Articles by John Richardson

ADCS Co-Chair John Richardson, BA, LLB, JD (member of the bars of Ontario, New York and Massachusetts), has written extensively and very informatively on US tax and citizenship matters.

2019.03.01.  WOW! A Big Reaction To The Article Posted Yesterday Called “USA Of The 21st Century Is Like Britain In The 19th Century, TaxConnections.
2019.02.28.  The USA Of The 21st Century Is Like Britain In The 19th Century, TaxConnections.
2019.02.21.  Canada’s FATCA IGA Is About Government Of Canada Turning Dual Citizens Over To The United States, TaxConnections.
2018.11.12.  Americans Abroad And The Transition Tax – Leaves Taxpayers In Tough Situation, TaxConnections.
2018.11.09. US Transition Tax Hearing – Argues Regulatory Flexibility Act Should Apply And/Or De Minimis Rule Be Created, TaxConnections.
2018.11.08.The Purpose Of The United States “Regulatory Flexibility Act”, TaxConnections.
2018.11.07.  Transition Tax Bad Effect On Small U.S. Business Owners Operating Overseas, TaxConnections.
2018.11.02.  Dual Citizen, Canadian Lawyer: Does “Intent” Matter In The Interpretation Of The U.S.Transition Tax? TaxConnections.
2018.11.01. U.S. Constitutions 16th Amendment Authorized Income Taxes: Transition Tax Is Not An Income Tax, TaxConnections.
2018.10.25.  Section 965 “Transition Tax”: Individuals Subject To U.S. State Tax Jurisdiction, The Response Of New York State, TaxConnections.
2018.10.16.  IRC Section 965 Transition Tax – Part 10: Individuals Subject to U.S. State Tax Jurisdiction, the Response of New York State, TaxConnections.
2018.10.12. IRC Section 965 Transition Tax – Part 9: From The “Pax Americana” To The “Tax Americana”:  , TaxConnections.
2018.10.11. IRC Section 965 Transition Tax – Part 8: This small business thought it was saving to invest in business expansion – Wrong, they were saving to be robbed by America! , TaxConnections.
2018.10.09.   IRC Section 965 Transition Tax – Part 7:Why The Transition Tax Creates A Fictional Tax Event That Allows The U.S. To Collect Tax Where It Never Could Have Before, TaxConnections.
2018.10.05.  IRC Section 965 Transition Tax – Part 6:  A Reprieve, TaxConnections.
2018.10.04.  IRC Section 965 Transition Tax – Part 5:  Shades of OVDP, TaxConnections.
2018.10.03   Tax Debt And Passport Revocation:  The New Weapon Against Americans Abroad, TaxConnections.
2018.09.27  IRC Section 965 Transition Tax – Part 4, TaxConnections.
2018.09.26.  IRC Section 965 Transition Tax – Part 3:  The US Wants Your Pension ,TaxConnections.
2018.09.25. IRC Section 965 Transition Tax: Part 2, TaxConnections.
2018.09.21.   IRC Section 965 Transition Tax: Resistance Is Futile,  TaxConnections.
2018.09.18.   U.S. Citizens Speak Out “While You Can” About Proposed Repatriation Tax Regulations: Exempt American Small Business Owners In United States And Worldwide From US Transition And GILTI Taxes, TaxConnections.
2018.08.23.  So You Have Received A Bank Letter Asking You About Your Tax Residence For Common Reporting Standards (CRS) Or Foreign Accounting Tax Compliance Act (FATCA) Part 3, TaxConnections.
2018.08.22.  So You Have Received A Bank Letter Asking You About Your Tax Residence For Common Reporting Standards (CRS) Or Foreign Accounting Tax Compliance Act (FATCA) Part 2, TaxConnections.
