Background …
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?
@SolomonYue is apparently having discussion with (I think) Congressman Holding’s Office with a view to effecting positive legislative change (although it’s too early to see exactly what that might mean). In order to contribute to the discussion, it’s important that legislators understand why and how applying U.S. tax rules to “tax residents” of other countries (Canada is another country) is so horrible, wrong, immoral, life destroying, etc.
The previous Brock post was my attempt (at the request of JC), to encourage Brock readers, to provide examples that explain how U.S. tax policy has destroyed the lives of those who have attempted compliance with U.S. tax laws. This was an attempt to solicit responses from those who have actually attempted compliance. It is NOT an attempt to solicit responses from the “silent majority” who have not and will not comply. I repeat, this is an attempt to solicit responses from those who have attempted compliance.
Also, this post is focused on the Income Tax related issues and NOT the FATCA induced banking problems. Please let’s keep some focus here!
It would nice to have contributors from all over the world!!!
What happened to the previous post? Why a “Chapter 2”? Why a second attempt?
Read the previous post and comments to see …
What did come from the post was a comment from Pacifica that suggested:
@USCA,
That comment you made earlier this evening went into incredibly explicit detail (and yet really clearly with those bullet points) about the project you and JC are working on. Thanks for taking the time to do that.
Why not make a new post for the project, using that comment for the post itself, as this thread has really diverged?
Okay. Here is the comment to which Pacifica refers:
This post is in response to comment/request from JC to collect stories about how compliance with the tax rules that apply to overseas Americans (1) create huge difficulties in their lives and (2) make compliance with U.S. tax laws “somewhere between difficult and impossible” and (3) unfairly burden U.S. citizenship for those who ARE filing U.S. taxes and (4) I think that force the renunciation of U.S. citizenship would be appropriate.
I point that one can be a “proud American” and still be forced to renounce U.S. citizenship. In fact, I have met quite a few of them.
The story must be from one who has filed U.S. taxes to the best of his/her ability. What seems clear from the JC information and the “tweets” is that the focus on this discussion is specific examples of how compliance has ruined your life.
I would think that this would include (but not limited to):
– entry into OVDP or Streamlined
– PFIC issues
– inability to find competent tax preparation help
– unjustified penalites
– PFIC confiscations
– CFC problems: Any kind of Subpart F income (including the transition tax and GILTI), problems with the 5471
– punitive U.S. taxation of non-U.S. retirement planning and pensions
– imposition of U.S. capital gains tax in countries that don’t have capital gains tax in general or specifically on the sale of the principal residence
– additional taxation caused by the necessity to use the “married filing separately category” if married to an alien who doesn’t want to be part of the U.S. tax system
– Australian Superannuation
– Punitive taxation of foreign life insurance policies with cash value
– inability to buy into non-U.S. businesses because of U.S. citizenship
– Paying REAL U.S. tax on FAKE U.S. income, generated by the interaction between the U.S. dollar as the functional currency and exchange rate fluctuations
– etc.
It seems to me that stories from those who felt forced to renounce would/could be compelling.
But, please take your cue from the part of the post that quotes JC. I wrote the post primarily on his behalf as his messenger (if you will).
But, again stories from those who have not complied are irrelevant to this thread.
(Incidentally, if you are a U.S. citizen abroad who IS filing U.S. taxes and you do not recognize any of the issues outlined: You are probably not filing your U.S. tax returns correctly!)
Who should respond to this request?
People who have attempted to comply with U.S tax laws while living in other countries WHO ARE/WERE subject to the tax laws of the country where you live. You do NOT have to currently be a U.S. citizen. The fact that U.S. tax compliance from abroad forced you to renounce U.S. citizenship is highly relevant.
Those who commented on the previous thread are invited to repost your “relevant” comments on this thread. Hopefully, this new post will encourage more participation.
Thank you …
____________________________________________________________________________
Footnote -for the purposes of context, here is JC’s original “request” …
News from Twitter chat with Solomon Yue. He says we may see the TTFI legislation this coming week. One comment to that is ‘we have heard that before.’
It sounds like the treatment for Accidentals will be three years of compliance without FBAR & FATCA penalty and then may elect TTFI status. Comment to that: sounds like streamlined except 3 years instead of 5.
