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Tax Residency in a FATCA and CRS World
by William H. Byrnes IV and Robert J. Munro *
Contributing Author: John Richardson, LL.B., J.D., CitizenshipSolutions.ca. Rewritten by William Byrnes with additional material included. lexisnexis.com/legalnewsroom…
Tax Residency retweeted
Replying to @nigeljgreen @CitizenshipTax
First they would create an exit or "settling up" tax triggered by severing @taxresidency; and
Second, they would switch to @CitizenshipTax.
They would emulate the USA.
Tax Residency retweeted
Reminder to all with @TaxResidency in Canada. The CDN Form T1135 combines features of both US #FBAR and Form 8938.
New disclosure program to fix:
citizenshipsolutions.ca/2025…
Canadians who fail to report foreign assets to the CRA risk audits, penalties theglobeandmail.com/investin…
My answer to Do Digital Nomads pay their taxes in their home country or in the host country? digitalnomadtips.quora.com/D…
Tax Residency retweeted
The next step will be for New York, CA and other high tax states to impose #Exittaxes if people move: "Tax collectors chase rich New Yorkers moving to low-tax states. Auditors inspect cell records, ev..." uk.finance.yahoo.com/news/ta… via @YahooFinanceUK
Tax Residency retweeted
The three groups (in terms of economic status) leaving California are: 1. Lower class 2. Middle class and 3. Higher class "Californians fed up with housing costs and taxes are fleeing state in big numbers" cnb.cx/2GL9LgI
Tax Residency retweeted
Both California and the USA define @taxresidency so that ALL people are presumptive tax residents. It's up to to the individual you prove that he is not.People should leave California before the state joins the USA in imposing S. 877A type exit taxes. forbes.com/sites/robertwood/…
Tax Residency retweeted
The USA must stop imposing #worldwide taxation (@citizenshiptax) on people have @taxresidency in other countries who don't live in the USA #BECAUSEITSWRONG! youtube.com/watch?v=qa5jeq3h…
Tax Residency retweeted
Numerous answers - none of which focuses on the reality of having @taxresidency in the USA and the possible Exit Taxes imposed on those who try to leave: Question on @Quora: Is getting a US Green Card worth the hassle and cost? quora.com/Is-getting-a-US-Gr…
Tax Residency retweeted
It's unlikely that @TaxJusticeNet will care in the least about US @CitizenshipTax - they are concerned only with those with @taxresidency not paying their #fairshare to their country of tax residence. It would be interesting to know what they think about US refusal to join #CRS.
Replying to @ExpatriationLaw @DavidCayJ
Hopefully @TaxJusticeNet & @OECD will include US's unique, immoral non-resident tax theft from other nations' economies when attempting to level the playing field.
#CRS is based on residency, US cannot be allowed exceptional status. They should be blacklisted on this alone.
Tax Residency retweeted
Replying to @TaxResidency
For expats in China? Individuals who are resident in China for 183 days or more a year are now considered tax residents, and are therefore subject to tax on their global income. This replaces the previous rule that only subjected f…lnkd.in/gW-Ht53 lnkd.in/g-T2nGP
Tax Residency in China under New IIT Law: Impact on Foreigners china-briefing.com/news/tax-…
U.S. Tax Residency: Some Black-and-White Rules, Some Gray cpajournal.com/2018/03/27/u-…
Understanding the Common Reporting Standard from the CBA: cba.ca/understanding-the-com…
No exchange of information with the USA because the USA has not signed the OECD Common Reporting Standard: "Common Reporting Standard - ITA Part XIX" - Canada.ca canada.ca/en/revenue-agency/…
"In light of the Wayfair decision, a question may be raised as to whether a state may now try to impose state corporate income taxes as well. Many states have introduced, in addition to the current physical nexus standard, an economic nexus standard." cadesky.tax/us-18-14/
We see that in the USA @taxresidency for income tax purposes is different than for Gift and Estate tax purposes - "Foreign Investment Into The U.S. Part II: Who Is A U.S. Person" taxconnections.com/taxblog/f… via @taxconnections
Offshore tax measures behind UK evasion spike international-adviser.com/of…
About #domicile
4. It is not easy to change domicile. More than an intention to change domicile is required.
About #domicile:
5. In determining whether a person is domiciled in a place the court looks to a number of factors which include:








