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!
Thanks to Olivier Wagner of 1040Abroad.com for participating in this podcast.
April 26, 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?
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”!
In order to let the US Senate Finance Committee know how the US Extraterritorial Tax Regime affects you, go here and select your template!