Monthly Archives: February 2016

Solving U.S. Citizenship Problems Sat, Mar 5, 2016 PARIS Fra

 


 
PARIS FRA
 
french us flags

WHEN: Saturday MARCH 5, 2016 11:00 – 13:00 CET

WHERE: Comptoir Voltaire / 253, boulevard Voltaire 75011 Paris / Metro & RER: Nation MAP

ADMISSION: €15 Payable in cash on the door please (to cover costs).
 
WHO: John Richardson, B.A., LL.B., J.D. (Of the bars of Ontario, New York and Massachusetts), Toronto citizenship lawyer- citizenshipsolutions.ca and Co-chair of the Alliance for the Defence of Canadian Sovereignty and the Alliance for the Defeat of Citizenship Taxation

Information presented is NOT intended or offered as legal or accounting advice specific to your situation.

 

Why the S. 877A(g)(1)(B) “dual citizen exemption” encourages dual citizens from birth to remain US citizens and others (except @SenTedCruz) to renounce

cross-posted from citizenshipsolutions.ca

Ted Cruz was born in 1971 in Canada. He was therefore born a Canadian citizen. He claims to have been born to a U.S. citizen mother and was therefore a U.S. citizen by birth. (Whether he qualifies as a “
natural born citizen
” is a different question.) As a Canadian citizen he had the right (prior to renouncing Canadian citizenship) to live in Canada. Had Mr. Cruz, moved back to Canada, he could have avoided the U.S. S. 877A Exit Tax. Incredible but true. It will be interesting to see whether Mr. Cruz regrets renouncing his Canadian citizenship. As you will see, by renouncing Canadian citizenship, Mr. Cruz surrendered his right to avoid the United States S. 877A Exit Tax.

Here is why …

The S. 877A Exit Tax rules in the Internal Revenue Code, are the most punitive in relation to U.S. citizens living outside the United States (AKA Americans abroad). To put it simply, with respect to Americans abroad, the S. 877A Exit Tax rules:

– operate to confiscate assets that are located in other nations; and

– operate to confiscate assets that were acquired by U.S. citizens after they moved from the United States.

There is not and has never been an “Exit Tax” anywhere else that operates in this way. The application of the S. 877A Exit Tax to assets located in other nations, is both an example of “American Exceptionalism” at its finest and a strong deterrent to exercising the right of expatriation granted in the “Expatriation Act of 1868“.

But, the “Exit Tax” applies ONLY to “Covered Expatriates” and “dual citizens from birth” can avoid being “Covered Expatriates”

As has been previously discussed, the Exit Tax applies ONLY to “ covered expatriates“. There are two statutory defenses to becoming a “covered expatriate”. This post is to discuss the “dual citizen from birth” defense to being treated as a “covered expatriate”. I have discovered that this defense is NOT as well known or understood as it should be.

The statute granting the “dual citizen from birth” defense to “Covered Expatriate” status reads as follows:

Continue reading

More Liberal Hypocrisy

Here we go again.

First, it was Justin Trudeau. Today, Citizenship and Immigration Minister John McCallum proclaimed “A Canadian is a Canadian is a Canadian.

In announcing plans to repeal the Conservatives’ Bill C-24 that allowed revoking Canadian citizenship of terrorists and others, Mr. McCallum said:

“It is a question of principle,” McCallum told reporters Thursday. “We do not need an additional set of rules that would create two classes of citizen.”

“If one believes that a Canadian is a Canadian is a Canadian … those principles must be applied universally.”

Hmm Mr. McCallum. FATCA is a question of principle too. And two classes of citizenship. And rights. And our loyalty. And the Charter. And sovereignty.

And Liberal betrayal. And Liberal hypocrisy.

Solving US Citizenship Problems – Munich DE- Thursday March 3, 2016

 


 
MUNICH DE

Solving US Citizenship Problems

Interactive discussion; updates on FATCA reporting, CBT lawsuit and other issues

WHO: John Richardson B.A., LL.B, J.D. licensed in Ontario, New York & Massachusetts. Member of ACA Tax Advisory Panel. Toronto citizenship lawyer- citizenshipsolutions.ca and Co-chair of the Alliance for the Defence of Canadian Sovereignty and the Alliance for the Defeat of Citizenship Taxation

WHEN: Thurs, March 3, 2016 19:00 – 21:00

WHERE: Eine WeltHaus München, Schwanthalerstraße 80, 80336 München, Germany MAP

ADMISSION: £15. Payable in cash on the door please (to cover costs).

Information presented is NOT intended or offered as legal or accounting advice specific to your situation.

Solving US Citizenship Problems-London UK Monday, February 29, 2016

 


 

LONDON UK
Solving US Citizenship Problems
 
Interactive discussion; updates on FATCA reporting, CBT lawsuit and other issues
 
WHO: John Richardson B.A., LL.B, J.D. licensed in Ontario, New York & Massachusetts. Member of ACA Tax Advisory Panel. Toronto citizenship lawyer- citizenshipsolutions.ca and Co-chair of the Alliance for the Defence of Canadian Sovereignty and the Alliance for the Defeat of Citizenship Taxation

WHEN: Monday, February 29, 2016 18:30 – 20:30

WHERE: University of London International Hall Meeting Room, Landsdowne Terrace, London WC1N 1AS UK – 150m walk
from Russell Square Tube Station MAP

ADMISSION: £15. Payable in cash on the door please (to cover costs).