2018.08.21.  So You Have Received A Bank Letter Asking You About Your Tax Residence For Common Reporting Standards (CRS) Or Foreign Accounting Tax Compliance Act (FATCA) Part 1, TaxConnections.
2018.08.10  Green Card Holders: The “Tax Treaty Tiebreaker” And Reporting Forms 8938, 8621 And 5471, TaxConnections.
2018.08.09.  Biggest Cost Of Being A Dual Canadian/United States Tax Filer, TaxConnections.
2018.08.08. Wisdom Of “Three Monkeys” Explains: Little Support For “Citizenship-Based Taxation” Makes Repeal Difficult, TaxConnections.
2018.06.22.  Responding To IRC Section 965 Transition Tax: Resistance Is Futile But Compliance Is Impossible, TaxConnections.
2018.06.21. Real Costs Of Being A “Dual Tax Filer” In Canada And U.S.,TaxConnections.
2018.05.29.  If You Are A U.S. /Canadian Dual Citizen And Want To Be A Shareholder In A Canadian Business –  Renounce U.S. Citizenship, TaxConnections.
2018.02.27. Unintended Consequences Of Tax Jobs And Cuts Act On Canadian Citizens And Others Abroad, TaxConnections
2018.01.31.  Interview with John Richardson by Anthony Parent,  Latest Podcast Guest: Tax Attorney John Richardson, Tax Connections.
2017.11.08.  US Tax Reform Bill Appears to Confiscate 12% of Retained Earnings of Certain Canadian-Controlled Private Corporations,TaxConnections.
2017.10.27.  Testimony: Green Card Holder Victim Of FATCA After Failing To Return Expired Card, TaxConnections.
2017.10.26.  Testimony On FATCA’s Extensive Reporting Requirements From A US Citizen Living Abroad, TaxConnections.
2017.10.25.  Testimony: Letter From Father To Senate On FATCA Regarding Disabled Son, TaxConnections.
2017.10.24.  Dear Son: A Letter On FATCA From A Concerned Father, TaxConnections.
2017.10.20.  Testimony: Businessman Abroad Affected By FATCA, TaxConnections.
2017.10.19.  Testimony: A Letter To Senators From An American Affected By FATCA , TaxConnections.
2017.10.18.  Testimony: The Effects of the Current Tax System on Americans Abroad, TaxConnections.
2017.09.27.  Imposing Taxation on Tax Residents of Other Countries, TaxConnections.
2017.09.21.  Part 1: South Africa and the USA — Citizenship-Based Taxation, TaxConnections.
2017.09.12.  Green Card, Leaving the US and Escaping Taxation, TaxConnections.
2017.09.07.  Stop Imposing Taxation On Residents Of Other Countries, TaxConnections.
2017.09.05.   Using Corporations To Reduce Or Defer Taxation For Individuals, TaxConnections.
2017.08.31.   The OMG Moment And Dealing With U.S. Citizenship Problems, TaxConnections.
2017.08.29.   Americans Abroad And IRS ‘Amnesty’ Offers In OVDP, TaxConnections.
2017.08.24.  The Canada-U.S. Tax Treaty Does Not Protect From Tax Liability, TaxConnections.
2017.08.16.  The Biggest Cost Of Being A Dual Canada/U.S. Tax Filer,TaxConnections.
2017.08.09.  13 Reasons Why I Committed Citizide, TaxConnections. This article also appears as a guest post in The Human Side of Expatriation, Virginia Le Torre Jeker, AngloInfo.
2017.08.02.  The Exit Tax Is A Perfectly Bad Idea, TaxConnections.
2017.07.27.  U.S. Imposes Full Taxation On Canadians—Tax Reform 2017,  TaxConnections.
2017.07.26.  Why Is The U.S. Imposing Full Taxation On Canadians? TaxConnections.
2017.07.20.  2017 Residence Based Taxation Request To Chairman Hatch, TaxConnections.
