ExpatriationLaw – X Spaces Lives Discussions – Ending Double Taxation Of Americans Abroad
ExpatriationLaw - X Spaces Lives Discussions - Ending Double Taxation Of Americans Abroad
Podcast Description
In 2024 President (then candidate) Trump pledged to end the "double taxation" of Americans abroad. This was welcome news to the community of overseas Americans. The Trump pledge was largely the result of work done by Republicans Overseas and the Republicans Overseas tax committee.
2024 was also a year of other groups and individuals "coming together" in an organized way to end the unfair taxation of Americans abroad.
I (John Richardson) started a series of live "X Spaces" discussions for the purpose of discussion of the taxation of the U.S. citizenship tax system - inflicted on Overseas Americans. The purpose of the discussions is to gain understanding and achieve agreement on the most important aspects of the problems. Where is there agreement? Generally, (regardless of specific differences) overseas Americans are united around the goal that Overseas Americans should be treated the same as nonresident aliens for the purpose of U.S. income taxation.
I am reposting the "X Discussions" here so that there is a record of what was said, by whom and why.
expatriationlaw.substack.com
Podcast Insights
Content Themes
The show emphasizes the inequities of the U.S. citizenship tax system impacting expatriates, including episodes addressing double taxation, FATCA reporting, and various reform proposals like the FAIR Tax and residency-based taxation. Specific discussions have included the implications of the Edelman case, the costs associated with ending citizenship taxation, and the challenges presented by IRS practices.
In 2024 President (then candidate) Trump pledged to end the “double taxation” of Americans abroad. This was welcome news to the community of overseas Americans. The Trump pledge was largely the result of work done by Republicans Overseas and the Republicans Overseas tax committee.
2024 was also a year of other groups and individuals “coming together” in an organized way to end the unfair taxation of Americans abroad.
I (John Richardson) started a series of live “X Spaces” discussions for the purpose of discussion of the taxation of the U.S. citizenship tax system – inflicted on Overseas Americans. The purpose of the discussions is to gain understanding and achieve agreement on the most important aspects of the problems. Where is there agreement? Generally, (regardless of specific differences) overseas Americans are united around the goal that Overseas Americans should be treated the same as nonresident aliens for the purpose of U.S. income taxation.
I am reposting the “X Discussions” here so that there is a record of what was said, by whom and why.
This AI generated podcast is based on a SEAT post announcing our latest article published in Tax Notes. The article explains how President Trump’s pledge to end the double taxation of Americans abroad can be achieved by the U.S. waiving it’s “saving clause” rights under the treaty.
To test your knowledge of the concepts, check out the flashcards at:
Unilateral Treaty Fix for Citizenship Taxation
1 source
The source argues for a unilateral treaty fix to mitigate the effects of U.S. citizenship taxation on Americans living abroad, particularly focusing on how this causes double taxation. The authors contend that the U.S. Treasury can achieve this by simply declining to use the “saving clause” in tax treaties, which currently reserves the U.S.’s right to tax its citizens as residents regardless of treaty provisions. If the Treasury refrains from invoking this clause, U.S. citizens could be treated as “treaty nonresidents” like Green Card holders, allowing them to benefit from the treaty’s residency “tie breaker” rules. This administrative action is proposed as a way for the President to fulfill a pledge to end the double taxation of expats without requiring legislative or formal regulatory changes. The text explains that the current system, supercharged by the saving clause, forces U.S. citizens abroad into dual tax residency, leading to worldwide taxation and complexity, often on non-U.S. source income.
This is a public episode. If you would like to discuss this with other subscribers or get access to bonus episodes, visit expatriationlaw.substack.com
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