I have no problem with any legally competent adult who decides to terminate any citizenship per its democratically decided termination provisions.[/quoteBBCWatcher wrote:sundaymorningstaple wrote:Good riddance springs to mind.
No, you're just factually wrong, entirely. Sorry about that, but let's look at the facts.sundaymorningstaple wrote:Any time the president can circumvent Congress with 'executive orders' says it all.
You could exercise your luck and earn money hardworking for the opportunity the country, the past and current generations of the citizens created for you. Yes, it's an old fashion and sounds like a cliche and hard to understand for the generations who never had really to fight for some basic rights, but like it or not, you owe them a lot. Be happy it comes down only to the money.ricedoll wrote:Our income is not from a US company either. How dare you use the word OWE?
Accidental Americans' U.S. citizenship arises due to their parents' ties to the United States rather than their own choices: they may be born in their own country but to one U.S. citizen parent who emigrated from the United States, or they may be born in the U.S. to parents residing in the country temporarily for work or study and then return to their own country in their early childhood, with few if any memories of the United States. The term may also sometimes be applied to people who definitely are not U.S. citizens but have some other sort of connection with the country, for example green card holders who moved back to their country of origin and let their green cards expire without formally cancelling their U.S. immigration status, or non-U.S. citizens married to Americans abroad. Such tenuous connections to the United States began to become a more salient issue in the late 2000s due to Internal Revenue Service crackdowns which were ostensibly aimed at tax evaders hiding assets in secrecy jurisdictions but ended up having much broader effects on people with U.S. citizenship who resided in other countries, as well as their families.
EXACTLY! And for us, its beyond taxation. Its about never returning to the US, its about us liking the world outside of the US, its about us having better job stability and better International School education for our kids; tax is only one part of it. And thanks for letting me how much the renouncing fees cost.I have a friend who gave up his based on the math alone. What held him back initially was the prospect of his children not enjoying citizenship when he has any and retirement. But he figured the extra money he can pocket for the next 35 years of his professional career will make up for all that.
Now I wonder why Uncle Sam skyrocketed the fees? To firewall rich people from renouncing or... I don't know? Please enlighten me. And thank god its only $2000. Not $20,000 EVERY SINGLE YEAR. We've got our coins all saved up in the piggy bank!When the news broke a year ago that the U.S. was hiking the fee to renounce U.S. citizenship by 422% there was a backlash. If anything, the uptick in American expatriations grew rather than declined. The U.S. State Department said raising the fee for renunciation of U.S. citizenship is about demand and paperwork. Perhaps, but a hike from $450 to $2,350 is still steep. That is more than twenty times the average level in other high-income countries.
I know close to nothing about the US tax system so I can not speculate here but I can try on a more general level.ricedoll wrote:Okay I agree to your reasoning. BUT why is it only the US? Why so exclusive?
Does it work like I'm repaying money for the opportunities the country has created for me? Or does it work like Asian filial piety where I give my parents money for the years the brought me up? This unreasonable taxation has no justifiable reasoning. Your reasoning only makes you feel more comfortable being taxed. But this is not the ultimate reason of the CBT taxation.
A collateral damage from the system that perhaps needs a non-oppressive solution in place but I believe in most of such cases it was possible renounce the U.S. citizenships before reaching the productive age. Or not? Is it any worse comparing to the NS system in Singapore? Is it any worse for any other country with compulsory NS?ricedoll wrote:As much as you make it sound like "ok, I am paying taxes because I'm successful being born in the US and eventually got a good job." Have you heard of Accidental Americans? They are born in the US, many left as infants, spent decades overseas and now the IRS is after them, treating them as Americans who have used the facilities and systems of the country. In fact many Canadian Americans are filing a lawsuit regarding this matter.
Easy answer: no. But this is not an argument relatively well-to-do people (or above) like. This reality, that there are about 40 countries with compulsory military service (but not the U.S.), is "inconvenient."x9200 wrote:Is it any worse comparing to the NS system in Singapore? Is it any worse for any other country with compulsory NS?
Sorry, I missed this part of your question. Yes, any U.S. citizen adult can renounce his/her own citizenship. That option is available at any time from the individual's 18th birthday onward and occasionally before that (if the individual is legally emancipated).x9200 wrote:....I believe in most of such cases it was possible renounce the U.S. citizenships before reaching the productive age. Or not?
