Why Americans don't wanna be Americans anymore?Record number of renounced citizenship

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Jhhnn

IN MEMORIAM
Nov 11, 1999
62,365
14,681
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He owed taxes on the sale of his home in London. Afterwards he renounced his US citizenship and may have had to pay more (the so-called "exit fee").

Read this: http://www.forbes.com/sites/robertw...n-paid-irs-is-now-renouncing-u-s-citizenship/

Fern

Please. It's just Johnson making himself into a poster boy, getting more publicity. According to him, it's not about taxes at all-

http://www.boris-johnson.com/2006/08/29/american-passport/

I think he has some legit points, particularly wrt the waves of stupidity emanating from the events of 9/11.

It's pretty remarkable how our so called liberal media made it into something it never was, huh?
 

Fern

Elite Member
Sep 30, 2003
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The question wasn't why should he have had to pay upon renouncement. How could the was have made sense?

Look, as an international tax professional I was just trying to answer your question:

I don't understand your point. Why should someone like the mayor of london pay an exit tax if he renounced?

The answer is that as a US citizen he was subject to the exit tax.

If your question is what is the purpose or reason for the exit tax the answer is to eliminate tax avoidance as a motive for expatriation (giving up citizenship).

Fern
 

justoh

Diamond Member
Jun 11, 2013
3,686
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Look, as an international tax professional I was just trying to answer your question:



The answer is that as a US citizen he was subject to the exit tax.

If your question is what is the purpose or reason for the exit tax the answer is to eliminate tax avoidance as a motive for expatriation (giving up citizenship).

Fern

I asked why a person in his circumstances should have to pay an exit tax. Obviously this set of circumstances includes him being a us citizen, otherwise he couldn't renounce.

Make sense?

So, "because he's a us citizen," is a non answer. hence the verb stuff. irritation.

To prevent other people, in other circumstances, from evading legitimate/reasonable tax responsibilities, also isn't an answer, because he isn't them.
 

Fern

Elite Member
Sep 30, 2003
26,907
173
106
Please. It's just Johnson making himself into a poster boy, getting more publicity. According to him, it's not about taxes at all-

http://www.boris-johnson.com/2006/08/29/american-passport/

I think he has some legit points, particularly wrt the waves of stupidity emanating from the events of 9/11.

It's pretty remarkable how our so called liberal media made it into something it never was, huh?

I don't get that meaning from the info you linked. Furthermore, he has railed on about owing US income taxes so long and so often I've lost count.

(I did notice that he has apparently still not renounced his US citizenship.)

But otherwise, the guy's an idiot:

It’s the arrogance. What other country insists that because you can be one of its nationals, then you must be one of its nationals?

As far as I can interpret the psychology of the rule, which has only been applied since 9/11, it is part of America’s new them-and-us mentality, the Manichaean division of the world into Americans and non-Americans, obliterating any category in between. Listen, buddy, the Americans seem to be saying. You got a right to be American? Then you do us the courtesy of travelling on the world’s number one passport when you come here. What you got to be ashamed of, boy?

See more at: http://www.boris-johnson.com/2006/08/29/american-passport/#sthash.6K1t3wBa.dpuf

He's a fool. Europe adopted similar rules after 911. My wife was born in Italy and for many years traveled under her Italian passport. Later as an adult she also received a French passport. So, for many years she was a dual citizen. However, post 911 Europe allowed only one passport and her Italian passport was stripped leaving her with just the French one.

He could be viewed as fortunate that the US is allowing him the two passports. He's twisting this privilege granted by the US into some sort of complaint about arrogance on its part.

In any case, the US is not the only that requires its citizens to use that passport for travel in country:

Question #1: “Can I enter a country I am a citizen of without using its passport?”

No, this is basically illegal and should not be done. Even if one of your passports is expired, that doesn’t mean you can just use the other one. That’s misrepresenting yourself to your country’s authorities.
http://www.stylehiclub.com/tips-gen...asked-questions-traveling-with-two-passports/

Fern
 

Fern

Elite Member
Sep 30, 2003
26,907
173
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-snip-
To prevent other people, in other circumstances, from evading legitimate/reasonable tax responsibilities, also isn't an answer, because he isn't them.

1. I didn't write "To prevent other people, in other circumstances". What I did write is the purpose behind the law.

2. Avoidance and evasion are two different things. Avoidance is legal, evasion is illegel.

Fern
 
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justoh

Diamond Member
Jun 11, 2013
3,686
81
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1. I didn't write "To prevent other people, in other circumstances". What I did writeis the purpose behind the law.

2. Avoidance and evasion are two different things. Avoidance is legal, evasion is illegel.

Fern

Why should he have to pay an exit tax (or indeed any us taxes at all)?
 

Fern

Elite Member
Sep 30, 2003
26,907
173
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Why should he have to pay an exit tax (or indeed any us taxes at all)?

As I wrote above: the purpose of the exit tax is to eliminate tax avoidance as a motive for expatriation (giving up citizenship).

As for income taxes "at all" - Upon passing tax legislation Congress will publish its intent, or purpose, behind the law. These publications are called "Bluebooks". Worldwide taxation was part of the initial tax law, likely passed shortly after 1913. My resources do not go back that far.

