Tax Residency

[Tax Residency @TaxResidency]

Tax Residency in a FATCA and CRS World

by William H. Byrnes IV and Robert J. Munro *

Contributing Author: John Richardson, LL.B., J.D., https://t.co/81nqy2iszY. Rewritten by William Byrnes with additional material included. https://t.co/oyzeYXtXqO

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

@nigeljgreen @CitizenshipTax First they would create an exit or "settling up" tax triggered by severing @taxresidency; and

Second, they would switch to @CitizenshipTax.

They would emulate the USA.

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

Reminder to all with @TaxResidency in Canada. The CDN Form T1135 combines features of both US #FBAR and Form 8938.

New disclosure program to fix:

https://t.co/54HdsTduOF

[Tax Residency @TaxResidency]

https://t.co/FvFvQKl18Z

[Tax Residency @TaxResidency]

My answer to Do Digital Nomads pay their taxes in their home country or in the host country? https://t.co/NlAkM7kid3

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

The next step will be for New York, CA and other high tax states to impose #Exittaxes if people move: "Tax collectors chase rich New Yorkers moving to low-tax states. Auditors inspect cell records, ev..." https://t.co/NswjvxIXUk via @YahooFinanceUK

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

The three groups (in terms of economic status) leaving California are: 1. Lower class 2. Middle class and 3. Higher class "Californians fed up with housing costs and taxes are fleeing state in big numbers" https://t.co/RFn0Qj51g2

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

Both California and the USA define @taxresidency so that ALL people are presumptive tax residents. It's up to to the individual you prove that he is not.People should leave California before the state joins the USA in imposing S. 877A type exit taxes. https://t.co/OwCJPAf4GS

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

The USA must stop imposing #worldwide taxation (@citizenshiptax) on people have @taxresidency in other countries who don't live in the USA #BECAUSEITSWRONG! https://t.co/6F57SchzXx

[US Green Card Abroad @USGreenCardLaw]

Numerous answers - none of which focuses on the reality of having @taxresidency in the USA and the possible Exit Taxes imposed on those who try to leave: Question on @Quora: Is getting a US Green Card worth the hassle and cost? https://t.co/Cf0HgGhdzM

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

It's unlikely that @TaxJusticeNet will care in the least about US @CitizenshipTax - they are concerned only with those with @taxresidency not paying their #fairshare to their country of tax residence. It would be interesting to know what they think about US refusal to join #CRS.

[John Richardson - Counsellor for US persons abroad @ExpatriationLaw]

@taxresidency

[Tax Residency @TaxResidency]

Tax Residency in China under New IIT Law: Impact on Foreigners https://t.co/ohtwC8SvOl

[Tax Residency @TaxResidency]

U.S. Tax Residency: Some Black-and-White Rules, Some Gray https://t.co/IQh7C5m0Nn

[Tax Residency @TaxResidency]

Understanding the Common Reporting Standard from the CBA: https://t.co/qsvjvhDUKa

[Tax Residency @TaxResidency]

No exchange of information with the USA because the USA has not signed the OECD Common Reporting Standard: "Common Reporting Standard - ITA Part XIX" - https://t.co/kI0jm33JiA https://t.co/7AJpNWgCra

[Tax Residency @TaxResidency]

"In light of the Wayfair decision, a question may be raised as to whether a state may now try to impose state corporate income taxes as well. Many states have introduced, in addition to the current physical nexus standard, an economic nexus standard." https://t.co/Y4D6uNTsfX

[Tax Residency @TaxResidency]

We see that in the USA @taxresidency for income tax purposes is different than for Gift and Estate tax purposes - "Foreign Investment Into The U.S. Part II: Who Is A U.S. Person" https://t.co/cY4kBmiYOv via @taxconnections

[Tax Residency @TaxResidency]

Offshore tax measures behind UK evasion spike https://t.co/Rll9B4VXSg

[Tax Residency @TaxResidency]

About #domicile

4. It is not easy to change domicile. More than an intention to change domicile is required.

[Tax Residency @TaxResidency]

About #domicile:

5. In determining whether a person is domiciled in a place the court looks to a number of factors which include: