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Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
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Friday Dec 04, 2020
Friday Dec 04, 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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