“UPDATE: FATCA: Citizenship-Based Taxation, Foreign Asset Reporting Requirements and American Citizens Abroad” is a comprehensive article in the New York University Law Journal on the evolution and current situation of FATCA/CBT/citizenship by international lawyer and retired US Foreign Service Officer Andrew Grossman. It’s well organised, both very detailed and easily readable for the layperson, with plenty of links throughout for those seeking further information on the various aspects. It’s an update of his article which was posted here around five years ago.
On 19 July 2023 the Ways & Means Tax Subcommittee held a hearing entitled “Biden’s Global Tax Surrender Harms American Workers and Our Economy.” Stop Extraterritorial American Taxation (SEAT) notes that this hearing presents an opportunity to give the House Committee on Ways & Means your feedback on both (1) specifically, the hypocrisy of their position regarding unfair taxes, and/or (2) more generally, the impact of nationality-based U.S. extraterritorial tax policies on the lives of Americans who live outside of the United States.
Send to: WMSubmission@mail.house.gov.
SEAT notes that submission guidelines are at http://waysandmeans.house.gov/wp-content/uploads/2023/07/ADVISORY_Tax-Subcommittee-July-19-2023.pdf and points out the following:
Please ATTACH your submission as a Microsoft Word document.
All submissions and supplementary materials must be submitted in a single document via email, provided in Word format and must not exceed a total of 10 pages. Please indicate the title of the hearing as the subject line in your submission. […] The name, […] address, [and] telephone numbers of [the person making the submission] must be included in the body of the email. Please exclude any personal identifiable information in the attached submission.
SEAT has submitted a statement to the Committee and encourages you to provide your own personal statement.
September 24, 2018
updated 1:02 PM CEST, Sep 27
Legislation that its proponents say would significantly improve the lot of American expatriates, many of whom have been left reeling by the Trump tax reforms introduced at the end of last year, will be introduced in Congress before the end of the month.
This was the message delivered to a London audience of around 80 mainly expatriate Americans last week by Republican Overseas global chief executive Solomon Yue, (pictured above, far left, and below), and again a few days later to an also mainly expat audience in Paris.
Today Yue is due to bring his message to expats in Frankfurt, with similar events scheduled for Berlin and Rome over the next few days.
Yue’s appearances were his latest on a global whistle-stop tour of key foreign business centers around the world that aims to rally support among – and ideally as well, the active involvement of – American citizens living abroad for legislative changes in the way their country currently taxes them, in the run-up to the midterm elections in November.
Panel discussion with John Richardson, Solomon Yue, Olivier Wagner and Jim Gosart.
In addition the meeting mentioned below, we would like to have a second, more informal program for expats and their families and friends. This format would be a more intimate question and answer which will be focused on individuals subject to the CBT regime. This would take place on Sunday, August 12, from 2:00 – 4:00 pm on the U of T campus. We need a confirmed number of individuals before booking a room. If you are interested, please email nobledreamer16 at gmail dot com Cost: $20
A LIGHT AT THE END OF THE TUNNEL OR ANOTHER ONCOMING TRAIN: THE POSSIBLE END OF U.S. CITIZENSHIP-BASED TAXATION
If you are an American citizen residing and doing business in Canada, you bear the pain of the heavy tax burden endured by all U.S. citizens due to the fact that the U.S. is the only major country that imposes worldwide taxation on its citizens no matter whether they live in the U.S. or in another country. In addition, the U.S. imposes significant penalty laden reporting requirements on U.S. citizens living in Canada and abroad.
Change is a possibility.
Did you know that there is a possibility that the U.S. Congress may introduce, debate and vote upon a bill that may ease this worldwide taxation burden on U.S. citizens living and working in Canada? This bill would enact ‘Territorial Taxation for Individuals (TTFI)’. It is a tax cut for 9 million overseas Americans by ending double taxation.
