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wiki:contents:us_tax:tax_reform [2017/10/13 09:49]
karen [Tax Reform Proposals] add note
wiki:contents:us_tax:tax_reform [2018/12/31 20:07]
karen [Tax Cuts and Jobs Act (2017)] link to category tcja on blog
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 ====== US Tax Reform ====== ====== US Tax Reform ======
 +
  
 ===== Tax Reform Proposals ===== ===== Tax Reform Proposals =====
  
 NB - this discussion covers only the proposals that relate directly to the taxation of non-resident US citizens and green card holders. NB - this discussion covers only the proposals that relate directly to the taxation of non-resident US citizens and green card holders.
 +==== Tax Fairness for Americans Abroad Act ====
 +
 +[[https://www.congress.gov/bill/115th-congress/house-bill/7358|HR7358]] was introduced by Rep. George Holding (R-NC) on 20 December 2018. See the [[http://fixthetaxtreaty.org/2018/12/21/tax-fairness-for-americans-abroad-act/|blog post]].
 +
 ==== Republicans Overseas ==== ==== Republicans Overseas ====
  
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-American Citizens Abroad issued their Residence Based Taxation (RBT) Proposal in 2016 and [[https://www.americansabroad.org/advancements-acas-residency-based-taxation-rbt-proposal/|updated it in February 2017]]. This proposal is the only RBT proposal [[http://www.democratsabroad.org/fbar_fatca_task_force_report|mentioned by Democrats Abroad]]. Karen's feedback on this proposal is available [[https://drive.google.com/file/d/0B4M9V1fcUGYsTjcxT2hmak1ISHc/view|here]]. Discussion of the ACA proposal and Karen's feedback is available [[http://isaacbrocksociety.ca/2017/04/17/aca-rbt-proposal-feedback-karen-alpert-2/|on the Isaac Brock Society website]].+American Citizens Abroad issued their [[https://web.archive.org/web/20171107235654/https://www.americansabroad.org/media/files/files/ad2154e6/Residency-Based_Taxation_ACA_Proposal_Side-By-Side_Comparison_161201_Final.pdf|Residence Based Taxation (RBT) Proposal in 2016]] and [[https://web.archive.org/web/20170414073521/https://www.americansabroad.org/media/files/page/0aacae5d/Residency-Based_Taxation_ACA_Descr_and_Side-By-Side_Comparison_170207.1.pdf|updated it in February 2017]]. This proposal is the only RBT proposal [[http://www.democratsabroad.org/fbar_fatca_task_force_report|mentioned by Democrats Abroad]]. Karen's feedback on this proposal is available [[https://drive.google.com/file/d/0B4M9V1fcUGYsTjcxT2hmak1ISHc/view|here]]. Discussion of the ACA proposal and Karen's feedback is available [[http://isaacbrocksociety.ca/2017/04/17/aca-rbt-proposal-feedback-karen-alpert-2/|on the Isaac Brock Society website]].
  
-The ACA RBT proposal allows non-resident US citizens to opt in to Residence Based tax rules (under which they would be taxed by the U.S. only on U.S. source income, just like any non-resident alien). To qualify for RBT, a US citizen must be a foreign resident for at least five years and must apply for a "Departure Certificate" from the IRS. A Departure Certificate would cost the same as the current renunciation fee (currently US$2,350), and could trigger the [[https://www.law.cornell.edu/uscode/text/26/877A|Section 877A exit tax]]. Non-resident citizens would still be required to file an annual [[https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar|Report of Foreign Bank Account (FBAR)]]. The proposal contains transitional rules for current non-resident citizens who are tax-compliant. It also repeals the [[https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion|Foreign Earned Income Exclusion]].+The February 2017 ACA RBT proposal allows non-resident US citizens to opt in to Residence Based tax rules (under which they would be taxed by the U.S. only on U.S. source income, just like any non-resident alien). To qualify for RBT, a US citizen must be a foreign resident for at least five years and must apply for a "Departure Certificate" from the IRS. A Departure Certificate would cost the same as the current renunciation fee (currently US$2,350), and could trigger the [[https://www.law.cornell.edu/uscode/text/26/877A|Section 877A exit tax]]. Non-resident citizens would still be required to file an annual [[https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar|Report of Foreign Bank Account (FBAR)]]. The proposal contains transitional rules for current non-resident citizens who are tax-compliant. It also repeals the [[https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion|Foreign Earned Income Exclusion]].
  
 In July 2017 ACA issued this discussion of "Territorial Taxation for Individuals": [[https://www.americansabroad.org/media/files/files/b88c9ece/Senate_Finance_Committee_July_17_2017_Tax_Reform_Hearing_-_ACA_ACAGF_Statement_1530.pdf|ACA Statement to Senate Finance Committee]]. In July 2017 ACA issued this discussion of "Territorial Taxation for Individuals": [[https://www.americansabroad.org/media/files/files/b88c9ece/Senate_Finance_Committee_July_17_2017_Tax_Reform_Hearing_-_ACA_ACAGF_Statement_1530.pdf|ACA Statement to Senate Finance Committee]].
 +
 +In October 2017, ACA issued this updated [[https://web.archive.org/web/20171108000832/https://www.americansabroad.org/media/files/files/8c367212/Residency-Based_Taxation_Vanilla_Approach_171015.pdf|description]] and [[https://web.archive.org/web/20171108001130/https://www.americansabroad.org/media/files/files/e547e516/Residency-Based_Taxation_ACA_Side-By-Side_Comparison_Vanilla_Approach_171101_v2_.pdf|comparison chart]] for their revised RBT proposal.
  
