Attention! Our Trip Is Entering International Waters: For Americans Abroad, Let The Double Taxation Begin!

January 21, 2022 - Participants include:

John Richardson - @Expatriationlaw

Jim Gosart - Vice-President Republicans Overseas

 

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Attention! We are entering "International Waters"! US Citizens be advised that you may now be subject to double taxation!

 

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To Whom Much Has Been Given, Much Is Expected!!

Yes, it's true! A US citizen, because and only because of the combination of US citizenship-based taxation coupled with living outside the United States, is likely to be subject to double taxation. The following discussion explains why.

Part A: Introduction – About Citizenship-based Taxation
Part B: How the Internal Revenue Code is designed to mitigate the effects of double taxation in certain circumstances
Part C: Determining what is “foreign source” income
Part D: The problem of international waters …
Part E: The effect of sourcing to the US income earned in international waters by dual tax residents
Part F: Deducting “foreign taxes” paid – although income from international waters may not be foreign, it is still subject to the payment of “foreign taxes”
Part G: Can a US citizen living abroad be saved by a tax treaty? Maybe if he/she lives in Canada****
Part H: Conclusion and the need for “Pure Residence-Based Taxation”

You can read the horrible details here ...

 

https://www.taxconnections.com/taxblog/airline-and-cruise-ship-employees-how-income-earned-in-international-waters-may-lead-to-double-taxation-for-only-americans-abroad/