citizenshipsolutions

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Update: 899 Penalty Tax Will NOT Go Forward - Secretary Bessent Claims Mission Accomplished!

Prologue I have written about the proposed IRC S. 899 Tax titled: “Enforcement Of Remedies Against Unfair Taxes” Take YOUR Money And Run: Understanding The Proposed § 899. ENFORCEMENT OF REMEDIES AGAINST UNFAIR FOREIGN TAXES The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship It now appears that the S. 899 tax will NOT be included in the “Big…

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The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship

Introduction – It’s The American (A)Way The United States tax system is designed to impose punitive tax, reporting and penalties on the non-U.S. income and assets of Americans abroad. Nonresident aliens (those who are neither U.S. citizens nor residents) are taxable ONLY on their U.S. source income. This reality has driven many U.S. citizens (living abroad) to renounce U.S. citizenship. It also…

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Highlights of @HelenBurggraf's American Expat Financial News Journal (2018 to 2023)

Introduction As the late Charles Adams would say: “As goes taxation, so goes civilization”. Helen Burggraf’s American Expat Financial News Journal (archived here) was an online newspaper/blog that existed from 2018 to 2023. It contained a wide range of articles – covering a wide range of topics – and reflected the frustrations of Americans abroad. Most of the site can be found at…

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Senate Finance Committee Response To The "Remittance tax" Proposed In The "Big Beautiful Bill"

Here is how I interpret the Senate proposed rules for the remittance tax found on page 388 of the Senate Bill (responding to the "Big Beautiful Bill"):https://t.co/KvSqazYSIu An overall reading confirms that the principle that: "It's expensive to be poor (and unbanked)." pic.twitter.com/pFOPkmdR1i — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) June 18, 2025 The Senate…

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A #GILTI Carveout For INDIVIDUAL CFC Shareholders Of Certain Virgin Islands Corps

Introduction and purpose: The Big Beautiful Bill (“BBB”) Contains many surprises. Yesterday, I wrote a first post about a section of the BBB that addressed the application of the GILTI rules. GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly That post was largely based on an interesting expose in the Washington Post. This called attention to the…

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GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly

Introduction and purpose GILTI – found in IRC 951A – is one of the most problematic manifestations of U.S. citizenship taxation. It has caused huge compliance problems and costs for Americans abroad. The costs are composed of (1) the compliance costs of Form 5471 and (2) the possibility of the payment of U.S. taxes. All businesses understand that taxes are a cost of running a business. GILTI has…

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Exit Taxes As A Barrier To Emigration And The Need For An International Treaty To Create Uniformity And Certainty Surrounding Emigration

Exit Taxes As A Barrier To Emigration And The Need For An International Treaty To Create Uniformity And Certainty Surrounding Emigration Outline: Part A – Introduction Part B – Emigration burdened by “exit taxes” Part C – Modern Exit Taxes And First World Democracies Part D – A Tax Treaty Solution That Protects BOTH The Right Of Emigration And the Desire Of Government’s To Tax Individuals On…

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Belgian DPA Decision - April 2025 - French and (Unofficial) English Versions

What follows are the both the official decision in French and the (obviously) Unofficial version in English. Congratulations to the Accidental Americans in the Netherlands! Belgian DPA decision April 2025 French original Belgian DPA decision April 2025 unofficial translation FR_to_en-US

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Toward An Argument That US Citizenship Taxation Violates International Law

Introduction – Why FATCA Litigation Fails … (Well, most of the time!)* In September of 2024, I wrote a blog post about FATCA litigation. Q. Why Does FATCA Litigation Fail? A. Because, It Focuses On The Symptom And Not The Cause That post was discussed on an IRS Medic podcast here: In that post, I suggested that FATCA litigation fails because it has to date focused on certain results of FATCA…

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Robert T. Kudrie: Citizenship Taxation, Globalization and Inequality

I came across a 2023 article published in the Florida Tax Review by Robert T. Kudrie of the University of Minnesota. The article is available here. https://scholarship.law.ufl.edu/cgi/viewcontent.cgi?article=1410&context=ftr Despite its title the article seems to focus more on the importance and enhancement of U.S. residents with “offshore assets” than on Americans abroad. Notably, on page 803…

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Mistakes In Renouncing In U.S. Citizenship: Not Knowing Your Net Worth At The Time Of Renunciation

The single biggest mistake that most* people can make in renouncing U.S. citizenship is: To renounce without a clear and accurate understanding of their net worth**. *Some with @dualcitizenship from birth "may" avoid the consequences of a net worth > 2 mill USD. (**Incredibly… — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) April 7, 2025 In the last week I have had…

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Part 6 - What Would A Ban On Dual Citizenship Mean For U.S. Citizens?

The Little Red Dual Citizenship Book See the Appendix for a list of posts making up the “Little Red Dual Citizenship Book” Whether or not it’s “fake news” … It started with what purported to be a post by President Trump on “Truth Social” that he was going to attempt to end dual citizenship. This was immediately exposed as a “Fake Post”. Nevertheless, I came across an interesting video of what it…

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Part 5 - The Clash Of Citizenships: When Dual Citizenship For The Individual Becomes Duel Citizenship For The State

Introduction And Summary This is Part 5 in my “Little Red Dual Citizenship Book” Series. For parts 1 to 4, see the Appendix. The proliferation of “dual citizenship” in the 21st century is a benefit for individuals. As Boston Globe Correspondent journalist David Shribman explains, dual citizenship may be a critical part of an individual’s identity. That said, “dual citizenship” may not be a…

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My Submission To Senate Finance: Discussion Draft - Taxpayer Assistance and Service Act

Introduction and purpose On January 30, 2025, The Senate Finance Committee released a proposed a Discussion Draft of the “Taxpayer Assistance And Service Act” The text of the bill is here: https://www.finance.senate.gov/imo/media/doc/tax_admin_bill.pdf The Committee’s commentary on the bill is here: https://www.finance.senate.gov/imo/media/doc/tas_act_discussion_draft_section_by_section.pdf The…

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Canada Bill - C71 Will Increase Citizenship By Descent Options For US Citizens Seeking Dual Citizenship

Introduction And Summary Excellent from @Chris_Muther: American @dualcitizenship interest surges amid political turmoil https://t.co/lIpRoGSXgI… via@BostonGlobe — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) March 26, 2025 A recent article in the Boston Globe is evidence that more and more Americans are interested in acquiring a second citizenship. Second citizenship…

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IRS Service To Expats: Another Reason To End U.S. Citizenship Taxation

Guest Post By Dr. Suzanne de Treville – Switzerland Discussions about eliminating double taxation for U.S. citizens abroad often focus on reducing the significant compliance burdens these individuals face. When the U.S. taxes income or assets already taxed in a citizen’s country of residence, the resulting complexity is substantial while the extra tax revenue to the IRS that results from this…

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The Douglas Adelman Indictment - What Does It Mean For Americans Abroad?

On March 18, 2025 an article by Margot Patrick appeared in the Wall Street Journal. A military-contract bonanza, European mansions, disgruntled business partners: The jet-setting case of one of America’s biggest alleged tax cheats. https://t.co/xfSgu6tva5 via @WSJ — Margot Patrick (@margotpatrick) March 19, 2025 A direct link to the article is here. Mr. Adelman was a U.S. citizen who had lived…