Karen says:
“Essentially, TTFI is saying go thru streamlined and then stop filing. For AA’s and LT expats that want to retain USC, this is a reasonable deal as long as they have no PFICs or CFCs or “foreign” pensions, or ….”Essentially, TTFI is saying go thru streamlined and then stop filing. For AA's and LT expats that want to retain USC, this is a reasonable deal as long as they have no PFICs or CFCs or "foreign" pensions, or ….
— Fix the Tax Treaty! (@FixTheTaxTreaty) May 12, 2018
Point of information about the above: FBAR and FATCA 8938 still exist under TTFI – so still filing! However, I ask as 8938 requires specification of the line on the 1040 return income from specified assets appears, and if no return is required under TTFI then would that end 8938? The devil is in the detail.
Solomon Yue says he will ask the question about PFIC and its exemption. At least someone is listening (Solomon Yue). He has said before about the exemption of foreign pensions, yet it has always been in regards to after TTFI election, and not the 3 years compliance period before one may elect TTFI.
In terms of AA: he has stressed that the TTFI bill is about asking Congress to do something for those who wish to remain American citizens, as the best chance to get buy in from Congress. Then of course once passed he will focus on other changes. So it sounds like perhaps multiple bills: 1) TTFI, 2) remove transition tax and GILTI from US Corps overseas, 3) remove FBAR and FATCA for USP overseas, 4 or more) Dems have a few including one that eliminates Social Security WEP. All this and there is no precedent of passage of a single focused bill helping US Persons overseas.
I asked Solomon for a Preamble on the TTFI speaking about the injustices. He declined such preamble and it will be only to align with TTFC.
Re: PFIC. A thought of today is a new acronym is needed for this. I like the word “curse” today. So Punitive Foreign Investment Curse for U.S. persons living overseas, or PFIC treatment. Innocuous and purposeful sounding names for these things should be changed to more representative names. Else, IMO, we give in to the narrative of the U.S. Compliance-Congressional Industrial Complex. Of course a name including “curse” would never fly in compliance code with DNA predisposed toward compliance. But we may give it a nick name.
Re: Cursed Foreign Corporations. This is what SY says:
Regarding small business owners abroad: we need 3 things 2 be done 4 them: 1) Pass #TTFI 2 connect w/ #TTFC, 2) exempt them from the transition/GILTI tax, 3) allow them 2 elect S Corp pass-through (corporate salaries/distributions r reported as personal foreign-source income).
Regarding small business owners abroad: we need 3 things 2 be done 4 them: 1) Pass #TTFI 2 connect w/ #TTFC, 2) exempt them from the transition/GILTI tax, 3) allow them 2 elect S Corp pass-through (corporate salaries/distributions r reported as personal foreign-source income).
— Solomon Yue (@SolomonYue) May 12, 2018
Solomon Yue says that he likes this story about being Proud Americans, and has already used it:
Tamar says:
I’ve said this b4: I’ve raised my kids (Israeli expats) w/spoken English at home & proud of their US origins despite leaving as toddlers. One son refused any Army job that wld require him to renounce! Get rid of #CBT & expats can be proud US ambassadors & trade promoters again.I've said this b4: I've raised my kids (Israeli expats) w/spoken English at home & proud of their US origins despite leaving as toddlers. One son refused any Army job that wld require him to renounce! Get rid of #CBT & expats can be proud US ambassadors & trade promoters again.
— Tamar (@tdbho) May 11, 2018
So do we have a feature here on Brock to come up with stories about being proud Americans? So we may give them to Solomon.
Do you have a deadline for this? I’d like to know that for its chronological placement on the Take Action! sidebar and the Projects index page. Thanks.
Here is the exchange that has started this post:
@Tamar
I’ve said this b4: I’ve raised my kids (Israeli expats) w/spoken English at home & proud of their US origins despite leaving as toddlers. One son refused any Army job that wld require him to renounce! Get rid of #CBT & expats can be proud US ambassadors & trade promoters again.
@Solomon
If you don’t mind, I will share what you just told us. Lawmakers & JCT need hear your son’s story and do what is right by him – the 25% we all need to focus on during this #TTFI legislative process. Thank you for share this.
@Tamar
2)I can’t speak for expats in other countries, but in Israel e.g. we usually celebrate Thanksgiving – as do our now-adult “AA” kids with their own friends. Many hang joint US-Israeli flags or have such pins. We LOVE America, just not what it’s doing to us.
@Solomon
I already used your son story. Thanks.
END.
@Tamar, is not 100% in support of the compliance. Quite the contrary.
@Tamar,
I just think it’s nuts that my daughter who’s in overdraft to feed her toddlers is trying to figure out how to save enough to pay a CPA bec. we can’t do it ourselves. And she left US at age 4…
@Tamar,
She’s on her 1st job, husband still a student, 2 kids & she’s saving up money so she can pay a CPA to do her US taxes,#FBAR etc. And they call us tax evaders?! She’s doing this to pay unjust taxes bec. not complying would never occur to her.
@Tamar, [makes a plea to exclude AMT:]
Please! & Thank you! I don’t think that ppl realize that AMT can destroy TTFI if not expressly excluded – and certainly that is not @RepHolding ‘s good intentions!
@Tamar [AMT]
That’s why it would be fantastic to add a few words to make clear that #TTFI electors are exempt from AMT. Otherwise yes, this is one of the reasons we all need CPA’s & can’t prepare our own taxes: everything has to be run twice & include an AMT calculation.
@Tamar [thinks, no longer have to file FBAR & is concerned about PFIC]
So #TTFI bill is clear that once you qualify you no longer have to file FBAR, Form 8938 (if applicable), & are free of PFIC rules (even if u still have to file re remaining US stock investments)? G-d bless.
@Tamar [PFIC]
I *don’t* want to renounce, but PFIC has *tremendously* harmed us financially & will be worse now that we’re at an age to invest in tax-advantaged (here) retirement funds! “Foreign” income is barred from IRA’s & we too need retirement incentives.
@Tamar [PFIC]
I don’t trust any law or reg. to disappear by default. Also, we expats with US Source income cuz we couldn’t invest in PFIC’s will still have to file 1040NR.
And PFIC has got to go; hopefully everything that considers my own country foreign to me has to go!
@Tamar [complains about WEP]
This issue, too, is crucial: Can you imagine retirees waiting a year & then having to file for a refund of the Soc. Sec. they’re supposed to be living on? Or even worse, having to stay in #CBT, AND wait for a yr for refund while on fixed income?
@Tamar [renunciation]
It’s much like unrequited love: We taught kids far from US to love it & be proud of their US origins- & keep being pushed out w/more 2x taxes, compliance, #GILTI by those who see us as evil for leaving tho we ask for nothing-love us back & enable us to stay!
@Tamar
3) My daughter married non-US citizen. Impossible tax situation! She *doesn’t* want to have to renounce. She even considered going the “grandparent” route to get citizenship for her kids, but she just can’t do that to them without #TTFI, etc. But she spks to them in English…
@Tamar
1) Please do .Proud US expats lit. bridge their 2 countries language & culture gaps-promoting & expediting trade etc. But the impossibility of #CBT #FBAR & #FATCA has made us objects of sympathy rather than envy.We can’t go on like this, but we want to stay citizens if you’ll us.
I renounced when the IRS told me their reason for penalizing me was that I wrote honest declarations on tax returns. I obediently committed perjury on every subsequent refiled and newly filed US return, but I don’t willingly agree to commit perjury. It’s illegal to tell the truth on US returns[*], I thought it was illegal to sign known false statements under penalty of perjury, it’s illegal to not file, so there was only one way to minimize the number of times I would have to commit perjury.
The IRS’s Taxpayer Advocate reported to Congress on 2011-12-31 that there were thousands of others just like me, honest taxpayers who find themselves forced to renounce.[**]
[* The IRS never pointed me to Internal Revenue Bulletin 2005-14. I found it accidentally. But it seems that the IRS, out of character, told the truth for a change, that writing an honest declaration really is illegal.
https://www.irs.gov/pub/irs-irbs/irb05-14.pdf
Search for the word “jurat”.]
[** http://www.taxpayeradvocate.irs.gov//userfiles/file/TAS_arc2011_execsummary.pdf
Page numbers 14 and 17.]
“3) My daughter married non-US citizen. Impossible tax situation! She *doesn’t* want to have to renounce. She even considered going the “grandparent” route to get citizenship for her kids, but she just can’t do that to them without #TTFI, etc. But she spks to them in English…”
Maybe we should leave language out of this discussion, because a real American would speak to their children in Navajo, Cree, Cherokee, etc.