2017.07.13.   Do Tax Preparers Know If Non-US Mutual Funds Are PFIC?, TaxConnections.
2017.07.05.  Expat Tax: Your Renunciation And When Your CLN Is Issued, TaxConnections.
2017.06 28.  U.S. Culture Of Penalty And Inflation, TaxConnections.
2017.05.21.  FBAR In The Homeland: The Willful FBAR Penalty Requires Proof, TaxConnections.
2017.06.06.  Topsnik 2 : Green Card Expatriation And The Exit Tax, TaxConnections.
2017.05.31.  The Teaching Of Topsnik 1 – 2014, TaxConnections.
2017.05.26.  Part 2: OECD CRS: Tax Residence And The Tax Treaty Tiebreaker, TaxConnections.
2017.05.24.  Determining Tax Residency In The United States, TaxConnections.
2017.05.18.  Tax Treaty Tiebreaker And Reporting: Forms 8938, 8621, 5471, TaxConnections.
2017.05.16.  Tax Treaty Tiebreaker And Taxation Of Subpart F And PFIC, TaxConnections.
2017.05.11.   Establishing Same Country Exemption Through Legislation, TaxConnections.
2017.05.10.   FATCA’s Same Country Exemption Won’t Work, TaxConnections.
2017.05.04. Green Card Holders: Tax Treaty Tiebreaker, TaxConnections.
2017.05.02.   How Exactly Does The Meadow Bill Repeal FATCA?, TaxConnections.
2017.04.27.  FATCA: How Does The Meadows Bill Interact?, TaxConnections.
2017.04.25.   Introducing FATCA – What Does It Mean In Your Life?, TaxConnections.
2017.04.20.  Digital Nomads Using The FEIE To Avoid Paying Income Tax, TaxConnections.
2017.04.18.  Form 8621 And 5471 Are Required Even If The Tax Return Isn’t!, TaxConnections.
2017.03.29.  Capital Gains Tax On Sale Of Principal Residence In Canada,TaxConnections.
2017.03.24.  Did Mr. FBAR Pay A Surprise Visit To Canada?TaxConnections.
2017.03.21.  FATCA Inquisition For Canadians Applying For Life Insurance, TaxConnections.
2017.02.14.  Be Careful What You “Fix For” – Mr. Kentera Meets Mr. FBAR, TaxConnections.
2017.02.07.  U.S. Taxation of the Australian Superannuation? – No! TaxConnections.
2017.01.05.  A Holiday Gift: What To Do About The Unfiled FBAR – Part 2, TaxConnections.
2017.01.04.  A Holiday Gift: What To Do About The Unfiled FBAR – Part 1, TaxConnections.
2017.12.22.  Tax Residency In Canada: Deemed VS. Factual Resident, TaxConnections.
2017.12.19.  Tax Residency VS Physical Presence: 4 Questions You Must Ask, TaxConnections.
2016.12.15.  How To Get A U.S. Social Security Number In Canada – Tax Compliance, TaxConnections.
2016.12.02.  Russia’s “Citizenship Reporting” Requirements – The U.S. Next? Your Taxes May Be Scrutinized!, TaxConnections.
2016.11.30.  Mr. FBAR As A Role Model For President Putin And The Russian Government, TaxConnections.
2016.11.09.  False Form 8854 Used As Part Of “Willful” FBAR Prosecution, TaxConnections.
2016.10.27.  The Internal Revenue Code Versus The IRS Form: Noncovered Expatriate Status And Form 8854, TaxConnections.
2016.10.20.  How The “Assistance In Collection” Provisions In The Canada-U.S. Tax Treaty Facilitates “U.S. Citizenship Based Taxation”, TaxConnections.
2016.10.18.  Canada Pension Plan (And Other “Foreign Social Security”), The “Net Worth” Test, Form 8854 And Form 8938, TaxConnections.
2016.10.17.  The “Exit Tax”: Dual US/Canada Citizen From Birth, No Canada Citizenship Today = No Exemption To US “Exit Tax”, TaxConnections.
2016.10.05.  The US “Expatriation Tax” And The Incentive To Apply For A Green Card And/Or Remain In The USA, TaxConnections.
