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A California Plan To Chase Away The Rich, Then Keep On Stalking Them - Hank Adler

A California Plan To Chase Away The Rich, Then Keep On Stalking Them - Hank Adler

December 29, 2020

December 29, 2020 - Participants Include:

 

Hank Adler - Chapman University

John Richardson - @ExpatriationLaw

 

On December 18, 2020 Mr. Adler's article appeared on the Wall Street Journal began with:

"California’s Legislature is considering a wealth tax on residents, part-year residents, and any person who spends more than 60 days inside the state’s borders in a single year. Even those who move out of state would continue to be subject to the tax for a decade—a provision that calls to mind the Eagles’ famous “Hotel California” lyric: “You can check out any time you like, but you can never leave.”

 

You can read the complete article here ...

https://www.wsj.com/articles/a-california-plan-to-chase-away-the-rich-then-keep-stalking-them-11608331448?reflink=desktopwebshare_twitter

 

I am pleased to have interviewed Mr. Adler - a man with a wealth of experience in taxation and tax policy. If we sever the title of the Wall Street Journal article into two parts we see that:

1. On the one hand, California has a  - Plan To Chase Away The Rich - California tax policies are driving people away; and

2. On the the other hand California wants to  - Keep On Stalking Them -  California's proposed wealth tax purports to tax them on for ten years on their worldwide assets, which includes assets that have no connection to California and were acquired AFTER the individual moved from California.

This has many similarities to Exit taxes in general and the IRS Section 877A Expatriation Tax in particular.

By the way, those Canadians who winter in California and have sufficient assets would be subject to this proposed wealth tax!

 

 

 

Tax Haven USA: Why the USA is a great place to invest for nonresident aliens and how these investments might be structured

Tax Haven USA: Why the USA is a great place to invest for nonresident aliens and how these investments might be structured

December 15, 2020

November 12, 2020 - Participants include:

John Richardson - @Expatriationlaw

Jimmy Sexton - @JimmySextonLLM

 

"The United States has learned how to keep capital in and how to attract foreign capital!"

 

In this episode, Jimmy Sexton and John Richardson discuss why the United States is such an attractive place to invest for nonresident aliens. In other words, the opportunities are NOT available to U.S. citizens or U.S. residents.

Topics discussed include:

- how U.S. tax laws are desgined to attract foreign capital to from a U.S. tax perspective

- how U.S. tax laws which promote secrecy operate to enhance the role of the United States as a tax haven

- how the combination of FATCA (the U.S. demands your information but will not reciprocate) and the refusal to sign CRS (the U.S. will not share information) have enhanced the attractiveness of the United States as a tax haven

- how the use of LLCs and foreign Grantor Trusts can be used by nonresident aliens

- how the U.S. tax rules that are used to attract foreign capital planted the seeds that grew into  the current S. 877A expatriation tax

 Warning! Do NOT die with U.S. situs assets in your name. How to structure your assets to avoid the U.S. estate tax

 

There are Havens, Tax Havens and Tax Haven USA - there is no substitute!

 

 

 

Marc Zell - About The Association Of Accidental Americans. v. Department Of State

Marc Zell - About The Association Of Accidental Americans. v. Department Of State

December 10, 2020

December 10, 2020 - Participants Include:

 

John Richardson - @Expatriationlaw

 

Marc Zell - Jerusalem based International Lawyer

 

On December 9, 2020 the Association Of Accidental Americans launched a lawsuit against the US Department Of State on the basis that the $2350 USD renunciation is unconsitutional.

I am pleased to have been joined by their lawyer Marc Zell to discuss the lawsuit.

I have written a post discussing the claim here:

http://citizenshipsolutions.ca/2020/12/10/association-of-accidental-americans-v-us-department-of-state-is-the-2350-usd-renunciation-fee-constitutional/

A direct link to the claim is here:

 

http://citizenshipsolutions.ca/wp-content/uploads/2020/12/AAA-vs-DOS.pdf

 

 

 

 

Wealth Taxes Coming Soon To A Country Near You: Asset confiscation, income taxation or something else?

Wealth Taxes Coming Soon To A Country Near You: Asset confiscation, income taxation or something else?

December 4, 2020

November 12, 2020 - Participants Include:

 

John Richardson - @ExpatriationLaw

Jimmy Sexton - @JimmySextonLLM

It is becoming clear that the United States is gradually moving toward a tax system that includes taxation based on non-realization events. In other words, taxes may be owing even when there is no income.

Examples include (but are not limited to): the Subpart F regime (particularly the transition tax and GILTI) and the S. 877A Exit Tax Regime. The PFIC regime creates artificial income based on a fictional charge on tax deferral.

The recent Democratic Party nomination process introduced wealth taxes into the vocabulary of taxation. In particular, Elizabeth Warren campaigned on a platform of wealth taxation. In the case of a wealth tax there is no realization whatsoever. The tax is based ONLY on your owning an asset.

Although it is unlikely that a wealth tax will become a reality soon. But, it is coming. In fact, I think it would be appropriate to call the first version of the Wealth Tax: "The Senator Elizabeth Warren Wealth Tax".

On November 12, 2020 Jimmy Sexton and I discussed the nature of wealth taxes.

 

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