Top Tweets for #savingclause
@patienceisalpha If the French had @citizenshiptax it would operate as equivalent to the US #savingclause. It appears that this would give France taxing rights to income sourced in the UAE and (possibly) not sourced in France. Presumably the FTC rules would continue to provide some relief.
"Simple+Unilateral Treaty Fix 4 Citizenship Taxation" -article exploring ways to mitigate problems of #citizenshiptax in absence of legislation -by @SEATNow_org co-founders @ExpatriationLaw @TAPInternation + @FixTheTaxTreaty https://t.co/3mpx6TWxw8 #savingclause #doubletaxation
Only two ways to eliminate the @doubletaxation of #Americansabroad in a @citizenshiptax world with the tax treaty #savingclause:
1. US prohibits any foreign country from imposing any tax on a US citizen.
2. US eliminates all foreign countries by annexing them and making them US.
#Doubletaxtion is NOT the fault of the USA. It's because of the existence of foreign countries that tax US citizens.
To be able to enforce @citizenshiptax, Austrlia, Canada and other countries would need to renegotiate their tax treaties to eliminate @taxresidency tie break opportunities. US tax treaties have a #savingclause that prohibits US citizens from EVER ceasing to be US tax residents.
Probably controversial, but I genuinely believe that within the next 5 years:
π¦πΊ Australia
π¨π¦ Canada
π¬π§ UK
πͺπΊ EU
And most Western countries will tax their citizens globally, like the US does.
So buy Bitcoin. Get your coins off exchanges.
And get to a Bitcoin-friendly jurisdiction. Countries like El Salvador and the UAE.
Considering the @doubletaxation of #Americansabroad: For #Americansabroad, US @citizenshiptax
by defintion creates dual @taxresidency
(full taxation by two countries). You WILL pay taxes twice on the same income in certain instances (bc of #savingclause in US tax treaties ). 3/
"Do As I Say! Not As I Do!
For the USA to complain about non-US countries imposing extraterritorial taxation is like "the pot calling the kettle black". US @citzenshiptax coupled with #FATCA and the tax treaty #savingclause are for the purpose of imposing US extra-territorial taxation.
@TAPInternation of @SEATNow_org discusses this hypocrisy here:
https://t.co/mfYaHaMBiI
Link to the @Expatriationlaw #savingclause discussion:
Friday January 17, 2025 - 06:00 EST (11:00 GMT)
https://t.co/rQyo2QykJG
@DoubleTaxation @TAPInternation @FixTheTaxTreaty @SEATNow_org Commentary about the #savingclause from @SEATNow_org
https://t.co/gYPb7TzxZc
BTW the claim that tax treaties prevent @doubletaxation is generally untrue (but may be true in some narrow circumstances depending on the tax treaty).
On the contrary, the #savingclause found in ALL (except Pakistan) tax treaties is for the purpose of guaranteeing the possibility of @doubletaxation on #Americansabroad.
The #savingclause in US tax treaties guarantees the possibility of @doubletaxation on many #Americansabroad. Some experience it and others do not (depending on their circumstances).
Do #taxtreaties protect #americansabroad? Are some people entitled to their own facts? #citizenshiptax #fatca #taxtwitter https://t.co/ZrllIQjjQD @ExpatriationLaw @FixTheTaxTreaty @TAPInternation
Any country signing a tax treaty with the USA is agreeing that the USA can impose taxation on the countryβs residents who happen to have born in the USA. They clearly do not understand US @citizenshiptax and the #savingclause.
Latest from @RepOverseasTax and @Expatriationlaw: With few exceptions, US tax treaties do NOT prevent @doubletaxation. Itβs the opposite. Because of the #savingclause treaties facilitate double taxation of #Americansabroad in a #FATCA world. https://t.co/ahFg4jHmot
Podcast - As reported by @TAPInternation, France is discussing @citizenshiptax for France. @TPSmyth01 and @Expatriationlaw discuss why this proposal (under France's exising tax treaties) is a non-starter. France has no #savingclause in its treaties. https://t.co/uP0oLmaRZR
Podcast - Karen Alpert @FixTheTaxTreaty and John Richardson @ExpatriationLaw discuss how @citizenshiptax, #FATCA and the treaty #savingclause enhance US @taxationabroad. A country pays a huge price for a tax treaty with the USA. What are the benefits? https://t.co/owdrxvi6GE
Conclusion: Any country that enters into a tax treaty with US is (bc of @citizenshiptax, #FATCA and #savingclause) agreeing to give the US taxing rights over a subset of its @taxresidency. Tax treaties expand the US tax base into other countries. What does the other country get?
US @citizenshiptax, #FATCA and #savingclause found in US Tax TREATIES has allowed US to apply apply its tax code outside the USA: 1. Claiming those with @taxresidency in other countries as US residents; and 2. Applying the US tax, form and penalty regime to them. How can this be?
@DianasPlace @RaddSeiger Any country that enters into a tax treaty with the US is (because of the #savingclause and @citizenshiptax) agreeing to give the US taxing rights over a subset of its @taxresidency. Tax treaties expand the US tax base into other countries. What does the other country get?
@JCDoubleTaxed @MikeBre14267200 @CitizenshipTax @DoubleTaxation @TheDemocrats @repdinatitus @freedomcaucus This is an impossible concept for Americans
@Citizenshiptax enforced by #FATCA and the treaty #savingclause are effective tools of colonization. If America were to stop this abuse it would cease to be America. "My country CBT sweet land of liberty ..." - Sing it in the schools.
USA is arguing that US/France tax treaty should be interpreted to REQUIRE @doubletaxation if France dares to tax investment income sourced in France and received by US citizens (property) resident in France. Treaty #savingclause used to create #doubletax and not avoid it.
Podcast - @FixTheTaxTreaty and @ExpatriationLaw discuss: US @citizenshiptax, dual @TaxResidency and why the US #savingclause facilitates the @Doubletaxation of #Americansabroad (it's far worse than you think). https://t.co/owdrxvhyR6
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