Starting over. Here’s my contribution again: a letter, written in my husband’s name, to the disingenuous–nay, fake–request for statements by the Senate Finance Committee in 2015. As far as I recall, we sent an abridged version to someone in RO to include in the short stack of letters recently being carried around Washington by Solomon Yue.
———————————–
Call me David. I won’t tell you my full name, because I am about to incriminate myself in a terrible crime.
I neglected to fill out a line on a form. For that, I stand to lose every penny I own, my home, my daughter’s education I’m paying for, and not even see her graduate because I may be in prison. But first, some background about me.
I am a born-and-bred United States citizen, who has lived in Hong Kong for over 20 years. I came for a job, which turned into a career, and after awhile Hong Kong simply became home—no different than if you were born in St. Louis but later settled in Seattle.
My children were born and raised in Hong Kong, but guess what their favorites were among all the bedtime songs I sang them every night—“God Bless America” and “America the Beautiful”. I am not making this up!
You’d have found no better ambassador for the USA than me. I can’t tell you how many thousands of times I’ve stood up for the USA against the criticisms of my non-American friends, making the point that the United States of America is a free society in which everyone can speak their mind and in which citizens can expect to be treated fairly.
I earn what would be considered a middle-class income in the United States. My wife and I have never earned more than the foreign earned income exclusion, and have never owed a penny in US income tax. I do my own returns, and the IRS has never doubted them. Please note: I am not some high-flying financial wheeler-dealer engaging in shady money laundering and tax dodging schemes. Even if I wanted to be that—and I do not—I don’t have near enough earnings or savings to do so.
For years, though, I’ve had a creeping feeling that my government sees me that way, that just by the fact of my being an American abroad, I must therefore be a tax cheat. Recent disclosure laws confirm this feeling of being treated like a criminal—some of my documents aren’t even handled by IRS normal channels anymore, but by their financial crimes unit!
In fact, the IRS has made me into a criminal, without my performing a single harmful act. I have faithfully, each year in June, reported my Hong Kong bank accounts to the Treasury Department, and now, under the new laws, to the IRS Financial Crimes Enforcement Unit. But guess what? It turns out that I neglected to report my official Hong Kong provident fund account, which I’ve maintained for 13 years. This isn’t a bank account, more like a 401k, and it isn’t voluntary; all employed Hong Kong residents are required to contribute, just like Social Security. It holds about $120,000. Not nearly enough to retire on, but it’s all I’ve got. Meanwhile the Hong Kong government won’t let me touch it. So maybe you’ll understand that, while I faithfully reported my BANK accounts—ones with money moving in and out, which are under my immediate control, it didn’t occur to me to report the existence of an account that holds no cash—it’s all securities—and which is beyond my reach until I retire.
But I’ll tell you what: I don’t plan to report it. There, I’ve incriminated myself. The US government has turned me into a criminal. After all, there’s no advantage for me to start reporting it now.
If I do report it, and the IRS deems that I “willfully” neglected to report it, they can mete out punishment of 50 percent of the account’s value per year of non-reporting, and toss me in jail for five years. In other words, the IRS can demand multiple times the actual value of my entire retirement fund and make me spend years in prison! If they determine that I was “non-willful” in my lack of disclosure—in other words, an understandable oversight—I will be charged “only” $10,000 per year of non-reporting for the past six years. In other words, if I’m innocent, then I only lose half of my entire retirement in one fell swoop.
All for neglecting to file a form which has no effect whatsoever on my tax situation!
And who determines willful versus non-willful? The fact that I did report other accounts but not this one deprives me of the “ignorance of the law” defense, so by such logic, my neglect was willful. But actually, the law offers no objective guidelines and it’s up to the examiner to make the call. And the way the law is worded, I am presumed guilty unless I can satisfy the IRS that it is otherwise. Thus, if the IRS examiner had a fight with her husband the night before, I can be made destitute, robbed of not only retirement but the home I live in.
So what happens if I don’t report this account and get caught? Same scenario as above. But if I never get caught, then no fines. I’ll take that chance.
How can my government threaten to wipe me out, steal my retirement from me, leave me destitute and turn me into a criminal, all over a line in a form?
Where does it stop? Do I need to report my supermarket membership loyalty account, which currently holds over a hundred dollars in purchase credit? What about my public transport stored value ticket, which regularly holds over $50? Must I report these as well or face up to five years prison time, according to the law? Well, I refuse to!
