John Richardson

Summary Of The Reporting Obligations Triggered By Relinquishing U.S. Citizenship Or Abandoning The Green Card

Summary Of The Reporting Obligations Triggered By Relinquishing US Citizenship Or Abandoning The Green Card

Expatriation generates a "reporting" frenzy! Report Early! Report Often! Report Everything! But, who is required to report what and to whom? What is the statutory basis for the reporting? What about Green Card holders? https://t.co/dAH1ihnpi7 — John…

US Supreme Court Denies Toth Cert Petition. Justice Gorsuch Invites Lower Courts To Consider Constitutionality Of FBAR Penalties

Should tax residency Be Based On The “Circumstances Of Your Birth” Or The “Circumstances Of Your Life”?

Panel session – US Expat Tax Conference from Deborah Hicks on Vimeo. Should taxation be based on the “circumstances of your birth” or the “circumstances of your life”? President Obama doesn’t think (apparently) that the “circumstances of your birth”…

Part 7: US Supreme Court Denies Toth Cert Petition. Justice Gorsuch Invites Lower Courts To Consider Constitutionality of FBAR Penalties

Prologue – Before The Supreme Court – The Background To The Toth FBAR Case This Is Post 7 in a series of posts describing the statutory and regulatory history of Mr. FBAR. These posts are organized on the page “The Little Red FBAR Book“.*…

Is FATCA Aimed At Resident Americans, Residents Of Other Countries, Or Both? (Part 3 – Notice 2023-11)

Part 3 – Notice 2023-11: Is FATCA Aimed At Resident Americans, Residents Of Other Countries Or Both?

Summary – The Reader’s Digest Version … In 2011 Canada's Finance Minister Jim Flaherty recognized that FATCA was being applied to target people with @taxresidency OUTSIDE the USA. He stated the obvious: "Canada is not a tax haven!" Raising the…

Archive for Definition Of U.S. Citizenship Taxation

A Definition Of U.S. Citizenship Taxation: How The U.S. Imposes Worldwide Taxation On People Who Live In Other Countries

Non-U.S. Banks May Be Forced To Sever Ties With US Citizen Clients Because Of FATCA (Part 2 – Notice 2023-11)

State Department Announces Intention To Reduce Fee To Issue Certificates Of Loss Of Nationality From $2350 To $450

Introduction And General Context On Friday January 6, 2023 the State Department announced its intention to reduce the administrative fee for issuing CLNs (“Certificates Of Loss Of Nationality”) for US citizenship relinquishments from the current…

Accidental Americans' District Court moment focuses on expatriation fees; costs; constitutional issues

Toward A Definition Of US Citizenship Taxation

Prologue The term “citizenship tax” is abstract and meaningless without context. What does it really mean? In this short post I attempt to describe US tax policy in simple terms. Bottom line: The ONLY contextual meaning of taxing based on citizenship…

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

L’ASSOCIATION DES AMÉRICAINS ACCIDENTALS, et al., Plaintiffs, v. UNITED STATES DEPARTMENT OF STATE, et al., Defendants. Case No. 1:20-cv-03573-TSC DEFENDANTS’ NOTICE OF INTENT TO PURSUE RULEMAKING TO REDUCE FEE AMOUNT In advance of the hearing in…

The Carrot, The Stick And Heightened FATCA Enforcement On Overseas Americans (Part 1 – Notice 2023-11)

Part 2 – Notice 2023-11: Non-US Banks May Be Forced To Sever Ties With US Citizen Clients Because Of FATCA

Introduction – The Readers’ Digest Version Why non-US banks, US citizens living outside the USA and the countries where they live can expect heightened FATCA enforcement in 2023: "The Carrot, The Stick And #FATCA Enforcement On #AmericansAbroad (Part…

Part 1 – Notice 2023-11: The Carrot, The Stick And Heightened FATCA Enforcement On Overseas Americans

Welcome To 2023 – A Year Of Heightened FATCA Enforcement Notice 2023-11: Temp relief provided to banks under Model 1 #FATCA IGAs who can't provide SSN numbers of #Americansabroad ("preexisting accounts only") if the gov joins banks in taking specific…

“Bear Necessities”: Argentina US #FATCA IGA Confirms No Obligation Of Reciprocity On US

The Readers Digest Version: A Tweet By Tweet Explanation The State Department website featured the following announcement: On December 5, Ambassador Marc Stanley and Argentine Minister of Economy Sergio Massa signed an Intergovernmental Agreement…

To TFSA Or To Not TFSA, Whether Tis Better For A US Citizen Living In Canada To Open A TFSA Or Not

Written by John Richardson | Posted in TaxConnections Introduction And Purpose Government employment is the road to an employment pension in Canada: “How many people are covered by a workplace pension plan?” /via @globeandmail https://t.co/2nzx9wJJac…

Archive for Citizenship Based Taxation