Dr. Snyder, Dr. Alpert and Richardson: 'Mission Impossible: 'Extraterritorial Taxation and the IRS'

The uniquely American definition of “tax residency,” which includes the imposition of worldwide taxation on the tax residents of other countries who happen to be American (even if they don't realize it), has left the U.S. Internal Revenue Service in charge of overseeing the implementation of three separate and distinct tax systems: residence, source, and extraterritorial, according to Paris-based attorney and U.S. taxpayer rights campaigner Laura Snyder, Toronto-based U.S. citizenship lawyer John Richardson, and Australia-based, recently-retired university lecturer and FixtheTaxTreaty.org founder Karen Alpert...

Richardson, Snyder, Alpert: 'Treasury could also fix CBT'

While there is apparently some disagreement as to whether Albert Einstein ever actually said that the "definition of insanity is doing the same thing over and over again, but expecting different results," few would challenge the argument for changing one's approach when, after numerous attempts to do something, one is clearly making no progress whatsoever.

Among the latest advocates of this strategy are Toronto-based U.S. citizenship lawyer John Richardson, Paris-based attorney and U.S. taxpayer rights campaigner Laura Snyder, and Australia-based university lecturer and FixtheTaxTreaty.org founder Karen Alpert...

  • News

New anti-extraterritorial taxation expat organization forms; launches survey

Stop Extraterritorial American Taxation, or SEAT, is the name of a new education and advocacy organization that's been formed by a half a dozen individuals who are already well known in the community of Americans living overseas.

As part of its launch, the international not-for-profit group, which is based in France and headed by lawyer and Taxpayer Advocacy Panel member Dr. Laura Snyder, is unveiling a survey it says is "aimed at learning more about how persons living outside the United States experience the extraterritorial application of U.S. taxation and banking policies".

  • Tax

Foreign Earned Income Exclusion podcast: Tax experts analyze the complex (and some say imperfect) FEIE

At first, the Foreign Earned Income Exclusion might seem a potentially useful tool indeed in the tax-paying toolbox of Americans who are resident overseas. After all, notes Toronto-based citizenship lawyer and American expat rights campaigner John Richardson, in his preface to a just-posted set of online podcasts on the FEIE, it "allows you to exclude – Exclude! Exclude! – US$102,000 a year of income from your tax return!"

In fact, though, the FEIE is not anything like the solution to the long-suffering expat taxpayer's problems this statement suggests it might be, he, and four other participants in the three podcasts, go on to agree...

  • Tax

Karen Alpert: Unforeseen consequences expected as 'Recovery Rebate' is distributed to expats

There has already been much speculation by media organizations, American expat groups and cross-border U.S. tax specialists about how the US$2trn federal stimulus package known as the CARES Act, signed into law last Friday by President Trump, will actually impact American citizens and Green Card-holders living outside of the United States.

Here, Karen Alpert, an Australia-based academic and tax expert who oversees a blog entitled FixtheTaxTreaty.org, considers some of the unforeseen consequences that seem likely to emerge from the U.S.'s well-intentioned plan to distribute a "Recovery Rebate" to such non-US-resident Americans... 

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Opinion

AARO: Response to Senate Finance Committee, on 'How U.S. international tax policy impacts American workers, jobs and investment'

AARO: Response to Senate Finance Committee, on 'How U.S. international tax policy impacts American workers, jobs and investment'

On April 7, 2021, the Association of Americans Resident Overseas submitted its comments to the Senate Finance Committee, in response to the committee's review of U.S. international tax policy, and...

Apr-29-2021