US Croatia Proposed Tax Treaty Gives The US Taxing Rights Over Renounced US Citizens

<p>December 18, 2022 - Participants include:</p> <p>Tim Smyth - <a href='https://www.twitter.com/tpsmyth01'>@Tpsmyth01</a></p> <p>John Richardson - <a href='https://www.twitter.com/expatriationlaw'>@Expatriationlaw</a></p> <p> </p> <p>This spells trouble!!</p> <p> </p> <p>_______________________________________________</p> <p>The text of the treaty document can be found at:<a href='https://home.treasury.gov/system/files/131/Treaty-Croatia-12-7-2022.pdf'> https://home.treasury.gov/system/files/131/Treaty-Croatia-12-7-2022.pdf</a></p> <p><a href='http://citizenshipsolutions.ca/wp-content/uploads/2022/12/Treaty-Croatia-12-7-2022.pdf'>Treaty-Croatia-12-7-2022</a></p> <p>Of particular note in Treasury’s announcement is:</p> <p>“The Treasury Department is pleased to conclude this new tax treaty with Croatia. It is the first comprehensive tax treaty that the United States has signed in over ten years and reflects our current tax treaty policies and is a milestone in the Treasury’s efforts to expand the U.S. tax treaty network. We appreciate the collaboration Croatia showed throughout the negotiations,” said Lily Batchelder, Assistant Secretary (Tax Policy).</p> <p>The new tax treaty closely follows the <a href='https://home.treasury.gov/system/files/131/Treaty-US-Model-2016_1.pdf'>U.S. Model income tax treaty</a>.</p> <p>Treasury’s announcement focuses on the mutually beneficial aspects of the US Croatia tax treaty. Notably Treasury’s announcement fails to comment on the inclusion of the enhanced “<a href='http://citizenshipsolutions.ca/2016/05/26/savings-clause-in-us-tax-treaties-guarantees-us-right-of-taxation-on-residents-and-citizens-of-other-nations/'>saving clause</a>” which is identical to the following provisions in the US Croatia tax treaty.</p> <p>4. Except to the extent provided in paragraph 5 of this Article, this Convention shall not affect the taxation by a Contracting State of its residents (as determined under Article 4 (Resident)) and its citizens. Notwithstanding the other provisions of this Conve