Nick Lee

Extraterritorial taxation & regulation based on citizenship aren’t good policy, and that’s a #FATCA. Policy wonk on @DemsAbroadTax

[Nick Lee @NicklesLee]

@JCDoubleTaxed @ExpatriationLaw @DoubleTaxation @USCitizenAbroad @CitizenshipTax Presumably the 1yr carry back / 10yr carry forward would cause it to match up to your eventual capital gains when you sell.

There’s no realistic way to avoid significant selling to cover taxes, which some of the critics claim to be an ECHR violation.

[Nick Lee @NicklesLee]

@ExpatriationLaw @DoubleTaxation @USCitizenAbroad @CitizenshipTax @grok explain how Savings BVs sidestep the problems with the new “paper gains” tax in Box 3

[Nick Lee @NicklesLee]

@ExpatriationLaw @DoubleTaxation @USCitizenAbroad @CitizenshipTax Box 3 (investments & savings) is taxed to hell under the new rules.

Personal Box 2 (dividends/distributions from a company you own more than 5% of) & corporate taxes remain favorable.

The people passing this tax know them & their donors don’t need to pay it.

[Nick Lee @NicklesLee]

@ParvizMalakouti They can’t fathom a world in which their jurisdiction has limits.

It’s like the (laughable) Dutch register of unwanted nationalities, intended as an alternative to renunciation for nationalities that don’t permit that.

[Nick Lee @NicklesLee]

@IRS_MEDIC @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul @RandPaul @RepLaHood Yes. I’m aware some people don’t like the opt-in nature of its RBT, but it allows for severing tax residency & there are some Americans abroad that would vocally object to it being automatic.

[Nick Lee @NicklesLee]

@IRS_MEDIC @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul @RandPaul @RepLaHood Hate the game, not the players.

We’re all entitled to think scoring is stupid & the root of many problems in America, but it’s the rule that legislation dies by.

I’d rather play stupid games & give this a chance of passage than die on the wrong hill.

[Nick Lee @NicklesLee]

@IRS_MEDIC @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul “You catch more flies with honey” holds true here.

We need leads on both the House & Senate sides in order for this bill to move, so @RandPaul alongside @RepLaHood is far better than “in place of”.

There are also legitimate reasons why the bill hasn’t been reintroduced yet.

[Nick Lee @NicklesLee]

@ExpatriationLaw @ACAVoice It’s refreshing to be getting a terse summary of the bill/statutory text that’s identifying why overseas Americans are likely *not* directly in scope.

Always a risk that the implementing regs are flawed, but that’s a bridge to cross when the time comes.

[Nick Lee @NicklesLee]

@adrianpandev @ExoloringPhil Guy in the photo—the LaHood RBT bill was one of the major topics of conversation this week.

Ending CBT is very much the North Star.

[Democrats Abroad Taxation Task Force @DemsAbroadTax]

BTW third year in a row that a Republican office complimented us and said we were better than lobbyists!

[Nick Lee @NicklesLee]

@AttyStevenBrown @ParvizMalakouti https://t.co/d84k7bYsN4 is worth looking at. Gets into the Tjebbes ruling, constitutional law, and all the fun stuff

[Nick Lee @NicklesLee]

@AttyStevenBrown @ParvizMalakouti We worked with Luigi Paiano a few years back for ours. Giovanni di Ruggiero has been posting pretty publicly about some of the angles for challenge, so he might also be worth looking into.

[Nick Lee @NicklesLee]

@AttyStevenBrown @ParvizMalakouti If you’re willing to roll the dice on (comparatively low) legal fees a bit, the immigration lawyers & opposition parties think this is going to be extremely vulnerable to legal challenges.

Could very well be the same as the oft-discussed “1948 cases”.

[Nick Lee @NicklesLee]

@ParvizMalakouti @IRS_MEDIC @ExpatriationLaw You’d expect him to just tick the “more than 25 accounts” box and report absolutely nothing in the contents.

[Nick Lee @NicklesLee]

@RichardRubinDC Those are going to be some incredible information reports

[Nick Lee @NicklesLee]

@Ronald77171496 @toezicht_AP @Financien Maar los van degene wiens hoorzitting half mei is?

[Nick Lee @NicklesLee]

@ParvizMalakouti There are ~106 amendments under consideration, so it’s anyone’s guess where this ends

[Nick Lee @NicklesLee]

@ParvizMalakouti @AnnaBower Yeah, the expedited discovery order had a bunch of named depositions & two “of choice”.

Presumably for those, they’d want to go up the food chain instead of shaking down an intern