Monday, July 27, 2020

Tax consequences of an expired (or not) US Green Card: The Twilight Zone Edition

Tax consequences of an expired (or not) US Green Card: The Twilight Zone Edition
Did you know that it is possible for you NOT to have a legal right to enter the US yet still be treated as a US tax resident on your worldwide income? That's right, the IRS can impose taxes and penalties on you - even if you can not legally come into the United States. This is just one of the many absurdities that can result when your earn a US Green Card but are not aware of how all the laws work. In this podcast, Immigration/Tax lawyer John Richardson of citizenshipsolutions.ca and Keith Redmond of American Expatriates 2.0 on Facebook join host Anthony Parent as they discuss some of the most bizarre hypothetical: 1. When it make sense to expatriate for tax purpose 2. Meghan Merkle's and Prince Henry's likely escape from the exit tax trap 3. The 8 year decision point. 4. Other ways you may want to enter in the US aside from a Green Card - it might be the wrong thing 5. What to do if you are not in compliance or are worried about something else. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/bHXdm97I5JI IRS Medic

Tuesday, July 21, 2020

Can the IRS Exit Tax be retroactive? Does IRC Section 877A go back in time?

Can the IRS Exit Tax be retroactive? Does IRC Section 877A go back in time?
Prior to 2004 a Certificate of Loss of Nationality (CLN) was not needed to renounce ones US citizenship for tax purposes. In 2004, that all changed with a law, Section 877A which now requiresd a CLN There is considerable debate whether or not Section 877A is retroactive in cases where a CLN was not issued. If a the interpretation that 877A is retro-active that would mean many US citizens are missing years of tax returns and foreign reporting. An because they would still be considered US persons, they would need to file Form 8854 and expatriate correctly,y including paying an Exit Tax, if due. One of the top experts, if not the top expert on nationality issues and how they relate the the IRS is John Richardson, Esq. of citizenshipsolutions.ca. John joined host Anthony E. Parent, Esq. of Parent & Parent, LLP a top international tax firm located in Connecticut. With them is Keith Redmond, a global advocate for the American overseas, founder of American Expatriates 2.0 Facebook. The three discuss there conclusions on why 877A is likely NOT retroactive, but why few professionals are willing to say that and give more detail to an article John wrote in 2015 on this subject at Isaac Brock Society https://ift.tt/2E8zaUl Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269 6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/xfqRLjYMozQ IRS Medic