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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
@@ Line 1: / Line 1: @@
 ====== US Tax Reform ======
 ===== 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.
+==== 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 ====
@@ Line 17: / Line 22: @@
-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 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 ====
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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]].
+===== 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 =====
 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]].