2016.09.28.  Is Form 8938 Required By “Green Card Holders” Who Are Nonresidents By “Treaty Tie Breaker”?, TaxConnections.
2016.08.26.  Part 1: Tax Treaties, Determining “Tax Residence” And New OECD Common Reporting Standard, TaxConnections.
2016.08.19.  U.S. Citizens’ Foreign Tax Credits Against The 3.8% Obamacare Surtax, TaxConnections.
2016.08.09.  The Interpretation of US Tax Treaties, TaxConnections.
2016.07.20.  What Does The New U.S. Treasury Model Tax Treaty Mean For You?, TaxConnections.
2016.07.14.  Reporting A “Treaty-Based Position”—Internal Revenue Code S. 6114 Using Form 8833, TaxConnections.
2016.07.11.  Changing Taxation-Based Citizenship Through Regulation, Not Law, TaxConnections.
2016.07.06.  U.S. Citizens Are Subject To U.S. Taxation Wherever They Live In The World, TaxConnections.
2016.06.29.  Forms Required By #Americansabroad 101 – The Explanation, TaxConnections.
2016.06.16.  Muhammad Ali, Draft Resistors, And Loss of U.S. Citizenship, TaxConnections.
2016.05.06.  Physical Presence As A Necessary Condition For Being A US “Resident” Under The Internal Revenue Code, TaxConnections.
2016.02.17. “Dual citizen exemption” encourages dual citizens from birth to remain US citizens, TaxConnections.
2015.12.09.  Converting The RRSP To The RRIF Constitutes Opening A New Account And #FATCA Enquiry, Tax Connections.
2016.12.04.  Distributions From Canadian RRSPs Are Subject To #Obamacare Surtax While Distributions From US Plans Exempt, TaxConnections.
2016.11.30.  Part 15 – Understanding “Exit Taxes” Interview with GordonTLong.com – Citizenship based taxation, PFIC, the S. 877A Exit Tax and #Americansabroad, TaxConnections.
2015.11.27.  Part 14 – Understanding “Exit Taxes” “Leaving the U.S. tax system – renounce or relinquish U.S. citizenship, What’s the difference?” TaxConnections.
2015.11.24.  Part 13 – Understanding “Exit Taxes” “I relinquished U.S. citizenship many years ago. Could I still have U.S. tax citizenship?” TaxConnections.
2015.11.20.  Part 12 – Understanding “Exit Taxes” “The two kinds of U.S. citizenship: Citizenship for ‘immigration and nationality’ and citizenship for ‘taxation’ – Are we taxed because we are citizens or are we citizens because we are taxed?”TaxConnections.
2015.11.17.  Part 11 – Understanding “Exit Taxes” S. 2801 of the Internal Revenue Code is NOT a S. 877A “Exit Tax”, but a punishment for the “sins of the father”, TaxConnections.
2015.11.12. Part 10 – Understanding “Exit Taxes” The S. 877A “Exit Tax” and possible treaty relief under the Canada US Tax Treaty, TaxConnections
2015.11.05.  Part 9 – Understanding “Exit Taxes”  For #Americansabroad: US “citizenship taxation” is “death by a thousand cuts”, but the S. 877A Exit Tax is “death by the guillotine”, TaxConnections.
2015. 10.30.  Part 8 – Understanding “Exit Taxes” “The U.S. “Exit Tax vs. Canada’s Departure Tax – citizenship taxation vs. residence taxation,” TaxConnections.
2015.10.28.  Part 7 – Understanding “Exit Taxes” Why 2015 is a good year for many #Americansabroad to relinquish US citizenship – It’s the “Exchange Rate, TaxConnections.”

 

 

 

 

Note:  I have just begun compiling this bibliography.  There are more articles which I will be adding to it over the coming days.  Pacifica.