Of all the different kinds of residency, the one that matters most is your “tax residency”

Introduction In a world of information exchange (FATCA and CRS), fiscally challenged governments (United States and other Western Democracies) and expanding notions of taxation (GILTI, France Digital Tax, etc.), your “tax residency” matters. In fact, in the 21st Century the most interesting thing about a person is his tax residency (or residencies). At the same […]

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 Code of the United States, which one of the following is NOT a tax resident of the United States of America? (A) A Congresswoman “Born […]

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 United States for any number of years. He then moves away from the United States and returns to live in his home country. He is […]

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 as “citizenship” (although one could be a citizen of the country where one is domiciled). Domicile is a concept that refers to one’s permanent home […]

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 — Citizenship Lawyer (@ExpatriationLaw) May 20, 2017 The advent of the OECD Common Reporting Standard (“CRS”) has illuminated the issue of “tax residency” and the desire of people to become “tax residents of  more […]

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 – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 21, 2016 Let’s begin with the law as stated in the Income Tax Act of Canada … Taxation in Canada is governed by the Income Tax Act of Canada. Sections […]

Tax residency vs. physical presence: The four questions you must ask before making a country your home

An introduction to “tax residency” … Most people equate residency with physical presence. They assume that where you are physically presence determines where you live. They further assume that where you live is where you pay your taxes. Conclusion: The country where you live is the country where you must be “tax resident”. Not necessarily! […]

Part 19 – Comments from those with @TaxResidency in other countries about the effects of @USTransitionTax & #GILTI

Designed for Google and Amazon and applied to individual Americans abroad … USA: Hands Off CCPCs! MT @ExpatriationLaw @ADCSovereignty 2 USA: PLS don’t harm CDNs w/retrospective tax on CCPCs https://t.co/s8vXQQxZL7 — ADCSovereignty (@ADCSovereignty) December 19, 2017 ADCS Press Release on the Transition Tax and GILTI: The Alliance For The Defence Of Canadian Sovereignty issued a […]

So, you have received bank letter asking about your tax residence for CRS or FATCA – A @taxresidency primer

Prologue: In the 21st Century, The Most Interesting Thing About A Person Is His/Her Tax Residency Welcoming the world's most famous @USCitizenAbroad: "Little Archie's big tax problem" – https://t.co/Yt9YtVivwu https://t.co/bVGqaguuOb — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 28, 2019 Introduction – So, what’s this “tax residence” stuff about? What does “tax […]

Considering the EB-5 Visa? The IRC S. 877A Expatriation Tax Demonstrates that "Not All US @TaxResidency Is The Same!"

Considering the EB-5 Visa? The U.S. S. 877A Expatriation Tax Demonstrates that “Not All @TaxResidency Is The Same!” https://t.co/QJnuiKmpQf — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 20, 2018 “Understanding U.S. Tax Residency … The United States uses a form of “deemed tax residency“. The Internal Revenue of the United States deems that […]