Breaking: Congressman Holding scrapes through with ‘Tax Fairness For Americans Abroad Act’

John Richardson (tax lawyer), Olivier Wagner (tax specialist), Solomon Yue (CEO & Founder Republicans Overseas), and Jim Gosart (Republicans Overseas) discuss Congressman Holding’s introduction of ‘Tax Fairness For Americans Abroad Act’. 

by Helen Burggraf

With just hours to go before most of the United States was due to close down for the Christmas holiday, Congressman George Holding today at last delivered a long-anticipated bill aimed at addressing the enormous problems many Americans living abroad have been having that are a result, most agree, of the fact that they are taxed on the basis of their citizenship rather than jurisdiction of residence.

Among the central features of Holding’s bill is an option for American citizens who are living abroad to elect to be taxed on the basis of their residency, rather than their citizenship.

Read the full article here.

The End of the Beginning: Solomon Yue and John Richardson discuss TFFAAA

Watch as Solomon Yue (founder and CEO Republicans Overseas) and John Richardson (international tax lawyer) discuss Congressman George Holding’s ‘Tax Fairness For Americans Abroad Act – H.R. 7358″.

 

TTFI bill is introduced by Congressman Holding

Today, December 20, 2018, Congressman George Holding (NC-R) introduced the Tax Fairness For Americans Abroad Act (TFFAAA) – H.R. 7358.

The TFFAAA will not only end the double taxation of overseas Americans, it will also make Americans more competitive in the international job market and free to pursue opportunities around the world.

The TFFAAA will amend the Internal Revenue Code by offering overseas Americans a status similar to that enjoyed by corporations where foreign-sourced income is taxed in the country where it is earned.

The bill can be summarized as follows:

  • Overseas American citizens can elect to become a qualified nonresident citizen under this bill or elect to remain taxed under the existing CBT.
  • Under this bill, a nonresident citizen is defined as an individual that:
    •  Is a citizen of the United States,
    •  Has a tax home in a foreign country,
    •  Is in full compliance with U.S. income tax laws for the previous 3 years, and
    •  Either:
      • a)    Establishes that he has been a bona fide resident of a foreign country or countries for an uninterrupted period which includes an entire taxable year, or
      • b)    Is present in a foreign country or countries during at least 330 full days during such taxable year.
  • Citizens moving overseas in a ‘split year’ can still make use of the Foreign Earned Income Exemption (‘FEIE’) to cover income earned abroad during the split tax year.
  • Once a citizen has elected nonresident citizen status, the US government will no longer tax that citizen’s foreign earned income or foreign unearned income.
  • All income earned by a nonresident citizen within the United States will continue to be taxed under existing laws.
  • While individuals will not be taxed on gain from the sale of foreign personal property attributable to their time as a qualified nonresident citizen, they will still be taxed on any gain attributable to their time as a resident of the U.S. In other words, if an individual holds a foreign asset prior to their election of qualified nonresident citizen status and then sells said asset while they are a qualified nonresident citizen, the individual will only owe U.S. tax on the portion of gain attributable to the period prior to their change in status.

Republicans Overseas is working with Congressman Holding’s legislative staff and Grover Norquist (President of Americans For Tax Reform) to develop a plan for getting the bill passed in Congress in 2019.

Click here to read the bill in its entirety.

Click here for a one-page description of the bill. 

Solomon Yue writes about TTFI in AARO News October 2018

Solomon Yue, CEO and VP of Republicans Overseas, discusses how Republicans Overseas has been working towards  Territorial Taxation For Individuals. Click here for the PDF version.

Territorial Taxation for Individuals Meeting in Italy

 

Vice Chairman and CEO of Republicans Overseas Solomon Yue (Left), Chairman of Republicans Overseas Italy Dr. Nancy Galan (Middle), and Vice President of AmCham Italy Luca Arnaboldi (Right) joined by the American Chamber of Commerce Italy Executive Committee members for a lunch meeting in Rome to discuss Congressman Holding’s TTFI legislation. AmCham Italy liked and agreed to support the legislation. Now we have a 4 of 4 winning record from this 5-city TTFI European tour and expect AmCham UK, France, Germany, & Italy all 2 endorse it.

Bipartisan TTFI event in Frankfrut, Germany

Thanks to Kerry Reddington for organizing this bipartisan TTFI event jointly hosted by American Chamber of Commerce Germany, Republican Overseas Germany, and Democrats Abroad Germany on September 24. The TTFI legislation passage requires all of us to work together regardless of  party affiliation and political spectrum.

 

Territorial Taxation for Individuals meeting in Paris, France

On September 21st Joe Smallhoover, board member of the American Chamber of Commerce France and Chair of Democrats Abroad France (DAF), and Solomon Yue, founder of Republicans Overseas (RO), presented the draft bill on territorial taxation for individuals (TTFI) at the American Chamber of Commerce France in Paris.This bill will be presented to Congress this fall, before the end of this session.

Yue began the presentation by saying how much territorial taxation for individuals (TTFI) — also known as residence-based taxation (RBT) — is an American issue, not a Republican, Democrat or Independent issue.

Read more here. 

John Richardson interviews Solomon Yue on TTFI