Trump’s Proposal To End Double Taxation Of Americans Abroad Discussed By Tax Academics

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Good morning. This is John Richardson speaking with you from Toronto,
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Canada. Today, Friday, October the 11th, 2024.
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And this has been a really, really interesting week.
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President Trump announced his support for a policy of ending the double taxation
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of American citizens abroad.
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This has generated a lot of interest, in some cases, a lot of controversy,
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all kinds of blog posts, statements from organizations.
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And as we might expect, Tax Notes has jumped in with an article about this as well.
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And that's in part what we'd like to talk to you about today. I'm joined by Dr.
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Laura Snyder in Paris, France, and Dr.
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Karen Alpert in Australia. And
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we are all members of Seat Stop Extraterritorial American Taxation Now.
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Let me begin with Laura. Laura, tell me about
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this article that appeared today well it's
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called trump vows to end double taxation of
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overseas citizens by alexander refot not
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sure how to pronounce his last name it's a pretty short article it makes reference
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to a video released yesterday where trump basically is quoted as saying once
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and for all i'm going to end double taxation on our overseas citizens you've
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been wanting this for years and no one has been listening to you.
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The article then very briefly explains the situation, has some quotes from some
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people who are supportive of Trump's position.
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And then at the end of the article, you've got a quote from Professor Ruben
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Aviona at the University of Michigan Law School, who has been a long,
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well, initially he was actually one of the first people to publish an article
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describing the problems with the current system of how overseas Americans are taxed.
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But he's done a complete 180 on that.
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And his most recent publications, he's quite supportive of the current system.
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And he's quoted in this article. He says that,
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well, he's described as believing that concerns over double taxation are exaggerated
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and makes reference to the income exclusion limit and tax credits,
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and that many citizens live in countries that have a tax treaty with the U.S.,
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and that those treaties often provide tiebreakers to ensure there isn't double income taxation.
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He said the double taxation argument is spurious. That's the word he uses.
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There are many more cases where Americans living overseas enjoy double non-taxation
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because of sections 9-1-1 or 9-3-3 than cases of double taxation.
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So that's what we've got here.
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What does the word spurious mean?
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Well, I haven't looked it up lately, but I basically think it means not.
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It's wrong, basically. Yeah, roughly irrelevant. Okay, yeah.
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Okay, something like that.
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So in other words, Professor Avion, number one, he supports the principle of
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citizenship taxation, which means by definition that he supports the principle
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of the United States imposing worldwide taxation on people,
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one, who do not live in the United States, and two with respect to income not
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sourced in the United States. So to be clear, that's his position, correct?
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Yep. Okay. All right. Now that's interesting because, I mean,
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that makes it sound an awful lot more graphic, you know, than just somehow he
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supports citizenship taxation.
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Okay. So you're making two points here, right?
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The first is he's saying, I think he's saying,
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well, there really isn't double taxation too much or something like that,
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right and the second thing he's basically
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saying this is not really a problem that's how i'm understanding it
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i see so towards his view he says the problems are
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exaggerated okay so so it's not a problem uh for the united states to be imposing
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its tax code on people who actually live in other countries on income they earn
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in those other countries have i got this right is this what this guy is saying
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yes um but he in another article i don't have it in front of me but In another article,
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he goes even further, and he says if you did change it,
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it would cause a problem in the United States with social cohesion,
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which he's written about in his own articles also.
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Well, I have a lot of opinions on what we're talking about. We'll get to that, I guess.
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Okay. All right. so then he
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makes the argument he says that in any case leaving aside
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all that sort of stuff you know the
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united states has tax treaties with a number of countries and these tax treaties
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have what's called a treaty tie break so that these american citizens are taxed
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as though they don't live in the united states is that right but the tax treaties
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have two two things that avoid double taxation.
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First, they've got the savings clause, which for anyone who's not a U.S.
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Citizen, allows you to say, hey, look, if country A and country B both want
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to claim you as residents, we're going to figure out who you're closer to,
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and we're going to award you as a resident to that country, and you will not
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be treated as a resident of the other country.
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That's the treaty tie-break provision, not the saving clause,
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the treaty tie-break, right?
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That's the 3D tiebreak. Yeah, that's the 3D tiebreak position. So they've got that.
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And they've also got a... Generally, they've got a more general thing...
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Paragraph that says that the purpose of the treaty is to avoid double taxation,
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whatever that means, and that the two countries will adjudicate when there's double taxation.
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But usually the word tiebreaker is about the residence tiebreak provision,
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not the double taxation provision.
