![Updating Citizenship-Based Taxation - Regulation, Legislation or Both?]()
September 4, 2021
September 4, 2021 - Participants include:
John Richardson - @Expatriationlaw
Elliot Bramham - See bio below.
On September 3, 2021 Bloomberg published a fascinating article called "Updating Citizenship-Based Taxation". In describing the US extraterritorial tax regime, the author states:
"As of now, the current system effectively creates a new taxation regime for every jurisdiction in which the overseas citizen resides. Beyond mastering the tax code, agents are required to navigate the laws and financial products of multiple jurisdictions in addition to being versed in any bilateral taxation treaties and social security agreements in place."
This podcast is an interview with the author - Elliot Bramham. The podcast includes a discussion of the US extraterritorial tax regime and why it has driven the need for specialized financial planners who recognize and understand why US citizenship creates hurdles in financial and retirement planning. In addition, the article recognizes that the problem of citizenship-based taxation can be solved through either regulation or legislation ...
To whom much has been given (US citizenship), much is expected (US citizens)!
Bio:
Elliot Bramham is an international graduate in financial management and laws. Wanting to enable others to reach their full potential, he moved to the United Kingdom to begin a career in financial planning.
Linkedin:
https://www.linkedin.com/in/elliot-bramham/
![Part 1: Renouncing US Citizenship? Valuation of joint interests (including the family home) in the context of the 877A Exit Tax Rules]()
June 6, 2021
March 17, 2021 - Participants Include:
John Richardson - @Expatriationlaw
More and more people are taking the steps to renounce their US citizenship or to abandon their Green Cards. US citizens who renounce US citizenship and Green Card holders who are "long term" residents are potentially subject to the Exit Tax rules found in Internal Revenue Code 877A.
Those who expatriate with a net worth of 2 million USD or more will (unless they have the benefit of the dual citizen from birth exemption) be subject to the 877A Exit Tax.
Many people who expatriate own property jointly with a spouse. There are different forms of joint ownership. The most common form of joint ownership in Canada and many other countries is "joint tenancy".
Therefore, the question of how "interests held in joint tenancy" should be valued is vitally important. It can make a difference between whether an individual is a "covered expatriate" or not.
Assuming one is a "covered expatriate", it is also important to understand how the Exit Tax rules apply (in the context of joint tenancy) assuming one is a covered expatriate.
This podcast is an excerpt from a presentation given by John Richardson on March 17, 2021
Obviously it is not intended to be and should not be relied upon as legal advice for any specific individual.
The general message is that (in most cases) the percentage of the ownership should follow the percentage of the contribution.
Part 2 will continue with a discussion about Part 1.
April 28, 2021
April 28, 2021 - Participants Include:
John Richardson - @ExpatriationLaw
Oliver Wagner - @1040Abroad
For dual Canada/US citizens living in Canada it's tax time. Specifically it's time to file both Canadian and US tax returns for the 2020 tax year.
2020 was a very difficult year. Dual citizens living in Canada may have received both the Canadian CERB payment and the the US CARES Act payment.
The basic principle, as discussed in this blog post, is that the Canadian CERB payment is taxable in both the US and Canada and that the US CARES Act payment is taxable in neither the US nor Canada.
US citizens residing in Canada may be eligible to receive up to $3200 US dollars of relief payments from the US government. This is your money to do with what you please!
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Thanks to Olivier Wagner of 1040Abroad.com for participating in this podcast.
April 26, 2021
March 2021:
John Richardson and Trowbridge partner Wayne Bewick discuss global mobility and pensions. Should people be prisoners of the country where they earned their pension? Is it time for there to be a global tax treatment on the mobility of pensions?
April 5, 2021
March 10, 2021 - Participants include:
David Lesperance and John Richardson
The whole concept of taxation is including a move toward taxation that is NOT based on income realization events, but rather on the ownership of assets.
What does this mean for your residence and citizenship portfolios?
![Dr. Laura Snyder Explains The US Extraterritorial Tax Regime And How It Applies To Americans Abroad: Let The Senate Finance Committee Know How It Affects You!]()
April 2, 2021
April 2, 2021 - Dr. Laura Snyder - @TAPInternation
About “citizenship-based taxation”- The US extraterritorial tax regime
The United States has the following three distinct tax regimes:
1. Source – like all countries: All income sourced to the United States is subject to U.S. taxation on U.S. source income (regardless of the “tax residence” or citizenship of the taxpayer);
2. Residence – like all countries: All individuals who are resident in the United States are subject to U.S. tax on their worldwide income; and
3. Extra-territorial tax regime – unique to the United States: The United States imposes worldwide taxation on the non-U.S. source income of certain individuals, who are tax residents of other countries and do NOT reside in the United States. This includes U.S. citizens living outside the United States.
Americans abroad are generally in the third category and are subject to the extraterritorial tax regime. They are subject to worldwide taxation by both the United States and their country of residence. Americans abroad do NOT as a general principle benefit significantly from tax treaties. This is because, all U.S. tax treaties contain a “saving clause” designed to ensure that Americans abroad are in effect subject to double taxation.
Who Are Americans Abroad?
The short answer is that Americans abroad are U.S. citizens living outside the United States in other countries. They run the whole circumstantial and economic spectrum of humanity. They include the poorest of the poor. They include some wealthy people. They include a large number of middle-class people. They include the employed, the self-employed and they include the unemployed. They include individuals who run small businesses in their country of residence. Some of these small businesses are run through corporate structures in the country where they reside and are tax residents.
Although Americans abroad are Americans who live in other countries, they are NOT and do NOT view themselves as “living offshore”!
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In order to let the US Senate Finance Committee know how the US Extraterritorial Tax Regime affects you, go here and select your template!
March 31, 2021
March 31, 2021 - The Return Of Coach Coutts
John Richardson and David ("Coach") Coutts discuss the essentials of staying healthy.
"Somebody's Gotta Care!"
