citizenshipsolutions

[citizenshipsolutions]

Some Worry They CAN Be Proven To Be U.S. Citizens - Some Worry That CANNOT Be Proven To Be U.S. Citizens

January 26, 2025 Introduction and purpose Are you or have you ever been a U.S. citizen? It depends on the “facts and circumstances” U.S. citizenship is unique. For many it’s the only citizenship worth renouncing (many U.S. citizens are forced to renounce U.S. citizenship). For others its the only citizenship worth having. For some U.S. citizenship is the only citizenship they have ever known. One…

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Extreme Caution Should Be Exercised In Applying For Non-Renunciation "Relinquishments" Of U.S. Citizenship

Keeping this short, sweet and to the point: I recommend NOT applying for Certificates Of Loss Of Nationality (“CLNs”) based on a past relinquishing act. Past relinquishing acts include ANY form of relinquishment that is not a present day “renunciation” of U.S. citizenship. (See the appendix to this post.) This recommendation is based on experiences in Canada: – knowing several cases where the…

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IRS Medic Livestream Videos - 2025 to 2023

Introduction: Over the years I have been a guest on the IRS Medic Youtube Channel a number of times. The topics have been varied and of relevance to Americans abroad. I thought I would collect “some” of the videos in one post. If you scroll down, I expect that you will some topics of interest to you. Many if not most of the topics have included written presentations in PDF format. I will add…

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Bonjour Part 3 - From Christensen To Bruyea: Boldly Go Where No Interpretation Of Foreign Tax Credits For The NIIT Has Gone Before!

Congratulations to Stuart E. Horwich, Horwich Law LLP, London, United Kingdom, and Max Reed, Polaris Tax Counsel, Vancouver, British Columbia, Canada, for Plaintiff. Introduction This is the third in a series of posts about “treaty based” foreign tax credits. The first post detailed the provisions of the U.S. France tax treaty which created the “three bite rule”. By creating the “three bite rule”…

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Understanding Double Taxation: A Methodology To Think About What It Is

Introduction: I received the following message from: Dr. Suzanne de Treville Swiss Finance Institute Professor of Operations Management, Emeritus University of Lausanne Faculty of Business and Economics 1015 Lausanne-Dorigny Switzerland A very interesting analysis of double taxation indeed. I am reproducing this as a blog post with her kind permission. Suzanne has kindly agreed to participate in…

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Thoughts On H.R. 82 and Senate 597: The Social Security Fairness Act

This is an embedded Microsoft Office presentation, powered by Office. John Richardson – Follow me on X.com @ExpatariationLaw

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Helen Burggraf Researches The WEP ("Windfall Elimination Provision")

Helen Burgraff of “American Expat Finance Fame” has done excellent research on the WEP (“Windfall Elimination Provision” Here is one of her best articles (included on this site with her permission): Proposed legislation would address the ‘Expat Retirement Surprise’, but some say SS solvency concerns could keep

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Part 55 - A Post "MOORE"Tem- The Supreme Court Upholds The 965 @USTransitionTax

Introduction and purpose https://twitter.com/USTransitionTax/status/1673425979497234432 The Supreme Court of the United States issued its ruling in the Moore case in June of 2024. The decision in Moore is here: https://www.supremecourt.gov/opinions/23pdf/22-800_jg6o.pdf Moore 22-800_jg6o I would characterize the decision as a loss for the Moores, but a possibly a huge win for those who backed…

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The Principles Of President Trump's Pledge to End Citizenship Based Double Taxation: A Series Of Dicussions

Introduction and context: In October of 2024, Candidate Donald Trump pledged to end the double taxation of Americans abroad. In the Appendix* to this post I have included three videos discussing this pledge. I have created a specific X.com community for the purpose of discussing President Trump’s pledge to end the double taxation of Americans abroad. You are invited to join that community…

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Schwarzbaum - FBAR Penalties ARE Subject To The "Excessive Fines Clause"

Prologue – U.S. Citizenship And The Tax, Form and Penalty Club U.S. citizens are members of the world’s premier “tax, form and penalty club”. The law of Mr. FBAR is a testament to the American penchant for imposing penalties for various “form crimes”. One of most interesting issues is whether there are constitutional limits to the penalties that can be imposed for failing to file an FBAR. The…

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Schwarzbaum - Willfulness In A Civil FBAR Penalty vs. Willfulness In A Criminal FBAR Penalty

Two kinds of “willful” FBAR penalties: Generally both “civil” and “criminal” FBAR penalties can be asserted. Conviction of a “criminal FBAR penalty” an result in incarceration. Willful FBAR Penalty 1 – The Civil Willful Penalty – 31 U.S.C. 5321(a)(5)(c) 31 U.S. Code § 5321 – Civil penalties (C) Willful violations.—In the case of any person willfully violating, or willfully causing any violation…

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Department Of States Introduces New Renunciation Form And Processes Effective November 1, 2024

The “Readers Digest” Version Towards the end of October of 2024, the following comment appeared online: ‘Just renounced in Rome this afternoon. Very smooth, professional, friendly. I was asked why by the consular officer but the office person who did all the work was extremely helpful and did not ask why I decided to do it. It should take 2-3 months to get my CLN. Maybe even less. One thing the…

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Part 4 Notice 2023-11: Relief For Foreign Banks And The Hunt For Americans Abroad Extended For An Additional Three Years By Notice 2024-78

Prologue and introduction: October 24, 2024 -Letter to Americans abroad from Kamala Harris In a letter addressed to Americans abroad Vice President Harris said that she takes the concerns of US citizens overseas seriously, “whether it’s improving access to consular services, addressing the complex challenges you face with banking, taxation, and financial services, or ensuring equal treatment in…

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Canada's Post Graduate Work Permit - The Best Citizenship By Investment Program Around!

Purpose and summary … Most young adults are interested in pursuing some kind of college or university degree. Although may will pursue this in their home country, many people see the value of studying abroad. Why not combine some cross cultural experience with your educational experience? For some time the Government of Canada has offered a “Post Graduate Work Permit” for graduates of certain…

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Republicans Overseas Announces President Trump Announces To End Double Taxation Of Americans Abroad

October 2, 2024 Republicans Overseas today announced that former President Donald Trump wishes to end the double taxation of Americans abroad! Further details to follow … For the moment, please reference the following tweets: For many years @SolomonYue of @RepOverseas has worked toward ending the @doubletaxation of #Americansabroad. Today he announces progress … https://t.co/Iv9rXdicmm — John…

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New Travel Requirements For Canadian and U.S. Citizens To Enter Either Europe Or The UK

Summary: In 2025 citizens of either Canada or the United States (and citizens of many other countries) will require an electronic travel authorization (similar to the US ESTA) to enter the country. This short post is simply to: 1. Alert you to these upcoming requirements; and 2. To point you to the right websites for information. In general you will be required to pay a nominal fee, enter your…

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Separating Citizenship From Tax Residency: The Republicans Overseas Tax Proposal

In 2024 the Republicans Overseas Tax Committee created the following proposal for separating U.S. citizenship from U.S. tax residency. The proposal is three parts which are: 1. A Legislative Fix – changing who is a tax resident from “individual” to “resident”. 2. A Regulatory Fix – changing the regulation to define “individual”in the Internal Revenue Code to mean “resident” 3. A Treaty Fix –…