The Green Card and the “Oh My God” Moment: You know you want to leave the USA? Not so fast!

One more day! One more #GreenCard holder chased out of America – Can't understand what is required of him https://t.co/tp09EMhTHP pic.twitter.com/IukTr1Mfo3 — Citizenship Lawyer (@ExpatriationLaw) August 25, 2017 Well he won the lottery. Specifically he won the “Green Card” lottery. He and his wife came all the way from an Asian country to “Live The […]

Green card holders: the “tax treaty tiebreaker” and eligibility for Streamlined Offshore

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

Green card holders, the “tax treaty tiebreaker” and reporting: Forms 8938, 8621 and 5471

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

Green card holders: the “tax treaty tiebreaker” rules and taxation of Subpart F and PFIC income

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

The US “expatriation tax” and the the incentive to apply for a Green Card and/or remain in the USA

America doesn’t really need skilled immigrants, or does it? Staple a "Green Card" to every PhD – Don't fall for this! Don't immigrate to the U.S. https://t.co/hHefrflU2v via @USCitizenAbroad — Citizenship Lawyer (@ExpatriationLaw) September 24, 2016 The above tweet references a post that references a comment by Victoria Ferauge:

Is Form 8938 required by “Green Card Holders” who are nonresidents by “treaty tie breaker”? – Any exemption is the result of “IRS grace”

Summary: @Vljeker interview with Bill Yates about the creation of IRS Form 8938 https://t.co/TLhSkdrYoq — Citizenship Lawyer (@ExpatriationLaw) September 23, 2016 The context: Form 8938 was created by the IRS to meet the reporting requirements mandated by Internal Revenue Code S. 6038D. S. 6038D was mandated by S. 511 of the HIRE Act. On March […]

Green Card Holders and #Americansabroad: “Residence”, “Long Term Residence” and the S. 877A “Exit Tax”

Tax jurisdiction and residential ties The two types of residential ties considered for all aliens When considering the meaning of “residence” for tax purposes, attempting to ascribe a place of “residence “to an individual, and imposing taxation on individuals, the Internal Revenue Code considers: A. The extent of “residential ties” to the United States; and […]

Are Green Card holders resident outside the USA “US persons” under the #FATCA IGA?

Introduction … Circa 2014: Are Green Card Holders who r resident in Canada "US Persons" within the meaning of Canada US FATCA IGA? https://t.co/txcOlpNMfJ — Citizenship Lawyer (@ExpatriationLaw) April 3, 2016 The above tweet references a comment that was left on Olivier Wagner’s Tax Samurai blog. Olivier is discussing an earlier post of mine called […]

Thoughts from a conversation: Green Cards – Dangers of moving to America and moving from America

"Coming to America" – Welcome to the land of Forms and #FBAR – It's what you couldn't imagine you don't know. https://t.co/cr9SPaOjHf — Citizenship Lawyer (@ExpatriationLaw) June 21, 2015 My #OVDI Progress http://t.co/e4i72v1Bkj via @wordpressdotcom – Another "Green Card" victim – he kept a bank account in the home country! — Citizenship Lawyer (@ExpatriationLaw) June […]

What’s a #GreenCard anyway? It’s NOT what you don’t know. It’s what you know that isn’t true!

Introduction – It’s about the right to live permanently in the United States There are tens of thousands of people who have “Green Cards” who live outside the United States. Some of them want to maintain their Green Cards which they understand to mean maintaining their right to live permanently in the United States. Otherwise […]