RO Tax Talk Episode 1: The Need for Pure RBT

Please join John Richardson, Jim Gosart, and Kym Kettler-Paddock as we talk about every overseas American’s least favorite thing: citizenship-based taxation.

Hint: we want to get rid of it! Bring on pure Residence Based Taxation.

Join us each week for a snippet of RO Tax Talk.

Pure RBT is the only real solution for Overseas Americans

Republicans Overseas stands for the full repeal of Citizenship Based Taxation and for the implementation of pure Residence Based Taxation.  See below for a summary of our position.

Republicans Overseas has asked for an Executive Order to alleviate tax & regulatory burdens

Republicans Overseas has sent a letter to White House Chief of Staff Mark Meadows, urging him to ask President Trump for Executive Orders that would:

  1. Exempt small businesses from the GILTI and Transition Taxes;
  2. Create a Commission on Overseas Americans to consider remedies for the harms done to Americans abroad via onerous regulations such as FATCA;
  3. End citizenship-based taxation by instructing Treasury to redefine “individual” in Section 1 of the 1913 Tax Code to ‘resident of the USA

We hope that President Trump will consider extending tax and regulatory cuts to overseas Americans.



Congressman Holding to discuss TTFI in London on April 24, 2019

By Helen Burggraf

Republican Representative George Holding will discuss his recently-proposed Tax Fairness for Americans Abroad legislation in April, in a public forum for American expats in London that the organizers say they are hoping will build the solid cross-party consensus that Holding’s bill will need to be approved by Congress. 

The event, which will also include Republicans Overseas vice chairman and chief executive Solomon Yue, and Toronto-based lawyer and citizenship expert John Richardson, is expected to take place at a venue in Mayfair on April 24, from 6 to 7:30pm, a spokesperson for the Republican party told the American Expat Financial News Journal.George Holding cropped

Yue will also speak on “territorial taxation for individuals” (TTFI) in Athens during the week of May 6, again accompanied by Richardson, at a venue and time to be announced.

Read the full article here. 

Full text of Tax Fairness For Americans Abroad Act of 2018

Please find the official bill here.

French Senator for French Abroad will support TFFAAA

My friend Damien Regnard, French Senator representing French Abroad will not only support the Tax Fairness For Americans Abroad of 2018 (H.R. 7358), but also lobby members of U.S. Congress from both sides of the aisle next week to make TTFI a reality for his dual citizens and Accidental Americans. I forwarded a copy of H.R. 7358 to him this morning.

Republicans Overseas France Chairman Marc Porter (left), Republicans Overseas Vice Chairman and CEO Solomon Yue (middle), French Senator Damien Regnard (right) at the French Senate chamber on Sept. 21, 2018.

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.