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Can't make "Live Toronto Event" to discuss end of @citizenshiptax https://t.co/pk6PVMNAKc? @Expatriationlaw interviews @SolomonYue LIVE: Friday Aug. 17 – 11:00 a.m. EST (Toronto) – VIEW it @thatchannel anywhere in the world! Tweet questions to @expatriationlaw in advance and RT! pic.twitter.com/bWFBBPv2Zz
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) August 14, 2018
@Jim
I tweeted him thanking him to the article and brought up the Transition Tax with the latest CBC article on it where my husband and I are featured.
“No bill will solve everything”
A bill to delete the word “alien” from the phrase “non-resident alien” in one US income tax statute would solve quite a lot for non-resident citizens.
Any good materials to help Amcham Australia become more public in their support of this? Such as for their website? They have not tweeted anything, I don’t see on their website. ?? I am very happy with Amcham Canada getting involved.
The National Review article finds use in the FEIE in its statement of: Many have annual earnings below the $102,100 threshold. As in… not such a big deal to get rid of CBT.
Three years compliance is a joke. People prefer a simply RBT, not a CBT 2.0
On top, for oversea banks, American aboard are still not welcomed because of FATCA.
This bill won’t fix anything, I don’t even bother to see if a vote will happen in the Congress or not.
Correct me if I’m wrong but it seems to me the National Review article explains the FEIE inaccurately.
All earned income is subject to taxation in the residence country, regardless of US law.
US law applies a top-up tax on earned income over the FEIE threshold, if the USC claims the FEIE.
If the USC lives in a high-tax country (tax rates not lower than US rates), and the USC claims tax credits, there’s no threshold. Correct? The USC can claim tax credits for foreign tax paid on earned income, with no limit.
@plaxy I believe there are some rules that prevent one from changing each year between using FEIE and credits. Once you start one way…
Removal of FEIE under CBT could hurt for residents in countries with a relatively high tax free threshold, and if one earns under/just above that threshold. Australia has a tax free threshold of $AU18,200 per year.
I see. Thanks for the explanation.
To some extent you can use both. Let say you have 100k earned income that is excluded using the FEIE.
You can’t use foreign tax as a credit on the same 100k but if you had other income as well you could use any taxes on the other income as credit.
In high tax countries, usually the foreign tax credit is enough.
“You can’t use foreign tax as a credit on the same 100k”
That was the rule, but I think the US government got it overturned so now you have to include the same 100k in foreign tax credit calculations, i.e. you’re required to double-dip.
In my only US Tax Court case that actually went to trial, the IRS called me frivolous for excluding from Form 1116 for general category the amount of non-US sourced earned income that was excluded by Form 2555. I submitted 4 pieces of evidence, 4 of the places where IRS instructions told people to do that excluding from Form 1116 because we’re not supposed to double-dip. The IRS attorney looked sheepish. I think the IRS stopped complaining about this kind of obedience. But the IRS’s opinion doesn’t matter!
In my first US Court of Federal Claims case, the US Department of Justice complained that my obedience of those instructions, excluding from Form 1116 for general category the amount of no-US sourced income that was excluded by Form 2555, showed a lack of sincere and honest intent to comply with US tax laws, therefore Federal Claims lacked jurisdiction to decide if I should get my withholding refunded for tax year 2005. In that court, I did not dispute the DOJ’s complaint. Therefore, as far as I can tell, the DOJ persuaded Court of Federal Claims that a sincere and honest intent to comply with US tax laws requires double-dipping.
Of course you’d need around 4 times the amount of earned income that I had in that year in order to benefit from it, but any of you rich bastards who would like to take advantage of that court ruling and do some double-dipping, I’ll gladly accept your donations for obtaining this for you.
I agree with John Richardson, the TTFI bill should be called, “The Save US Citizenship Act.”
In the preamble, it can describe some of the main problems faced by US expats (double taxation, inability to save for retirement, effects of CFC rules etc). It can also include some statistics about how many people have renounced / relinquished US citizenship since the passage of FATCA.
Strongly agree! Though I think some emphasis on the problems faced by US citizens seeking employment abroad, and the way it hurts US competitiveness should be an extra paragraph. Together, this can greatly increase the possibility of stimulating the nationalistic lobes of lawmakers’ brains. This is worth the effort of contacting Solomon Yue, George Holding, Mark Meadows, and any other concerned parties.
In the name, probably best to avoid the word “abroad” in it and just call it The Save US Citizenship Act.
@Barbara
Solomon Yue:
solomon.yue@republicansoverseas.com
@JC
Why “US”? Is there any other?
@JC: Of course it must be “Save US citizenship”. The word “USA” strikes a chord in the shallow hearts of US officials. And, without “US”, it could be some libtard-sponsored bill trying to save Mexican citizenship for all those illegal immigrants stealing American jobs.
I meant @BB. Sorry. And thanks for Solomon’s email. I’m writing him straight away. As others should too, I think.
This should be a feature in its own right.
This is the meeting on day 2. Any video of the Amcham meeting?
Portland –
What struck me about the National Review writer’s explanation was that by omitting to even mention the US obligation to allow credit for domestic tax paid, it seemed to imply that both countries had equal taxing rights on income over the FEIE limit.
But I realise now that that was probably not the intention. The question of taxing rights probably never entered his mind.
So much negativity and I can guarantee all the negative responses are from people who were not there on Thursday night. I was there and I think this is Monumental progress and it is a great start. The bill is not even out yet and you have all pissed all over it. Way to go. I was there Thursday and saw him and explained in detail what the bill covered and it’s in direct opposite to what most of you are saying. At least wait till the bill comes out. I know it will help me immensely. There is no room for negativity on this. If you can’t support it just shut up and get out of the way.
Thanks Dave for attending the meeting and your encouraging words.
I look forward to the video of the event.
Do we have video on the Amcham meeting? And, how it was different than this interview?
Wasn’t much difference except Solomon described the legislative process a bit. Also q&a.
@DaveSimpson
“There is no room for negativity on this. If you can’t support it just shut up and get out of the way.”
That language is totally uncalled for. We here speak freely, it is our right, we learn from each other the pitfalls of any proposed change. We do not follow blindly.
The US has legally negotiated tax treaties with a multitude of countries over many years covering the taxation of US pensions .received by non residents thus avoiding double taxation.. My sole income comes from a US TIAA university pension. Will the US be willing to renegotiate all these treaties that have taken many years to achieve? Will my resident country give up the right to tax my pension or will I be double taxed?!!
@DaveSimpson
Your diatribe smacks of “I’m all right, Jack!”. Wonderful that TTFI might help you. But what about the large number (likely a majority) that it will not? TTFI is a half-assed solution that still firmly entrenches CBT that your heirs will pay the price for. I agree it is a step forward, but if it should pass, it will be the last real change we will see in a generation. And you will probably disappear into the woodwork, smug that you’re taken care of. Congress will blast “job done” from its minarets and the rest of those non-resident will be hung out to dry.
I won’t give up lobbying until the US joins the rest of the civilized world with actual RBT, and I sure as hell won’t shut up until ALL non-residents are taken into account.
I’m opting to shut up and get out of the way, for the most part, because like most accidentals with no US ties, I’d be an idiot to sign up for some sort of semi-compliance in order to then excuse myself from compliance when there is no reason for compliance in the first place.