Working offshore for a foreign company in foreign waters, pay UK taxes, and from what I can gather, I’m not eligible for the FEIE

Hi, I saw an interesting situation described over on reddit. Here it goes: The taxpayer was a bona fide resident of the United Kingdom but was working on international waters (oil field). Question: How can he avoid dual taxation: Foreign Earned Income Exclusion, Foreign Tax Credit? Cool stuff. So, as discussed in Income earned on international ...

Humor – Courtroom Quotations

These are humorous courtroom quotes that have been circulating on the Internet. But hey, a little laugh doesn’t hurt, so here they are: The following quotations are taken from official court records across the nation, showing how funny and embarrassing it is that recorders operate at all times in courts of law, so that even ...

US Estate Tax May be Payable by Canadians

All amounts in this article are in US dollars Canada-U.S. Tax Treaty Article XXIX B Taxes Imposed by Reason of Death A U.S. estate tax return must be filed if a deceased Canadian resident who is not an American citizen owned U.S.-situated assets exceeding $60,000 fair market value at death.  However, if the deceased made substantial lifetime ...

RRSP : Response to concerns regarding Revenue Procedure 2014-55 (Which obsoletes form 8891 and changes the way a treaty election for RRSPs is made)

While not everything is good news, I think that the concerns found in this comment (similar to the ones voiced by Moodys Gartner here) are not always founded.   The Rev. Proc. is a problematic for a multitude of reasons, including: 1. it substitutes a form for which there is no failure to file penalty ...

GATCA is coming to town

GATCA is coming to town
As many of you know, the United States has implemented FATCA (Foreign Account Tax Compliance Act), requiring financial institutions around the world to report the names of their depositors who are US persons (hence potentially liable to pay US tax) – or else face a 30% withholding on their US sourced income. There have been ...

200,000 Saudi US citizens liable to pay US taxes

200,000 Saudi US citizens liable to pay US taxes
As seen on Arab News More than 200,000 Saudi citizens with dual US citizenship are liable to pay taxes under US taxation laws, according to academics at King Abdulaziz University (KAU) in Jeddah. Such laws have prompted scores of people with dual nationality around the globe to give up their US citizenship. In fact, relinquishing ...

More and more Americans give up their citizenship, 2014 is on track to be a record year

More and more Americans give up their citizenship, 2014 is on track to be a record year
  A significant number of people continue to surrendered their US citizenship or terminate their “long-term US residence” (for green card holders). There are 776 names on the list that the Treasury Department released Friday for the third quarter of 2014. That’s the third highest quarterly figure ever. The total number of ascetics published to ...

Local Client Base (under FATCA) Credit Unions in Canada – an update 1

By way of background, as per the Canadian IGA, credit unions can apply to be classified as a “local client base” financial institution. In this case, the credit union would be FATCA compliant by reporting to the IRS only the names of clients who are US residents – the names of clients who are US ...

FEIE Audit questionnaires

FEIE Audit questionnaires
IRS Audit Questionnaire 1 IRS Audit Questionnaire 2

PFIC Excess Distribution regime (Section 1291 Fund) – Form 8621 line by line 1

PFIC Excess Distribution regime (Section 1291 Fund) – Form 8621 line by line
We’ve see the basics of PFIC taxation in post Passive Foreign Investment Companies (PFIC) and Canadian mutual funds, although truth being told, it applies to PFICs anywhere, now let’s dig in – Let the brain damage begin The scenario is that John Doe (SSN: 000-00-0000). He bought share of the Safe Investment Inc, a PFIC on ...