 ==== Independent Proposal ==== ==== Independent Proposal ====
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 Heitor David Pinto has drafted a proposal that essentially replaces citizen with resident throughout the U.S. Tax Code. This proposal can be found [[https://drive.google.com/file/d/0B7VqDyDIAgW2N2IyMkJxY1hpNTA/view|here]]. Heitor David Pinto has drafted a proposal that essentially replaces citizen with resident throughout the U.S. Tax Code. This proposal can be found [[https://drive.google.com/file/d/0B7VqDyDIAgW2N2IyMkJxY1hpNTA/view|here]].
  
 +===== Tax Cuts and Jobs Act 2017 =====
 +
 +House Republicans introduced their tax bill on 2 November 2017. On 9 Nov 2017 the House Ways and Means completed their mark-up. 
 +
 +Bloomberg has prepared a table comparing the House and Senate versions of the bill ([[http://src.bna.com/t7h|pdf]]).
 +
 +The final bill was passed by Congress on 20 December and signed into law on 22 December 2017. 
 +==== House Bill ====
 +
 +[[https://www.congress.gov/bill/115th-congress/house-bill/1|H.R.1 - Tax Cuts and Jobs Act]] was introduced by Rep Kevin Brady on 2 Nov 2017. Discussion can be found in [[http://isaacbrocksociety.ca/2017/11/02/here-is-the-2017-u-s-house-tax-cuts-and-jobs-act-bill-does-it-help-or-harm-us/|this thread]] on the Isaac Brock Society. Description by the Joint Committee on Taxation ([[https://www.jct.gov/publications.html?func=startdown&id=5031|pdf]])
 +
 +**News Articles**:
 +  * [[https://www.msn.com/en-us/news/markets/republicans-just-made-a-slew-of-changes-to-their-tax-bill/ar-AAuylfd|Republicans just made a slew of changes to their tax bill]] (Business Insider) 8 Nov 2017
 +  * [[https://www.taxconnections.com/taxblog/us-tax-reform-bill-appears-to-confiscate-12-of-retained-earnings-of-certain-canadian-controlled-private-corporations/#.WgUUxbOWZaR|US Tax Reform Bill Appears To Confiscate 12% of Retained Earnings of Certain Canadian Controlled Private Corporations]] (Tax Connections) 8 Nov 2017
 +  * [[https://www.cnbc.com/2017/11/09/gop-tax-reform-plan-advanced-by-house-ways-and-means-committee.html|House Republicans advance tax bill, aim to bring it to a vote next week]] (CNBC) 9 Nov 2017
 +
 +==== Senate Bill ====
 +
 +From the Senate Finance Committee: 
 +  * [[https://www.finance.senate.gov/chairmans-news/hatch-unveils-pro-growth-pro-jobs-pro-family-tax-overhaul-plan-|Press Release]]
 +     * Description of the Chairman's Mark of the “Tax Cuts and Jobs Act” ([[https://www.finance.senate.gov/imo/media/doc/11.9.17%20Chairman's%20Mark.pdf|pdf]])
 +
 +**News Articles**:
 +  * [[https://www.nytimes.com/2017/11/09/us/politics/facing-math-trouble-house-panel-races-to-adjust-tax-bill.html|Senate Tax Plan Diverges From House Version, Highlighting Political Pressures]] (New York Times) 9 Nov 2017
 +  * [[https://www.businessinsider.com.au/trump-gop-tax-reform-senate-bill-text-details-rate-2017-11|US Senate Republicans just unveiled their enormous tax bill]] (Business Insider) 10 Nov 2017
 +  * [[https://www.rollcall.com/news/politics/finance-committee-wont-mark-tax-bill-language-next-week|A Tax Bill in Plain English? Senate Finance Committee Is Already There]] (Roll Call) 9 Nov 2017
 +  
 ===== Efforts to Support Tax Reform in the US ===== ===== Efforts to Support Tax Reform in the US =====
  
 FIXME Here's where we should collect info on research, letter writing campaigns, etc. that support any shift away from Citizenship Based Taxation. FIXME Here's where we should collect info on research, letter writing campaigns, etc. that support any shift away from Citizenship Based Taxation.
 +
 +If you want to write to your US Senator or Congress(wo)man - https://democracy.io/ makes it easy. You will need to use a US street address - you can enter your last US residence, or use Google Maps to find a real address in the area where you (or your parents) last lived in the US.
 +
 +In January 2017, a link to [[https://docs.google.com/spreadsheets/d/1v4kBW-PiVokAJbmmQyycCjQHCP6ym6oozdtW91ZWy-M/edit#gid=1727735074|this spreadsheet]] of Congressional Assistants to members of the tax committees was [[https://www.facebook.com/groups/AmericanExpatriates/permalink/717143111785097/|posted on Facebook]] (NB: it is not clear that anyone is maintaining this spreadsheet).
 +
 +====== Tax Cuts and Jobs Act (2017) ======
 +
 +For a discussion of the provisions that affect international businesses, including local corporations owned by nonresident US citizens, see the [[wiki:contents:us_tax:cfcs|wiki page on Controlled Foreign Corporations]].
 +
 +Other impacts of TCJA were discussed in [[http://fixthetaxtreaty.org/2018/12/19/tcja-and-us-expats/|this blog post]].
 +
 +A complete list of blog posts on TCJA can be found [[http://fixthetaxtreaty.org/category/tcja/|here]].
 +
 +
 +
 +
 +
  
  
wiki/contents/us_tax/tax_reform.txt · Last modified: 2018/12/31 20:09 by karen
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