Easing US/UK immigration

I wonder if the IRS/HMRC will make taxtion simpler to facilitate US/UK immigration........

https://www.theguardian.com/politics/2017/jan/23/theresa-may-donald-trump-us-uk-immigration

There's an interesting data figure given in the article:

"The latest figures show there are 181,000 US-born citizens in Britain...."

Past data has shown 197,000 UK residents born in the US (Sept. 2010 data)-

https://www.theguardian.com/news/datablog/2011/may/26/foreign-born-uk-population

and 197,355 UK residents born in the US (2011 UK census: including NI [although article says "Britain"])-

https://en.wikipedia.org/wiki/Americans_in_the_United_Kingdom

Of course, in all cases, in addition to US born are those Americans born elsewhere plus those naturalised US citizens returning to the UK.

Data from other countries, for example Switzerland, show a decline in the number of US births in the country being registered by the US Embassy and recorded by the Swiss authorities.

If the figure in the article is accurate, I wonder why the decline in US born residents? Or can we guess? (Seems too soon for Brexit to influence the data.) The US Department of State and Congress have continually increased their estimates of US citizens abroad from roughly 4.5/6.5 million in 2012/13 to 8.5 million in 2015. Didn't FATCA come into effect for reporting in 2011?

 

You guys must be kidding.

Are you honestly thinking Trump will cancel FATCA?

Why wouldn't he?  It's part of the republican platform, I can't see how Trump would be disadvantaged by doing it. 

I'm rather hoping he will, which would make a small silver lining to the coming Trumpageddon.

You guys must be kidding.

Are you honestly thinking Trump will cancel FATCA?

Time to get out to the countryside for some of this crisp, cool air, SoS.

No one mentioned Trump.

It's more about fabricating the number of Americans abroad in order to exaggerate a 'tax gap' when indications are the number of Americans abroad are decreasing. The question was is this due to increasing complexity in US reporting? I doubt there's any way to confirm the reason.

Time to get out to the countryside for some of this crisp, cool air, SoS.

Maybe so. Getting twitchy.

Suggestion: delete the Savings clause from US-UK tax treaty. Would make things a lot easier.

Suggestion: delete the Savings clause from US-UK tax treaty. Would make things a lot easier.

As it's a standard part of all US tax treaties I don't think that will happen.

For the record: regarding elimination of Citizenship Based Taxation and replacing it with RBT or TBT, and the Same Country Exemption as regards FATCA reporting.

The ACA (American Citizens Abroad) RBT (Residence Based) proposal of December 5, 2016. The ACA press release can be found at:
https://www.americansabroad.org/news/aca-publishes-detailed-descr-of-its-rbt-proposal-and-announces-coalition-to-score-rbt-proposal/

The ACA side-by-side comparison chart can be found at:
https://www.americansabroad.org/media/files/files/ad2154e6/Residency-Based_Taxation_ACA_Proposal_Side-By-Side_Comparison_161201_Final.pdf

The full text of the ACA proposal can be found at:
https://www.americansabroad.org/media/files/files/9960ba5d/ACA_RBT_proposal_for_submission_to_Senate_Finance_April_2015.pdf

The Republicans Abroad organisation is proposing a TBT (Territorial Based) solution. The January 6, 2017 proposal can be found at:

(Click on the body of the text to enlarge; and click on the arrows that appear on top of the text to go from page to page)

On January 6, 2017, the US Treasury released to following document
"Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities"

It refuses to consider the 'Same Country Exemption' for US expats banking in their foreign country of residence as regards FATCA reporting. The ACA response can be found at:
https://www.americansabroad.org/news/treasury-department-slams-the-door-on-same-country-exemption-for-americans-abroad/

The full Treasury document can be found at:
https://www.federalregister.gov/documents/2017/01/06/2016-31601/regulations-relating-to-information-reporting-by-foreign-financial-institutions-and-withholding-on

You guys must be kidding.

Are you honestly thinking Trump will cancel FATCA?

I am not sure he CAN cancel FATCA. It must be repealed by Congress - no?

As it's a standard part of all US tax treaties I don't think that will happen.

Revoking the savings clause on a country by country basis would allow the US to ease up on CBT without making tax haven loopholes. It also has the advantage that few people would understand its significance.

Revoking the savings clause on a country by country basis would allow the US to ease up on CBT without making tax haven loopholes. It also has the advantage that few people would understand its significance.

Why would the US want to ease up on the basic principle of CBT?

Why would the US want to ease up on the basic principle of CBT?

I know it's boring reading, but the Republicans Overseas paper linked above counters the "CBT is a cash cow and repealing would be a revenue loss" argument with one that says TBT results in positive revenue. It offers a variety of reasons TBT is advantageous to the US. The ACA proposal attempts a revenue neutral position.

OK, perhaps a degree of smoke and mirrors, but the RO proposal balances income by changing the tactics for those living abroad with US source income. Anything from the US would have a flat tax withholding of 30% if it is FDAP income, which means altering any treaty that allows lower, or no rates on US sourced income. Non-resident citizens would be treated the same as non-resident aliens. (If I read all this correctly.)
https://www.irs.gov/pub/int_practice_units/WITCUP_15_1_01.PDF

There are some who are very upset about the TBT proposal.

EDIT: HuffPost article was from 2014!

Again, from a previous thread, can pigs fly? No one's holding their breath.

Why would the US want to ease up on the basic principle of CBT?

it is in the RNC platform paper published in 2016. Clearly states to change to residency-taxation and repeal FATCA and FBAR. Of course, they may (and probably will) ignore this, but Reince Priebus (the chairman of the RNC) is now the closest person to Trump.

I enjoy reading threads like this but won't have any hope of changes until I hear of an actual proposed bill being considered in Congress. Even so, well under 10% of all proposed bills actually become law.