"Tax residence" for US Estate and Gift and "tax treaty tiebreakers with overlapping domicile

Introduction – Two kinds of tax systems – Two kinds of “tax residency” Title 26, the Internal Revenue Code of the United States is composed of twelve subtitles. Subtitle A […]

The teaching of Topsnik 1 – 2014: Taxation for #GreenCard @TaxResidency and "tax treaty tiebreakers"

Introduction This is part of a series of posts on: (1) “tax residency“, (2) the use of “treaty tiebreakers” when an individual is a “tax resident” of more than one […]

Part 2: OECD Common Reporting Standard ("CRS"): "tax residence" and the "tax treaty tiebreaker"

Part 1: Tax Treaties, determining "tax residence" and new OECD Common Reporting Standard ("CRS… https://t.co/OwRTHv1Irh via @ExpatriationLaw — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) May 21, 2017 […]

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 […]

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 […]

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 […]

Part 41 – The Six Faces Of The 965 Transition Tax – The Ugliest Face Applies To Americans Abroad

Part I: Introduction – What Is The Transition Tax? "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation tax but didn't know to […]

Some US Citizens And Green Card Holders Resident In Belgium Are Excluded From Benefits Under The Tax Treaty Available To US Citizen Residents

Prologue Some Green Card holders and #Americansabroad living in Belgium are like Alice in her "Adventures In Wonderland". You see they have @taxresidency in the USA, but when they move […]

Article 4 paragraph 2 of the U.S. U.K. Tax Treaty: A clause preventing the use of the tax treaty tie breaker for some Green Card holders

Introduction – In The 21st Century The Most Important Thing About A Person Is His Tax Residency Interestingly the U.S. UK tax treaty appears to have created a "saving clause" […]

The "proper care and feeding of the Green Card": Tax Filing Edition – Use of the 911 Foreign Earned Income Exclusion

Introduction: The Purpose and Limited Scope Of This Post This post focuses on Green Card holders who are filing the 1040 tax return. The 1040 is the return that is […]