If you sell your primary residence (i.e. where you are living now) you should be entitled to the homeowners' exclusion (currently $500K for joint filing).ricedoll wrote:If he sells our house where we are living now, the US taxes the profit of this transaction! This is not just filing taxes, but paying taxes on what you make through your own overseas property!(
http://www.lexisnexis.com/legalnewsroom ... pheld.aspxFrom Pub 54
3) My entire income qualifies for the foreign earned income exclusion. Must I file a tax return?
Generally, yes. Every U.S. citizen or resident who receives income must file a U.S. income tax return unless total income without regard to the foreign earned income exclusion is below an amount based on filing status. The income levels for filing purposes are discussed under Filing Requirements in Chapter 1.
Foreign Earned Income Exclusion Timely Election Rules Upheld
The Tax Court recently upheld the validity of Treasury Regulations Section 1.911-7(a)(2) in a case where the taxpayer sought application of the foreign earned income exclusion (FEIE) under IRC Section 911, but was denied the exclusion because she had failed to make a timely election pursuant to Section 1.911-7(a)(2). [McDonald v. Commissioner, TC Memo 2015-169]. In the case, the taxpayer worked overseas in 2009 but did not file an income tax return for that year. [Id]. In 2010 the IRS prepared and filed for the taxpayer a substitute for return (SFR) for 2009, and in April 2012 the IRS issued a notice of deficiency (NOD) for 2009. [Id]. The taxpayer did not challenge the NOD, but instead filed a return for the 2009 tax year in May 2012. The taxpayer attached to the return a Form 2555, “Foreign Earned Income” form, claiming an exclusion for a portion of her income earned in 2009, and included a payment. [Id]. The IRS audited the taxpayer’s return and issued a second NOD in which the Service denied the taxpayer’s claimed foreign earned income exclusion on the grounds that:
1) the taxpayer did not make a valid election and did not file Form 2555 with a timely-filed return;
2) did not elect to exclude the foreign income on a prior return; and
3) did not otherwise comply with the procedure for making a valid election to exclude the foreign income under Section 1.911-7(a)(2).
The sole issue in the case was whether the taxpayer was entitled to the FEIE. The taxpayer’s claim that she was entitled to the exclusion was based primarily on her argument that Section 1.911-7(a)(2) was invalid. [Id]. The FEIE is provided for in IRC Section 911, which states: “At the election of a qualified individual (made separately with respect to paragraphs (1) and (2)), there shall be excluded from the gross income of such individual, and exempt from taxation . . . for any taxable year – (1) the foreign earned income of such individual, and (2) the housing cost amount of such individual.” [IRC Section 911(a)]. [Id]. The procedural rules for making an election are provided in Regulations Section 1.911-7. Regulations Section 1.911-7(a)(2) provides for the requirement of a return when making an election under IRC Section 911. As discussed by the court, Regulations Section 1.911-7(a)(2)(i) establishes the timing requirements under which a valid FEIE election can be made, and the regulation provides four alternative timing methods via which a taxpayer can make a valid election. [Id].
The court held that the Secretary had the statutory authority to impose a deadline for electing the FEIE. The court found that the Secretary had the authority under IRC Section 7805(d) to prescribe when the election was to be made. [Id]. The court also held that the regulation’s deadline was reasonable. [Id]. The court noted that the court had addressed and rejected the same challenge to Section 1.911-7(a)(2)in a prior case [Faltesek v. Commissioner, 92 T.C. 1204 (1989) ] where the court had held that the alternative periods in Section 1.911-7(a)(2)(i)(A) through (C) were not unreasonable or arbitrary and “were within the specific authority granted to the Secretary under section 911 as well as the Secretary’s general authority to promulgate regulations under section 7805.” [Id].
The court concluded that:
. . . the Secretary’s interpretation and implementation of the statute is valid, because it reasonably implements Congress's specific grant of authority in section 911(d)(9) to prescribe regulations that are necessary and appropriate to carry out the purposes of the statute, and Congress's general grant of authority under section 7805(d) to prescribe rules for the time and manner of making elections under the Code. The regulation provides taxpayers with four alternative methods by which they can timely elect the FEIE. The fact that the Secretary could have chosen longer periods within which to permit the election is of no consequence, because the alternative methods with four varying periods are reasonable. [Id].
Accordingly, the court ruled in favor of the Service and granted the Service summary judgment in the case. [Id]. The court’s clear and concise opinion presents an interesting example of the burden a taxpayer faces when challenging the validity of a treasury regulation.
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