Furthermore, it takes me three or more full working days each year to complete my US tax forms…in order to come to the same final figure year after year: that I don’t owe Uncle Sam a dime. The alternative is to pay a preparer $2000 to do so, money that at my income I can’t afford. This compares to the mere 30 minutes I need to fill out my Hong Kong tax form. I do my utmost best to be honest and detailed in my reporting. Yet even after such care in doing my US forms, the obtuse complexity of the forms, the regulations, and the labyrinth of deductions and charges, makes me tremble with fear that an inadvertent mistake on my part could trigger a devastating and expensive audit, and penalties and legal fees that could wipe me out.
Meanwhile, what does the US government gain from all this? The vast majority of American expatriates I’ve met in the past twenty years are very much like me: middle-income earners—teachers, journalists, public relations executives—who, like me, never earn enough to actually owe any US taxes. Yet the IRS spends hundreds of millions of dollars in processing our returns, in investigations and enforcement. Certainly, taxing Americans abroad and prying into their bank statements is not a profitable venture for the government. At the same time, it only serves to alienate people like me.
Because I am sick and tired of the paranoia that has overtaken my life, all as a result of US government prying into my financial affairs, and the potential destitution that a few simple oversights in tax and account reporting could lead to, all because my government presumes that I, along with all other American expatriates, is a tax criminal.
I’m fed up. It is my intention to renounce my US citizenship rather than live with this fear. I intend to apply for full citizenship in Hong Kong. Yes, believe it or not, I would trade my US citizenship to become a citizen of the People’s Republic of China. Not because I have a single droplet of love for the Chinese government. It isn’t to avoid US taxes, since, as I said, I’ve never earned enough to owe any. But because I feel more fear for my well-being, and more burden, both financially and psychologically, as a US citizen than I do for my personal safety as a citizen of the Hong Kong Special Administrative Region of communist China. At least as a Chinese citizen I know I’ll be able to afford to retire.
It isn’t too late, though. The US Congress could change the law, bring it in line with every other developed, civilized, powerful nation, and end the taxation of its citizens living abroad. End the prying into every aspect of where we put our money. Let me continue to be a proud and effective ambassador for the United States, who believes that the USA can, and should, be a force of good in the world, not one that treats its own citizens like criminals.
@Barbara, I tweeted that to Solomon Yue:
https://twitter.com/JCDoubleTaxed/status/997281673610854401
K. I e-mailed your story to Solomon Yue.
@solomon Yue:
#TTFI is designed to help Barbara & her husband David. Both should to attend my talk at AmCham Hong Kong on May 25. They can register here: https://amchamhk.eventbank.com/event/8210/#
https://twitter.com/SolomonYue/status/997286782700929024
E-mail from Solomon Yue:
both are great stories. I will use both.
Barbara and David should be encourage to attend my talk in Hong Kong on 5/25. Please contact them.
Anthony Parent’s interview with “Julio” might be compatible with this new thread. I don’t know if Solomon Yue could get the go-to guys to sit down and watch this video but I wish they would. This is a man who wants to be compliant but the cost to do so is formidable.
It would be nice to have a Brocker at the Hong Kong event.
SY says that at that event on 25 May that he will provide much more detail “outline” of TTFI:
I’m waiting 4 a final #TTFI outlines 2 present at an AmCham Hong Kong event on May 25. https://amchamhk.eventbank.com/event/8210/# All my ?s have further delayed the legislative text release. Agree w/ better late/good than earlier/insufficient. I’m also mindful abt missing this yr legislative window
https://twitter.com/SolomonYue/status/997139764309458944
In the past, there was a letter from a couple who lived in Toronto and sent to the president. I can’t find it anymore- but maybe one of you remembers? They were tax compliant ( I think teachers at a University?) and said that they had to give up their citizenship because they could no longer comply. Somehow I remember the name “Mary”. Something about retirement too. Was it a letter from Mary to the president? I think she explained in the letter what their dilemma was, hoping that the president would help.
@ Polly,
I think it’s this one. Marilyn and her husband are retired university teachers (she’s also a retired lawyer), in Canada 43 years (47 now), daughter born in Toronto. Hadn’t renounced at time of letter, but did so not long after (video page mentions that).
