AIRLINE PILOT!!! Chances for PR?

[BBCWatcher]

One wild thought, will your MSL contribution go up to >$20KUSD ever?

I don't know, and neither do you. All we know is that through October, 2015, Singapore didn't have CBT. Now it does, and with a much higher tax incidence among overseas citizens/PRs. (The highest incidence CBT in the world, it certainly appears.) Singapore's income tax rates are increasing next year (Year of Assessment 2017). Singapore's birth rate is among the lowest in the world, and the government wants the total population to level off. You do the math.

There was a period of time when the United States didn't have the Foreign Earned Income Exclusion, back in the 1970s, and had a top marginal income tax rate of 70%. The percentage of U.S. citizens living overseas who owed any U.S. tax on non-U.S. source income was much higher than today's 6%, and among those who did owe tax the percentage owed was, on average, much higher. Today there is now a certain percentage of Americans living overseas who have a negative tax rate, meaning they get CBP (citizenship-based payments) via the U.S. tax code. President Obama has proposed increasing that free money, and several presidential candidates have proposed slashing U.S. taxes. You do the math.

Tax laws and regulations can change overnight, and they do. So can lots of other events. For example, there are many people alive who remember when Singapore was invaded and occupied by a foreign power that acted quite brutally.

I have absolutely no problem with whatever your husband decides, but it's completely silly to argue that U.S. citizenship isn't valuable, at least on a contingent basis. Of course it is. Many other citizenships are valuable too. Every citizenship is a package deal of evolving rights, privileges, obligations, and responsibilities.

You mentioned being Hollywood celebrities, professional skier and baseball players. However, my husband is none of them.

At present. How about his future children? One assumes we dream big dreams for our children.

[ricedoll]

There is no guarantee whatsoever that any particular foreigner can enter the United States. There have been periodic, specific proposals in Congress to ban renunciants from entry into the United States. Former U.S. citizens should assume that there is a possibility they will be denied all entry into the United States in the future.

What a joke! I know first-hand of many ex-Americans with zero problem traveling back to the US on their new passports. Some said, they even had a friendlier immigration custom experience! If what you proposed ever happens, that would be pure discrimination on US soil. Please don't be silly.

And please educate me on CBP. Where are these Americans residing in? Europe? Or what industries do they work in?

[BBCWatcher]

I know first-hand of many ex-Americans with zero problem traveling back to the US on their new passports.

There is no guarantee that a foreigner can enter the United States, and Congress really did seriously consider barring ex-citizens from the United States. It may do so again. You must assume it is possible that you will not be able to set foot in the United States if you are a former U.S. citizen.

Roger Ver is a former U.S. citizen who has not been able to enter the United States. You can look him up. His attorney advised him that he would be able to travel to the U.S. to visit his family and to speak at conferences. His attorney was wrong.

If what you proposed ever happens, that would be pure discrimination on US soil.

Yes, it would. And perfectly legal even under present U.S. law. Foreigners have no right of entry.

Please don't be silly.

I am entirely serious. There are many possible futures, and one must plan for never being able to visit the United States if one renounces U.S. citizenship. It is a realistic possibility. Ask Roger Ver.

If guaranteed access to the United States is important, then don't renounce U.S. citizenship.

And please educate me on CBP.

Under current U.S. tax law "CBP" tends to happen in two common scenarios:

1. A young adult U.S. citizen or U.S. permanent resident living practically anywhere attending any university (inside or outside the U.S.) on the U.S. Department of Education's list on a full-time basis and with typical (or even slightly atypical) young adult/college age income levels. Such individuals typically qualify for $1,000 per year in free money from the IRS (the American Opportunity Tax Credit), up to $4,000 total.

2. A U.S. citizen or U.S. permanent resident with one or more documented U.S. citizen children living in any comparatively high tax country and with a middle class (or even slightly upper middle class) or lower total income. Such households can typically qualify for $1,000 per year per child in free money from the IRS (the Additional Child Tax Credit) and also excess Foreign Tax Credits.

There are many comparatively high tax countries, and only some of them are in Europe. Japan, Australia, New Zealand, and Canada are other examples for most households. The U.S. is down around #50 (depending on which list you check) in total tax burden, so there are plenty of comparatively higher tax countries.

[ricedoll]

1. A young adult U.S. citizen or U.S. permanent resident living practically anywhere attending any university (inside or outside the U.S.) on the U.S. Department of Education's list on a full-time basis and with typical (or even slightly atypical) young adult/college age income levels. Such individuals typically qualify for $1,000 per year in free money from the IRS (the American Opportunity Tax Credit), up to $4,000 total.

2. A U.S. citizen or U.S. permanent resident with one or more documented U.S. citizen children living in any comparatively high tax country and with a middle class (or even slightly upper middle class) or lower total income. Such households can typically qualify for $1,000 per year per child in free money from the IRS (the Additional Child Tax Credit) and also excess Foreign Tax Credits.

