Nick Lee

@JCDoubleTaxed @ExpatriationLaw @DoubleTaxation @USCitizenAbroad @CitizenshipTax Presumably the 1yr carry back / 10yr carry forward would cause it to match up to your eventual capital gains when you sell. There’s no realistic way to avoid significant selling to cover taxes, which some of the critics claim to be an ECHR violation.

@ExpatriationLaw @NicklesLee @DoubleTaxation @USCitizenAbroad @CitizenshipTax How is the U.S. Double Taxation supposed to work? Extra tax/compliance on selling to help fund payment of the N.L. wealth tax? If it were in California that would definitely be double taxation w/o credit available with most all other countries. x.com/ExpatriationLa…

This tax on “fake income” will absolutely create more @doubletaxation on @USCitizenabroad in NL! This is the result of US @citizenshiptax. But some will stupidly blame #doubletaxation on the NL tax policy (which is seriously stupid in its own right).

@ExpatriationLaw @DoubleTaxation @USCitizenAbroad @CitizenshipTax @grok explain how Savings BVs sidestep the problems with the new “paper gains” tax in Box 3

@ExpatriationLaw @DoubleTaxation @USCitizenAbroad @CitizenshipTax Box 3 (investments & savings) is taxed to hell under the new rules. Personal Box 2 (dividends/distributions from a company you own more than 5% of) & corporate taxes remain favorable. The people passing this tax know them & their donors don’t need to pay it.

@ParvizMalakouti They can’t fathom a world in which their jurisdiction has limits. It’s like the (laughable) Dutch register of unwanted nationalities, intended as an alternative to renunciation for nationalities that don’t permit that.

How does the bill purport to enforce renunciation of an American's foreign citizenship? By submission of a written renunciation of such foreign citizenship to the U.S. Secretary of State. 😂 Which of course has no legal effect in a foreign country, absent that foreign country's legislation giving it legal effect. Strangely, there appears to be no mention in draft of the bill of a requirement for the American dual citizen to submit a citizenship relinquishment request with the foreign country - the entity that's actually competent to deprive the foreign citizenship. So the bill looks like some kind of obedience-loyalty test for American citizens. "Give us, a gaggle of American politicians, a letter, otherwise toothless, saying you only love me and will never kiss anyone else." Either that or the person who drafted the bill is as confused about how dual citizenship works as the Senator who conceived it. 🤔

@IRS_MEDIC @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul @RandPaul @RepLaHood Yes. I’m aware some people don’t like the opt-in nature of its RBT, but it allows for severing tax residency & there are some Americans abroad that would vocally object to it being automatic.

@NicklesLee @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul @RandPaul @RepLaHood Did you read the bill?

The Large, Stupid and Ugly Bill & Trump's Policy of Strategic Uncertainty I was very excited to be at least a small part of Donald Trump's campaign pledge to end double taxation for Americans Abroad. However, not only does the Large Stupid and Ugly Bill not offer any relief, but Donald Trump is now actively fighting a court decision that allowed to Americans to offset their NIIT taxes with their foreign tax credits, in order to avoid double taxation. The bait & switch is truly breathtaking and unfortunately, the cult of personality blinds too many from seeing the very clear application of tyranny with dishonesty. I ask those who are still supporting Trump on his tax policy, is there anything he can to do to lose your trust in him? Do you have a red line of what campaign promise he can't break? Or is everything he does or doesn't do automatic proof of his awesomeness? Is this all about "trusting the plan?" Is his strategic uncertainty a good thing? Do you like being confused, being unable to defend his policies as you yourself can't understand them?

@IRS_MEDIC @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul @RandPaul @RepLaHood Hate the game, not the players. We’re all entitled to think scoring is stupid & the root of many problems in America, but it’s the rule that legislation dies by. I’d rather play stupid games & give this a chance of passage than die on the wrong hill.

Pretending this is a legitimate political process could be a deeper part of the problem. No one is expected to read or understand what they sign into law. WTF. This process is the worst of both worlds. The government gets to claim a color of legitimacy, whereas on a very basic level, it quite easy to see there is no representation. But there is taxation.

@IRS_MEDIC @palladium12345 @TaxFairUSAbroad @SolomonYue @SenRandPaul “You catch more flies with honey” holds true here. We need leads on both the House & Senate sides in order for this bill to move, so @RandPaul alongside @RepLaHood is far better than “in place of”. There are also legitimate reasons why the bill hasn’t been reintroduced yet.

@palladium12345 @TaxFairUSAbroad @SolomonYue LaHood seems to be a phony. EY is his top donor. His job could have been to suck the life out of the movement. Well played I got to say. I suggest @SenRandPaul is our best chance - he fully knows what FATCA is.

