https://wiki.fixthetaxtreaty.org/doku/ 2026-05-02T19:06:16+00:00 https://wiki.fixthetaxtreaty.org/doku/ https://wiki.fixthetaxtreaty.org/doku/lib/exe/fetch.php?media=wiki:dokuwiki.svg text/html 2025-05-09T06:28:17+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:au_specific&rev=1746772097&do=diff Income Not Taxed in Australia !FIXME This page lists items either not taxed in Australia or taxed concessionally that will be taxed on a US tax return. Gain on Sale of Residence !FIXME Centrelink Payments !FIXME text/html 2025-05-09T06:25:29+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:cbt&rev=1746771929&do=diff The problems with Citizenship Based Taxation are covered throughout this wiki. Under US tax law, US citizens and green card holders are US tax residents regardless of where they actually live. This creates a situation where US tax-residents who physically reside outside the US are treated as tax-resident by two (or more) countries simultaneously and must navigate both sets of tax rules simultaneously. text/html 2025-05-09T06:27:34+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:cfcs&rev=1746772054&do=diff This page describes US Tax rules that apply to Controlled Foreign Corporations (CFCs) Definition of CFC Controlled Foreign Corporation (CFC): If more than 50% of a foreign corporation is owned by US Shareholders (as defined below), that foreign corporation is a CFC, which triggers not only increased disclosure on Form 5471, but also potential liability to the US Shareholder for US tax on undistributed income of the CFC. text/html 2025-05-09T06:25:58+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:enforcement&rev=1746771958&do=diff Enforcement of CBT One of the main fears of US expats learning about US taxation of nonresident citizens is that the IRS will drain their local bank accounts and force them to pay bankrupting penalties for failure to comply. The purpose of this page is to gather evidence on the reality of IRS enforcement. text/html 2025-05-09T06:30:11+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:exit_tax&rev=1746772211&do=diff Exit Tax “For some, there is even an IRS tax on your exit. You pay tax on all your income every year. The Exit Tax is like an estate tax on the gain in your assets, even though you are not actually selling anything. It is the IRS’s last chance to tax you. text/html 2025-05-09T06:29:19+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:other&rev=1746772159&do=diff Foreign Pensions Foreign Pensions: This is a letter written in January 2018 by the American Bar Association explaining the US tax problems associated with non-US pensions. It includes analysis of section 402(b) and the current model US tax treaty. text/html 2025-05-09T06:26:36+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:pfics&rev=1746771996&do=diff Passive Foreign Investment Companies (PFICs) FIXME - much more is needed here. Just wanted to make sure these links were available. Form 8621 US-domiciled ETFs are traded on the ASX. See List of Australian exchange-traded funds and sort by domicile. text/html 2025-05-09T06:28:44+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:renunciation&rev=1746772124&do=diff Renunciation There are two separate processes to follow. First one must renounce or relinquish US citizenship - which gives up the right to live, work and vote in the US as well as the right to a US passport. This process is governed by US nationality law. Then there is the process of exiting the US tax system text/html 2025-05-09T06:32:42+00:00 Anonymous (anonymous@undisclosed.example.com) https://wiki.fixthetaxtreaty.org/doku/doku.php?id=wiki:contents:us_tax:tax_reform&rev=1746772362&do=diff 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 HR7358 was introduced by Rep. George Holding (R-NC) on 20 December 2018. See the