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 […]

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 […]