Subpart F, GILTI and The Transition Tax - Fake Income: Americansabroad are taxed more punitively than US residents

<p>January 3, 2022 - Participants include:</p> <p>John Richardson - <a href='https://www.twitter.com/expatriationlaw'>@Expatriationlaw</a></p> <p>Jimi Gosart - Vice-President <a href='http://www.republicansoverseas.com/'>Republicans Overseas</a></p> <p>________________________________________________________</p> <p>The United States is the only major country in the world that continues to impose worldwide taxation on its citizens when they move from the country and establish tax residency in another country. But, it gets worse. When US citizens move from the USA and establish tax residency in another country they are <a href='https://www.taxconnections.com/taxblog/dual-citizens-of-the-united-states-and-other-countries-read-the-commentary/'>subjected to a separate and more punitive form of taxation that that imposed on US residents</a>.</p> <p> </p> <p>US citizens abroad are subjected to various forms of taxation on "fake income" (meaning income they have never received). One very common form of "fake income" are found in Subpart F of the Internal Revenue Code. The <a href='https://citizenshipsolutions.ca/?s=transition+tax'>Transition Tax</a> and <a href='https://citizenshipsolutions.ca/?s=GILTI'>GILTI</a> were created by the 2017 TCJA.</p> <p>In this episode Jim Gosart and John Richardson discuss "fake income" as a general principle (it doesn't apply to US residents on their US based assets). The 2017 Transition Tax and GILTI are the result.</p> <p>Our point is simple:</p> <p>The only solution is for the United States to stop citizenship-based taxation and adopt <a href='http://seatnow.org/2021/07/18/begin-with-the-end-in-mind/'>pure residence-based taxation</a>!</p> <p> </p> <p> </p>