Letter:
Dear Mr. President, Why I’m Leaving America, by Marilyn, Forbes.
Discussion:
http://isaacbrocksociety.ca/2014/08/17/dear-mr-president-why-im-leaving-america-writer-tried-hard-to-be-tax-compliant-americansabroad/
Video:
https://vimeo.com/citizenshiptaxation
This approach of “humanizing ” expats is reminiscent of MLK’s ” I am a Man”. The more stories the better. When people actually hear what we are saying they are incredulous and sympathetic. Good Luck
@Barbara SY just tweeted part of your story here:
https://twitter.com/SolomonYue/status/997599519943491585
Pls RT/Like
Well in that case, Barbara’s husband David and I may end up as enemies. This is because I am preparing to naturalize in Taiwan, despite the possibility of conflict with China. I am more afraid of my own government than I am of China’s (and that is even after reading this morning’s article about the concentration camps in Xinjiang, where nearly a million Uygurs and Kazakhs have been forced to eat pork, drink beer, and denounce Islam). This is ironic, since US military power is the main thing preventing Taiwan’s annexation by the PRC.
Two things caught my attention about Solomon Yue’s tweeting of my husband’s message:
“…some want 2 make a STMT/cut…”
What the heck is a “STMT”? Can someone enlighten the rest of us?
“So no TTFI vote this year.”
Which means two things:
1) It means TTFI vote…never. By next year, Democrats will increase their membership in Congress, if not gain outright majorities. Which means TTFI is dead.
2) Which begs the question: why are we sharing these stories right now? I get it that Solomon Yue wants (wanted) them to add weight to his discussions with Rep. Holding. But if it’s too late to add to the legislative agenda, what is the intended purpose/target of this effort?
stmt–“statement”
sy has bd hbt of mkng incprhnsble twts
@pacifica
Yes- thats it.
Another opportunity to let your concerns regarding the #TransitionTax be known. The irony is not lost on those whose overseas businesses will be destroyed by the R/T Tax and #GILTI. The Committee on Ways and Means Tax Policy Subcommittee Chairman Buchanan Announces Hearing on Tax Reform and Small Businesses: Growing Our Economy and Creating Jobs.
Only the tax compliant face bankruptcy/loss of retirement funds. The other 80% of Americans abroad with corporations don’t have anything to worry about come June 15.
https://waysandmeans.house.gov/wp-content/uploads/2018/05/20180523TP-Advisory-2.pdf
Re: some want to make a statement. Translation, IMO:
Some want to have one bill to fix all the ills. One may get an idea from all the tweets from @Tamar listed above that Tamar along with a number of others were trying to confirm various provisions of the TTFI such as exclusion of AMT, PFIC, etc before and after TTFI election.
Solomon believes that if he tried one bill for everything that would reduce the chance for passage (he is worried about Congressional resistance to perceived loopholes for Fatcats). Then such bill (with everything in it) would be a statement (because less likely to pass) rather than fixing some of the problems. Once some of the problems are fixed he will pursue more fixes. We have yet to have a dedicated bill passed for USP Overseas actually reducing the over-regulation. That would be a positive step and precedent.
@Barbara will you be there on the 25th? You had a very nice story in regards to Hong Kong before his presentation in Hong Kong.
Solomon liked to tell the story of a law firm in Hong Kong that had 25 American citizen lawyers, but as the cost of hiring Americans, he says is 40% more than non-Americans, that this number has dropped to 1 lawyer.
It does not sound like you are a lawyer. It is important that a range of people factor into the changes of TTFI.
His plan is to get the initial TTFI passed before the midterms.
I think he wants some positive stories/positiveness as any organisation/workplace wants positiveness when working to change something. I think he wants positive stories of Americans overseas to tell to Holding and others to encourage them.
@JC: I’d attend Solomon Yue’s presentation in Hong Kong, but I am not there until mid or late June. It’s a shame, since I’d have liked to speak with him in person.
But I still don’t get it: is it absolutely certain there will be no bill sent to Congress this year?
@Barbara. Solomon is intending a TTFI before the midterms. He will reveal more information about this on the 25th.
@JC: Thank you for the clarification. Solomon’s tweet was unclear on this point.
I look forward with baited breath to his announcement this Friday. Wouldn’t it be nice and fitting if he issues a “shot heard around the world” against extraterritorial taxation from another ex-British colony!