Com'on, we both know with our current salary, $1000 per year for schooling or free money from the IRS is nothing. Compared to the US taxes we pay, this sum is negligible. Without CBT, I could spend more than $10,000 on my child per year if I desire. Do you have kids?

[ricedoll]

Roger Ver, nicknamed Bitcoin Jesus, (b. ~1979) is a Kittitian/Nevisian early investor in bitcoin related startups who was formerly an American citizen.

He leveraged his gains and invested over a million dollars into new bitcoin related startups including Blockchain, Ripple, and BitPay.[1]

Ver pled guilty to selling explosives on eBay in 2002, and was sentenced to 10 months in federal prison.[2][3][4]

He renounced his United States citizenship in 2014. In 2015 he was denied a visa to reenter the United States by the US Embassy in Barbados which claimed that he had not sufficiently proven ties outside of the USA that would motivate him to leave at the end of his visit, causing fears he might become an illegal immigrant. Later his visa was approved by the US Embassy in Tokyo.

First of all, he was a federal prisoner, the serious kind. We are all law-abiding citizens.
Secondly, we have more than suffice and strong proven ties outside of the US.

[BBCWatcher]

Com'on, we both know with our current salary, $1000 per year for schooling or free money from the IRS is nothing. Compared to the US taxes we pay, this sum is negligible.

You misunderstood, completely.

It's a negative tax rate, truly. In the scenarios I described -- quite common and realistic scenarios -- those individuals owe zero U.S. tax and they receive free money from the IRS. Their total U.S. tax rates are negative. This is also part of the U.S. tax code. U.S. citizenship has its privileges.

[BBCWatcher]

We are all law-abiding citizens.

No, were your husband to renounce his U.S. citizenship he would not be a law-abiding citizen at least because he wouldn't be a citizen. Foreigners have no right of entry into the United States. If guaranteed right of entry into the United States is important to have, then a U.S. citizen should not renounce his/her citizenship. Nobody except a U.S. citizen has a guaranteed right of entry into the U.S. (and right of indefinite stay). A renunciant must be prepared for the possibility of never being able to visit the United States again.

[Strong Eagle]

We are all law-abiding citizens.

No, were your husband to renounce his U.S. citizenship he would not be a law-abiding citizen at least because he wouldn't be a citizen. Foreigners have no right of entry into the United States. If guaranteed right of entry into the United States is important to have, then a U.S. citizen should not renounce his/her citizenship. Nobody except a U.S. citizen has a guaranteed right of entry into the U.S. (and right of indefinite stay). A renunciant must be prepared for the possibility of never being able to visit the United States again.

To add onto what BBCWatcher has said...

I assume your husband already has a second citizenship and that your intention is that you and he will be living in the country of that citizenship?

No? Then you have a couple of problems. If he has no second citizenship already, then with the renunciation of US citizenship he becomes stateless. That's not such a hot deal, especially for an international airline pilot... no citizenship = no passport.

Oh, you say your husband does have a second citizenship but you're not going to be living in the country of his citizenship? Then your husband is going to have an interesting time trying to prove that his only reason for renouncing his citizenship was not to avoid taxes.

See, if you're moving to your other citizenship home country, you can make the argument that you don't need US citizenship. But, if you're merely moving to Singapore, with a lower tax rate, and then you renounce US citizenship, then, well... if it looks like a duck and it quacks like a duck, it is a duck, and it certainly looks like the whole reason for him renouncing his citizenship, based upon your comments in this thread, is simply to avoid paying US tax.

And, if that determination is made by the US authorities, two things happen. First, he will be subject to an "exit" tax. All assets held in the USA by him are evaluated at "mark to market" prices the day before the renunciation becomes effective, and taxes must be paid on all gains as though the asset were sold. This exit tax will also be applied if your husband cannot show that he was in tax compliance in the 5 years immediately preceding his renunciation date.

And second, he will be permanently denied entry into the USA, just like a terrorist or a convicted felon, should the US determine he gave up citizenship to avoid paying taxes. It's permanent, there is no appeal. Read about London Mayor Boris Johnson.

Same for the renunciation of US citizenship. Unlike the UK or Canada, where you can can renounce your citizenship and then apply to get it back, US renunciation is irrevocable.

So... you really ought to think this through and read the comments I am going to be making in the other thread you are in. But the taxes? You sound rather greedy to me.

[sundaymorningstaple]

Actually, she sounds like a Singaporean Chinese girl who got lucky and now thinks she's a tai-tai.

[ricedoll]

First of all, the desire to renounce US citizenship (if ever) in the future is
1. We will never plan to move back / work in the US
2. We very much prefer living in SG and/or the country we are in now
3. I believe the education system here and in SG will benefit my future kids a lot more.
4. So if we never plan to raise our family in the US, any liabilities along with the US passport will only be more negatives than positives. The reason I went into discussing the US tax issue was I could foresee this happening for as long as my husband is holding the US passport and working overseas. Of course for wherever here or in SG where he could enjoy a stable career and good lifestyle, that's where we would long stay, and where one day we hope to acquire citizenship.