@ExpatriationLaw @ACAVoice It’s refreshing to be getting a terse summary of the bill/statutory text that’s identifying why overseas Americans are likely *not* directly in scope. Always a risk that the implementing regs are flawed, but that’s a bridge to cross when the time comes.

This commentary from @ACAVoice about the new remittance tax is worth the read.

@adrianpandev @ExoloringPhil Guy in the photo—the LaHood RBT bill was one of the major topics of conversation this week. Ending CBT is very much the North Star.

@ExoloringPhil I did not know this. My understanding was that they were advocating against it.

Most Americans have no idea how brutal it is to live abroad as a US citizen. 5+ million Americans overseas deal with a headache most can't imagine... While Canadian citizens who move to Spain face zero tax obligations to Canada. Americans? Still filing US returns from wherever they land. The absurdity is real: • FBAR filing for any foreign account over $10K • FATCA compliance makes opening a simple bank account a headache • Double taxation even after paying local taxes Boris Johnson sold his London flat, paid UK taxes, then IRS demanded MORE on the same gain. He called it outrageous and renounced his citizenship. The Pope must file US tax returns on his Vatican salary. The simple truth is: An American who moves abroad = tax and compliance prison for life. Millions were hoping this administration would keep its promise and eliminate these absurd requirements. So far? Radio silence... We need to keep talking about this. 5.5 million Americans abroad deserve representation. Or at least basic fairness. Taxation without representation isn't just history. It's happening right now... #Expats #TaxTwitter #ExpatTax

BTW third year in a row that a Republican office complimented us and said we were better than lobbyists!

@AttyStevenBrown @ParvizMalakouti facebook.com/share/15F4kmG9… is worth looking at. Gets into the Tjebbes ruling, constitutional law, and all the fun stuff

@NicklesLee @ParvizMalakouti Thank you so much! I’ll be sure to take at them, definitely an intriguing theory

Yet another reminder that citizenship opportunities available today will be gone tomorrow.💨

@AttyStevenBrown @ParvizMalakouti We worked with Luigi Paiano a few years back for ours. Giovanni di Ruggiero has been posting pretty publicly about some of the angles for challenge, so he might also be worth looking into.

@NicklesLee @ParvizMalakouti I need to look into it! We’re a 1948 case as it is. Was hoping for more of a clean case but might not be the case

@AttyStevenBrown @ParvizMalakouti If you’re willing to roll the dice on (comparatively low) legal fees a bit, the immigration lawyers & opposition parties think this is going to be extremely vulnerable to legal challenges. Could very well be the same as the oft-discussed “1948 cases”.

@ParvizMalakouti Yes, I think we filed the CoNE in March 2024 (right before the fee) and it took a long time. Then had to go get local documents. Hopefully, things break our way on it though.

@ParvizMalakouti @IRS_MEDIC @ExpatriationLaw You’d expect him to just tick the “more than 25 accounts” box and report absolutely nothing in the contents.

@IRS_MEDIC @ExpatriationLaw Maybe you should consider writing a short public letter to the Vatican to alert them to this issue affecting the new Pope, and all other American citizens living abroad.

Amazing issue spotted here. 👇🤣 cc: @IRS_MEDIC @ExpatriationLaw

@RichardRubinDC Those are going to be some incredible information reports

Well, the debate over US citizenship-based taxation for Americans living abroad has a fun new example for us all to think about.

@Ronald77171496 @toezicht_AP @Financien Maar los van degene wiens hoorzitting half mei is?

@NicklesLee @toezicht_AP @Financien Er heeft een zitting in Arnhem plaatsgevonden op 25maart, verwachte uitspraak 6 mei.

Eindelijk een lichtje aan de horizon voor de toeval Amerikanen! Wat gaat de 🇳🇱@toezicht_AP doen voor de 🇳🇱staatsburger? Na een schaamteloos optreden op 25 maart in de rechtbank te Arnhem! Ipv op te komen voor de bescherming van burgers zitten zijn in de broekzak van @Financien

@ParvizMalakouti There are ~106 amendments under consideration, so it’s anyone’s guess where this ends

Interesting developments for Italian citizenship by descent. 👀 “The letter advocates for mitigating amendments which among others would include allowing applicants already in process to remain eligible and extend eligibility to third-degree descendants with language requirement.”

@ParvizMalakouti @AnnaBower Yeah, the expedited discovery order had a bunch of named depositions & two “of choice”. Presumably for those, they’d want to go up the food chain instead of shaking down an intern

@NicklesLee @AnnaBower Ah, I didn't see Abrego's lawyers were limited to two depositions.

The White House—which is required to facilitate the return of Kilmar Abrego Garcia under a court order—just posted this on X.