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News:News Commentary
January 20, 2023 - Participants Include:
Keith Redmond - @Keith__Remond
John Richardson - @ExpatriationLaw
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This informal discussion was the result of two separate (but contextually related) discussions on social media discussing US citizenship taxation.
First - Keith Redmond's American Expatriates Facebook group. The discussion thread is here:
https://www.facebook.com/groups/AmericanExpatriates/posts/2370830776416314/
Note this thread is discussed until approximately the 30:35 mark.
Second - Discussion on Twitter
https://twitter.com/RonSteenblik/status/1614669507590496259
Note this thread is discussed from approximately the 30:35 mark until the end.
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Interestingly both discussions illuminated the fact that those subject to the US extra-territorial tax regime are clearly impacted in different ways. These differences make it very difficult to unite Americans abroad in a common goal of ending US citizenship taxation.
Generally, those subject the US extra-territorial tax regime fall into one of the following four groups. Each group is characterized by a dominant goal (although there is some overlap):
Ending Citizenship Taxation - This group which is symbolized by SEAT is focussed on ending US citizenship taxation. This means that citizenship is never relevant for the purposes of taxation.
Ignoring Citizenship Taxation - It is clear that there are any individuals who approach the problem of citizenship taxation by simply ignoring it. It is clear that many people who are subject to the citizenship tax regime are simply not "in the US tax system". Typically these are people who have no economic centre of gravity in the United States and have no plans of living in the United States.
Escaping Citizenship Taxation - Members of this group are concerned with solving their specific problem. For example, they would want the Taxation of capital gains on principal residence, PFIC, CFC or Foreign Trust rules changed. Once that issue is solved they believe their problems are solved.
Improving Citizenship Taxation - These individuals are NOT concerned with ending citizenship taxation as a general principle. They are concerned with reforming citizenship taxation in a way that reduces the kinds of non-US source income that is taxable by the United States. But, US citizens abroad would remain US tax residents. An example fo this would be the "Beyer Bill".
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Why should the US entertain a transition from citizenship taxation to residence taxation when Americans abroad are NOT united in the goal of ending citizenship tax?
To put it simply:
Americans abroad have divided and conquered each other!
Insights and Solutions Into The Problem Of US Citizenship Or Holding A Green Card
SEAT Working Paper Series - Extraterritorial Taxation #15 - Taxing in Respect of Rights
Canada's New Capital Gains Tax And Navigating Wealth Management Strategies in Canada
SEAT Working Paper Series - Extraterritorial Taxation #14 - Revenue Neutrality Makes No Sense
The Life And Times Of Nova Scotia's Atlantica Party - With Ryan Smth
SEAT Working Paper Series - Extraterritorial Taxation #13 - Other Countries Have A Duty To Act
The US Tax Treaty Saving Clause As A Vehicle To Tax Residents Of Other Countries On Non-US Income
SEAT Working Paper Series - Extraterritorial Taxation #12: It's Not About Paying Taxes
Insights into the Intertwining of Politics and the Law in Ontario's Justice System
SEAT Working Paper Series - Extraterritorial Taxation #11: Deference or Constitutionalization?
SEAT Working Paper Series - Extraterritorial Taxation #10: Violating Human Rights
Insights on Boosting Immunity to fight the common cold with Health Coach David Coutts
David McKeegan's Journey with Greenback Tax Services
SEAT Working Papers Series - Extraterritorial Taxation #9: Forcible Destruction Of Citizenship
SEAT Working Papers Series - Extraterritorial Taxation #8: More Violations of Equal Protection
Coach Coutts - Leave The Democracy To US!
Canada's Justice System: A Deep Dive With The Founders of Compassionate Justice Canada
SEAT Working Papers Series - Extraterritorial Taxation #7: Unlocking the Complexities and Discrimination of Citizenship Taxation Laws
Catching Up With Amy From Sydney - Unraveling US Taxation and Voting for Expatriates
SEAT Working Papers Series - Extraterritorial Taxation #6: No Compelling Governmental Interest
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