PREP Podcaster - ”Success Favours The PREPared Mind”
News:News Commentary
June 27, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
As more and more people renounce U.S. citizenship or surrender their Green Cards the will take steps to avoid being a "Covered Expatriate".
A "Covered Expatriate" is an individual (subject to few exceptions) who meets any one of the following three tests:
- net worth in excess of 2 million USD
- U.S. tax liability exceeding an average of $190,000 USD in the five years prior to renunciation
- failure to certify U.S. tax compliance for the five years prior to renunciation.
The consequences of being a "Covered Expatriate" are two-fold:
1. Being subject to the 877A Expatriation Tax
2. Gifts/bequests made to "U.S. Persons" being subjected to a 40% tax (payable by the recipient of the gift) as per S. 2801 of the Internal Revenue Code.
It's important that the recipient of the gift be able to prove that the gift/bequest was NOT received by a "Covered Expatriate".
In this podcast we discuss common sense steps that can (and should) be taken to meet the burden of proof of showing that the gift/bequest was NOT received from a "Covered Expatriate".
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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