The elaborated discussion on FATCA, Citizenship Based Taxation and US taxes was necessary because it affects 8 million Americans overseas. I am surprised many Americans living in the US never heard about this. I would not say this is the no.1 factor why one day my husband would renounce, but this will be one of the few.

Same reason why many others want to get citizenship of another country other than their own. Because they see themselves settling down and creating a life, making a living in that country.

[ricedoll]

SundayMorning, marriage is not a stroke of luck. And why in your opinion that being married to a Caucasian pilot is lucky?
And I don't see myself as a tai-tai. Thank you.

[BBCWatcher]

I'm going to disagree with you slightly, Strong Eagle. It's important to be entirely factual here, so let's review the facts.

First, under present tax law there is no U.S. Expatriation Tax unless the U.S. person renouncing (or relinquishing) U.S. citizenship has a total global net worth of at least $2 million on the date of renunciation. Even then there may be no U.S. Expatriation Tax owed -- it depends on the financial and other circumstances.

Second, there is in fact a law called the Reed Amendment that Congress passed and the President signed in 1996. It is U.S. law now, already. The Reed Amendment bars the entry of former U.S. citizens deemed to have renounced their U.S. citizenships for the avoidance of tax. However, at present the enabling regulations and enforcement mechanisms have not been put in place. So the law is there, ready in waiting, but it isn't being enforced yet.

Nonetheless, given the fact that Congress and the President have previously agreed to the Reed Amendment -- indeed, it is law -- and given also that Congress has continued to tighten up U.S. immigration, an individual considering renunciation of his/her U.S. citizenship should plan for the possibility of never being allowed to step foot in the United States again, exactly as I wrote. That's the only reasonable, logical, considered viewpoint in these circumstances.

To pick a couple examples of how Congress has recently acted (with the agreement of the President), starting on January 1, 2016, the U.S. State Department can now suspend or revoke the U.S. passports of "seriously tax delinquent" individuals, defined as those with an unresolved, formal IRS tax lien of at least $50,000. Reportedly the IRS and State Department were ready to go, so this has started -- and it's similar to the delinquent child support rules that already existed. Also, the U.S. government has cancelled ESTA visa waiver privileges for individuals who hold a second citizenship with any of a few "unpopular" countries (such as Iran) and for individuals who have travelled to such countries. For example, a person who is a citizen of both the U.K. and of Iran can no longer obtain U.S. ESTA travel permission and can no longer travel to the U.S. under the Visa Waiver Program. The "bad" citizenship (or travel history) cancels out the "good" citizenship for these purposes.

In 2012 Congress considered a "juiced up" Reed Amendment called the Ex-PATRIOT Act. That law did not pass, but (in simple terms) it would have increased some renunciants' taxes and barred their U.S. entry. The "seriously tax delinquent" passport revocation law took several years to pass, but pass it did. The Ex-PATRIOT Act, or something like it, might pass in the future. When there is a "notorious" case that upsets Congress -- another Eduardo Saverin, for example -- it would not be surprising if Congress tightens up entry. Note that the Ex-PATRIOT Act would have affected many past renunciants as well as future renunciants, so it is not reasonable to assume that renunciation now under present law would offer any assurances. Foreigners simply have no legal right of entry into the United States, and Congress can do whatever it wants whenever it wants with respect to any foreigners.

[Strong Eagle]

^^^^^^^^^
I read the IRS regulations and it's not only 2 million... it's any of three conditions.

https://www.irs.gov/Individuals/Interna ... iation-Tax

Expatriation on or after June 17, 2008

If you expatriated on or after June 17, 2008, the new IRC 877A expatriation rules apply to you if any of the following statements apply.

• Your average annual net income tax for the 5 years ending before the date of expatriation or termination of residency is more than a specified amount that is adjusted for inflation ($147,000 for 2011, $151,000 for 2012, $155,000 for 2013 and $157,000 for 2014).
• Your net worth is $2 million or more on the date of your expatriation or termination of residency.
• You fail to certify on Form 8854 that you have complied with all U.S. federal tax obligations for the 5 years preceding the date of your expatriation or termination of residency.
  If any of these rules apply, you are a “covered expatriate.”

So, you don't need to be worth US$ 2 million for the tax to apply to you. You need to make about $160K a year, or you need to have failed to fully comply with all tax obligations.

I agree that the act barring former US citizens from entry for non payment of tax has not been enforced. Given the other squeezes that have been placed on tax deadbeats, I wouldn't be surprised to see some high profile person being used as an example.

[BBCWatcher]

Fair point, but read that again carefully. You must have a U.S. income tax bill in those big amounts. A $250K pilot doesn't have a $150K U.S. income tax bill under any circumstances.

[ricedoll]

http://www.wsj.com/articles/SB100014240 ... 1011995562

Facebook co-founder Eduardo Saverin renounced his U.S. citizenship last year and now is a resident of Singapore.
How much did he save on his taxes by making the switch then?

Why is the news article focused on taxes if he said he did not move to Singapore for tax reasons? And I need to know does he have any problem returning to the US.