Solomon Yue, CEO of Republicans Overseas has been involved with drafting the TTFI bill. Mr. Yue, who is currently working with AmChams throughout the world, will present publicly shareable information about the TTFI bill, and discuss its progress as it journeys through the legislative process. He will be encouraging AmCham Canada to lend its support in the global effort to encourage Congress to move forward with this legislation.
According to an article by Michael Cohn in Accounting Today, a multi-lateral tax enforcement group has been formed. The Joint Chiefs of Global Tax Enforcement (or J5 for short), intend to “collaborate in fighting international and transnational tax crimes and money laundering.”
U.S., U.K., Canada, Australia and Netherlands form international tax enforcement group https://t.co/x3bX03Ardw Enough Already! We've got Treaties, #FATCA , #CRS When will it end? pic.twitter.com/4DRrjKSVhg
— Citizenship Taxation (@CitizenshipTax) July 1, 2018
Membership of the J5 includes the heads of tax crime and senior officials from Internal Revenue Service Criminal Investigation (IRS CI), Her Majesty’s Revenue & Customs (HMRC) in the U.K., the Australian Criminal Intelligence Commission (ACIC) and Australian Taxation Office (ATO), the Canada Revenue Agency (CRA), and the Dutch Fiscal Information and Investigation Service (FIOD).
Leaders of the group met Thursday in Montreal to formulate their plans. The J5 plans to work together to gather and share information and intelligence, as well as conduct operations and build capacity for tax crime enforcement officials. Areas of focus include cybercrime and cryptocurrency, data analytics, and enablers and facilitators of tax crimes. The alliance will concentrate on building international enforcement capacity, as well as enhancing operational capability by piloting new approaches and conducting joint operations, to bring perpetrators who enable and facilitate offshore tax crime to justice
In the last little while, there are 4 new Accidental American groups which appear to be under the umbrella of Fabien Lehavgre’s group ( website , Facebook , Twitter . I don’t believe I have seen any of these mentioned here so want to be sure this information is available so people are aware of it.
For those of you on Facebook and Twitter, kindly share, RT and like these pages. Thanks.
— Accidental Americans (@USAccidental) June 2, 2018
— Accidental Americans (@USAccidental) June 3, 2018
— Accidental Americans (@USAccidental) June 3, 2018
Les "américains accidentels" de Belgique s'organisent.
Rejoignez-les en envoyant vos coordonnées à firstname.lastname@example.org pic.twitter.com/k8Flx1zMJq
— Accidental Americans (@USAccidental) May 7, 2018
In a rare instance of “concern” for Americans abroad, Congressman George Holding (Republican North Carolina) may be proposing a bill that could allow some U.S. citizens to live outside the United States and NOT be subject to U.S. tax on their “non-U.S. income”. This would be a “shocker” and a real “Game Changer”. Unsurprisingly this possible initiative has large support including support from ACA, Republicans Overseas, Democrats Abroad, Accidental Americans, etc. Each of these groups (yes each of them) has contributed to and supported this initiative in various ways. Even so, there are partisan fault lines …
There are certain groups/individuals who would NOT support this change (some for ideological reasons and some because they don’t believe the changes would benefit them personally). In any event …
How you can follow the developments …
Interestingly, @SolomonYue of (dare I say) Republicans Overseas, is actively communicating with individuals impacted by this in an ongoing Twitter discussion. “JC” of Isaac Brock fame, (who you all know) is also an active contributor to the Twitter conversation. (You will see other participants) who you will recognize.
In any event, as you all know, the central issue is that U.S. tax policies:
1. Make it impossible for U.S. citizens to move from the United States AND integrate into the tax systems of other countries (if you don’t “quite” understand this, then this post is not for you);
2. Impose very severe punishment on those who (ironically) do attempt compliance with this collection of U.S. tax laws that make life impossible.
As I suggested in the previous post, it seems to me that:
The penalties imposed on Americans abroad who attempt U.S. tax compliance, are far worse than:
The penalties imposed on Americans abroad who do NOT attempt U.S. tax compliance.
The purpose of this post and the anticipated comments is to explain why this is the case!
So, why I am writing this post?