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 jurisdiction and (3) how to use “treaty tiebreakers” to end “tax residency” in an undesirable tax jurisdiction. Topsnik 1: It’s about the taxation (not expatriation) […]

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 — Citizenship Lawyer (@ExpatriationLaw) May 21, 2017 This is Part 2 – a continuation of the post about “tax residency under the Common Reporting Standard“. That post ended with: Breaking “tax residency” to Canada can be difficult and […]

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 […]

On what date does an individual (other than a U.S. citizen) begin or end @USTaxResidency

This is an interesting and important question. This question is always important for determining how the Sec. 877A “Exit Tax” applies to “permanent residents” AKA “Green Card Holders” who with to abandon their permanent residence. There are many other many other reasons why this matters. U.S. tax residency (which is an example of “deemed tax […]

Part 1: South Africa is NOT attempting to compete with USA by challenging the US monopoly on citizenship-based taxation

As goes taxation, so goes civilizations This is Part 1 of my posts discussing the South Africa situation. Part 2 is here. The problem is NOT “worldwide taxation”. The problem is imposing “worldwide taxation” on people who don’t live in… https://t.co/OCThq5Shx9 — Citizenship Lawyer (@ExpatriationLaw) September 7, 2017 There have been a number of suggestions […]

The teaching of Topsnik 2 – 2016: #Greencard expatriation and the S. 877A “Exit Tax”

What! You want to abandon your Green Card and leave the USA! Reverse Immigration: How IRS Taxes Giving Up Green Cards via @forbes https://t.co/SXFh2uUivs – Leaving the USA? The USA wants YOUR ASSETS! — Citizenship Lawyer (@ExpatriationLaw) May 22, 2017 Introduction – Introducing Gerd Topsnik – The World According to Facebook Discussion on Topsnik, tax […]

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 […]

Part 1: Tax Treaties, determining “tax residence” and new OECD Common Reporting Standard (“CRS”)

Canada: Common Reporting Standard legislative proposals here https://t.co/nuwVULQClQ – Report "tax residents" of "reportable jurisdiction" — Citizenship Lawyer (@ExpatriationLaw) August 23, 2016   The above tweet references an article from Stikeman Elliot which includes: For CRS purposes, the term “reportable person” generally refers to a natural person or entity that is resident in a reportable jurisdiction (excluding […]