border tax experience and enough resources to keep up with the various changes on both sides of the border.
Phil Hogan, CPA, CA
My experience with three different tax accountants has not been great. I have to echo usxcanada’s sentiments and would even take it a step further in saying that in some cases there is even gross negligence.
On one hand we have to be thankful that these individuals are there when we need them. However, it isn’t out of kindness and some can even be considered parasites.
Just wanted to share my experience from an expat far away (Germany):
Taxesforexpats.com was for me the best choice. Reasonable (but not cheep) fees, fast response even to stuipid questions. No bad surprises on the bill. Fast & good processing. I believe it’s not a “walk in” office, but entirely IT driven. The only negative thing for me was, that all correspondence is in english. Not easy, if one was educated in another language (in my case: german since school grade 3). German speaking tax people offered the same service for more than 6 times as much. No way!
I’ve done it! My “streamlined offshore” submission was successfully processed by the IRS. I can step into the light again. I was scared to death for a while and I am still recovering from that….
What a nonsense! According to the double tax agreement as employee I can only be taxed in the country where I work and live. By definition my US taxes must be 0. Not even my german lawyer did know about all this.
Nope, I do not work for them and do not have any benefit from this posting. The reviews in Trustpilot are all excellent. Please excuse my limited english.
An die deutsche Leserschaft (die zweifellos existiert):
In kann taxesforexpats.com uneingeschränkt empfehlen. Es mag etwas teurer sein, als andere Lockangebote, aber es bleibt dann auch bei den angegebenen Preisen. Der Service ist sehr gut, emails werden manchmal innerhalb von Minuten beantwortet, die gesamte Erstellung geht sehr schnell . Die gesamte Kommunikation ist allerdings in Englisch, was nicht einfach ist, wenn man in einer anderen Sprache ausgebildet wurde (deutsche Schule ab Klasse 3). Deutsch sprechende Steuerbüros haben einen erst mal angeschaut wie ein Auto (keine Ahnung!) oder haben Mondpreise genannt. 2k€ kostet etwa „Streamlined foreign offshore“ mit einigen Konten. Auch wurde mir in anderen Belangen (z.B. mit der SSN) geholfen.
Es ist also getan und ich möchte meine positive Erfahrung kundtun. Ich arbeite nicht da und habe auch nichts von diesem „post“.
Nach einer Weile Schockzustand bin ich jetzt dabei mich wieder zu erholen.
Ich frage mich nur was dieser Unsinn soll. Als Angestellter unterliege ich der uneingeschränkten Steuerpflicht in D und nach Art. 15 DBA kann ich nur in einem Land besteuert werden. Was ein #@##@! Nonsens!