However, the Supreme Court ruled on the issue (worldwide taxation) in the case of Cook v. Tait (165 U.S. 42 (1924). If you can find that case, you'll probably find your answer as the SCOTUS often discusses Congressional intent when ruling on income tax issues.

Fern
 

Jhhnn

IN MEMORIAM
Nov 11, 1999
62,365
14,681
136
I don't get that meaning from the info you linked. Furthermore, he has railed on about owing US income taxes so long and so often I've lost count.

(I did notice that he has apparently still not renounced his US citizenship.)

But otherwise, the guy's an idiot:



See more at: http://www.boris-johnson.com/2006/08/29/american-passport/#sthash.6K1t3wBa.dpuf

He's a fool. Europe adopted similar rules after 911. My wife was born in Italy and for many years traveled under her Italian passport. Later as an adult she also received a French passport. So, for many years she was a dual citizen. However, post 911 Europe allowed only one passport and her Italian passport was stripped leaving her with just the French one.

He could be viewed as fortunate that the US is allowing him the two passports. He's twisting this privilege granted by the US into some sort of complaint about arrogance on its part.

In any case, the US is not the only that requires its citizens to use that passport for travel in country:


http://www.stylehiclub.com/tips-gen...asked-questions-traveling-with-two-passports/

Fern

First, hold up Johnson as the poster boy in the fight against the evil IRS, then call him an idiot & a fool because the Italian govt revoked your wife's Italian passport. As if the situations are vaguely analogous.

European govts followed along with Uncle Sam wrt their own passport situations? Humored the Americans? Sure, why not? Dual citizenship is a PITA for govts. As Johnson notes, being an American citizen has perks, especially if you get pinched in a foreign country. Our govt is obliged to come to his aid if he is, even if he hasn't lived here since he was 5. We're also obliged to allow him entry on an American passport, use our legal system to defend his interests. That citizenship grants him privilege that other Britishers don't have. It's only reasonable that he should comply with American tax law to have that. The rest of us do. The rest of us need to show our American passport to enter the country, as well.

He's right, however, that mostly nobody bothered with the passport thing prior to 9/11 because it affects an extremely small % of world population. The tech to do so has advanced tremendously in the meanwhile, too. They used to have it both ways for free, but now they don't, and all for the wrong reasons, too.

Wah.

It's important to recognize that Johnson is quite wealthy, meaning he doesn't do his own taxes. So where were his financial advisors when he sold the house? Did he really get ambushed, or did he spend the money to have a great publicity stunt?

He *is* out on the circuit pitching his book...
 

justoh

Diamond Member
Jun 11, 2013
3,686
81
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I don't think anybody said that he did. They merely speculate to fan the flames of outrage.

Maybe he doesn't. I don't know how much money he has. It's unimportant, though. That's why i used the word, "should." If he does have to, why should he have had to?

As far as paying us taxes at all, before renouncement, how did he benefit from US citizenship, which is the justification for world-wide taxation?

re the exit tax, they can easily make the determination that he isn't of the type described by some who would leave the country just to avoid taxation. He left long ago. As people love to point out, there are relatively few cases of people renouncing, so he doesn't have to be collateral in some sensible measure to prevent others from avoiding more legitimate responsibility; they can make individual determinations (when did he leave; where was he domiciled at the time he made the relevant investments, or probably better, was he a permanent resident of somewhere else, not just domiciled, with manifested intent not to return, or something, when he made the investments (if that's possible). Some minimum US contacts test, I don't know... whatever would make sense).
 
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Fern

Elite Member
Sep 30, 2003
26,907
173
106
First, hold up Johnson as the poster boy in the fight against the evil IRS,

Who held up who? It sure as hell wasn't me. Try sticking to facts.

then call him an idiot & a fool because the Italian govt revoked your wife's Italian passport.

Yeah, he's a fool.

He went on his bitch/rant about the US when pretty much every other country requires the same thing.

And yeah, the Italy story is relevant. If his second passport would have been from another Euro country they just would have just taken it away from him. He wouldn't have been given a choice. The moron's lucky he still has two passports. If he's too stupid to figure out the rules maybe he should give it up.

IMO, his problem is that of a .1%'er and he can STFU.

Fern
 

Fern

Elite Member
Sep 30, 2003
26,907
173
106
-snip-
re the exit tax, they can easily make the determination that he isn't of the type described by some who would leave the country just to avoid taxation. He left long ago. As people love to point out, there are relatively few cases of people renouncing, so he doesn't have to be collateral in some sensible measure to prevent others from avoiding more legitimate responsibility; they can make individual determinations (when did he leave; where was he domiciled at the time he made the relevant investments, or probably better, was he a permanent resident of somewhere else, not just domiciled, with manifested intent not to return, or something, when he made the investments (if that's possible). Some minimum US contacts test, I don't know... whatever would make sense).

Years ago that's how it worked. I.e., you could apply for an individual ruling from the IRS. If the IRS determined that tax avoidance was not the reason for renouncing citizenship you were not subject to the exit tax.

Fern