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 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 — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) December 21, 2016 Let’s begin with […]

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 […]

Part 2 – Would A Move To Residency-based Taxation Solve The FATCA Problem For Americans Abroad Created By The FATCA IGAs?

Purpose Of This Post – The “Readers Digest” Version Through the #FATCA IGAs the U.S. has effectively (1) forced other countries to build an extra-territorial jail for those found to […]