UPDATE SATURDAY September 15, 2018
(click on the picture for a clearer image)
A Letter from Monte Silver
Americans against the Repatriation/GILTI taxes – within striking distance of winning and you can help! And what to do with the October 15 filing deadline?
On August 1, 2018, the Treasury issued proposed regulations that interpret the Repatriation tax law – a 250 page very complicated document. I discovered that in issuing the document, Treasury seriously violated numerous Federal laws and procedures. This gives us tremendous leverage in negotiating for an exemption from the Repatriation & GILTI laws. It is not unreasonable to expect that this battle may be won by December 15, 2018. As you many have an October 15, 2018 filing deadline, I attach a relevant portion of an IRS publication stating that you may be able to extend the filing date until December 15, 2018. I suggest that you discuss this with your US CPA specialist to see if this applies to you.
cross posted from AmericanExpatFinance.com
By Helen Burggraf, Editor – September 08, 2018
A panel discussion that will consider recent and growing efforts to convince U.S. lawmakers to end America’s increasingly-unpopular “citizenship-based” tax regime is set to take place at a venue in the Mayfair district of London, on the 18th of September.
UPDATE 10 SEP 2018
Gary Clueit In the example of the Covered Expat inheritance 40% tax on heirs I gave during the interview, I misstated that there was no credit available for any foreign estate tax or IHT paid, giving the UK as an example. Apparently, the amount due to the IRS can be offset by any amount paid to a foreign country. It makes no difference in my case, since my domicile is a country that has no estate or inheritance tax.
Also, only 4 OECD countries (Japan, South Korea, France, UK) have an estate tax equal to or more than the US. Every other country either has none (including 15 OECD countries), or is at a lower rate than the US. Which means, unless you are domiciled in one of the very few high tax countries, your heirs will still lose a significant portion of their inheritance.
It is one thing to pay death taxes where you are living/domiciled. It is an entirely different matter to have to pay anything to somewhere you once lived, left and paid an exit tax on ALL unrealized gains at the time. And zero credit for any increase in wealth since you departed.
Exceptionalism at its best!
“…. and the US government is my best business promoter”
“I’m livin’ high on the hog”, says Blackie the Black marketer in my followup interview. “I’m selling non-US citizenship like hotcakes…..I can’t keep up with demand.
Some of you might remember that I interviewed Blackie years back, when President Obama had hiked the fee to $400 for renouncing U.S. citizenship. Blackie had established a business selling fake Certificates of Loss Of (United States) Nationality (CLN), after the fake-American-passport business had dried up.
Not long after that, demand for non-citizenship was so high that President Obama hiked the fee again to $2350. “The business model I started based on $400 competition skyrocketed when the fee went to $2350” explains Blackie. “Whereas the president was marketing a product at the $2350 level, I undercut it and gave them the same paper at a fraction of that price”
“I’ve been able to make this into a full-blown enterprise, with employees…I even hire marketing consultants to analyze my market segments and give me tips for where to go next” he explains.
Update 27 August 2018
interesting: One of the factors irritating to the EU is the “repatriations of billions of dollars in profit from Europe by U.S. based tech giants” (Bloomberg) an outcome of course, from recent U.S. tax reform (TTFC)
I have become fascinated by an ongoing development in Europe stemming from Trump’s actions against Iran. First, there is the United States pulling out of the Joint Comprehensive Plan of Action
JCPOA, (aka the Iran nuclear deal in which Iran promised to stop development of its nuclear program in return for a lessening of sanctions and increased trade relations). After the withdrawal, Trump issued harsh sanctions against Iran.
Over the last couple days, a number of expats have tweeted/posted a
condensed version of this story. I was curious know more about it.
On August 21, German Foreign Minister Heiko Maas wrote an editorial for the German paper, the Handsblatt. He called for a “balanced partnership” as counterweight to the US actions regarding Iran.
At first, this might seem completely unrelated to our situation however, one aspect of this “Balanced Partnership” may include an option for trading outside of the U.S. SWIFT system.
from The Nation
Interesting that FATCA, which predates CRS is not mentioned here.If the U.S. were interested in reciprocity, wouldn’t this be the focus? In fact, this is not FATCA or CRS. It is plain and simple discrimination. If the U.S. continues making the U.S.an unwelcome place for immigrants, we may no longer have to listen to the nonsense that our leaving is irrelevant due to the much larger numbers of people clamoring to get into the United States of America.
Panel discussion with John Richardson, Solomon Yue, Olivier Wagner and Jim Gosart.