Double Taxation Of Americans Abroad Is Because Of Citizenship Based Double Tax Residency

What Is Meant By The Double Taxation Of Americans Abroad? On February 12, 2025 I hosted an “X Spaces“. The intended purpose was to discuss Professor Avi-Yonah’s new paper “Should […]

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 […]

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 […]

Presumptions, tax residency and presumptions of tax residency: Nonresident alien status in a FATCA world

Introduction – All The World Is A Multiple Choice Test Q.1 – A tax resident of the United States is taxable on his worldwide income. According to the Internal Revenue […]

Green Card holders who have moved from the United States without properly severing US tax residency

Here is the scenario that this post is addressing: An individual becomes a permanent resident of the United States (meaning that he has a Green Card). He lives in the […]

Domicile as a basis for tax residency: How to have @taxresidency where you may not live

What is domicile? About domicile … Domicile is an old “common law” concept. Domicile is NOT the same as “residency” (although it might include residency). Domicile is NOT the same […]

Determining Tax Residency In the United States: Citizenship and other forms of deemed tax residence

Introduction The search for second passports and #offshore havens https://t.co/mFWja1CR87 via @FT – how the #CRS and #FATCA have created @TaxHavenUSA — John Richardson – Counsellor for US persons abroad […]

Determining Tax Residency in Canada: Deemed resident vs. factual resident

How #taxresidency in Canada is understood by @OECDTax for the Common Reporting Standard https://t.co/1M23xcaf2c — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) December 21, 2016 Let’s begin with […]