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Absolutely. So what I'm going to do here is I want to actually,
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I think I should pull up the U.S.
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Model tax treaty as an example of these things.
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But the point is that the first thing it does is it says when people are tax
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residents of more than one country.
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So, I mean, what in the world does that mean? Well, you know,
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part of the problem with the U.S.
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Citizenship taxation is it means that a U.S. citizen is always a tax resident
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of the United States, even if they leave the United States. I mean,
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so, you know, his claim that somehow double taxation is spurious is absolutely
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ridiculous because U.S.
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Citizens, by definition, if they leave the United States, are subject to double taxation, okay?
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But when you have somebody who's a tax resident of more than one country,
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say the United States and Canada, Canada and U.S.
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Because you're a U.S. citizen, Canada because you live in Canada.
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Basically, treaties have provisions that say, well, in the case of dual tax residency,
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we're going to have some rules that assign residency to one country or the other.
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So you're not a dual tax resident, right?
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Yeah, right. And then there's a savings cost that says, oops, if you're a U.S.
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Citizen, you can't use any of the rest of the treaty unless it's listed here.
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And it never lists that particular tiebreak.
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Right. That's exactly right. So in other words, the treaty says, you know what?
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All this is well and good, but if we're dealing with a U.S. citizen,
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none of the treaty applies unless it specifically is stated to apply, and U.S.
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Citizens are not, in fact, not allowed to use a treaty tie-break provision to
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not be treated as U.S. citizens, right?
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Right. Okay. Yeah, they're always dual-tax residents.
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Yeah, I mean, that's right. So as per the treaties, right, U.S.
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Citizens are always dual-tax residents if they're a tax resident of the other country as well.
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So then the issue is, is there actually double taxation, even if you're a dual tax resident?
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And I think this whole focus on double taxation is difficult because you've
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got two countries with two completely different tax codes that define income differently.
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Where they define income the same, the treaty will generally allow one country
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or the other to tax and will allow credit.
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A foreign tax credit to the other. But the real problem is where they define things differently.
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And one place where they almost always define things differently is tax-deferred retirement accounts.
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Because every country's tax code has its own separate, unique provisions for
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retirement savings, right?
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Right. And you're in Australia. Maybe you can comment on that issue a little
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bit in the Australian context?
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Well, so Australia's got superannuation, which is a separate retirement account
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that your employer is required to contribute money to, required by Australian
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law. You can't get out of it.
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And under Australian rules, those contributions that your employer make are
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not your income. They go into your superannuation fund and your superannuation
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fund actually pays tax on that as it goes in.
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But the u.s says well it's going into
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so so the australian rules work for
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australia then because you're a
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u.s tax resident as well you have to look at this through
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a u.s tax lens which doesn't recognize superannuation
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as being anything other than an account in your name therefore your wealth is
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increased when the contribution has been made therefore you have income okay
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so that that's a That's an example of a definitional issue that would lead to double taxation.
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Karen, we've talked about this over the years. There are also timing differences.
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Would you care to comment in the context of, say, GILTI or the transition tax?
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Right. There are timing problems when, say, one country decides that you're
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going to recognize a gain that hasn't actually been realized, phantom gains.
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Things like the transition tax that was in tax reform act where they.
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Basically made controlled foreign corporations recognize all of their previously
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deferred income all at once, one lump sum.
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And that was a tax event in the US, but it wasn't a tax event where you live.
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So you've got all this huge capital gain in the US, the transition tax gain,
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or a capital gain when you do an exit tax.
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All these things are capital gains that happen because the U.S.
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Tax code creates a gain on a particular kind of transaction that the foreign
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tax code is not going to have a gain because there's no realization event.
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You'll have something similar in Australia if you gift property,
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because gifting property is a disposition event for capital gains.
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Right. And I don't believe there's a provision in the U.S.-Australian Tax Treaty
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that deals with that situation.
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So in other words, this is real, okay? It's not a figment of somebody's imagination.
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And for people who've been hurt by this, the pain has been considerable.
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The carnage has been considerable.
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So, you know, these claims that, you know, somehow double taxation is not an
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issue or would you agree with me if I were to say they're completely wrong?
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Yeah. Okay. So, you know, back to this whole saving clause thing. I'm going to read you.
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This is, you know, there are different saving clauses, all right,
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you know, in different treaties. But here's the one in Canada.
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And here's what this says. Except as provided in paragraph three,
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nothing in the convention shall be construed as preventing a contracting state
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from taxing its residents as determined under Article IV residence.
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So, in other words, you can use the tiebreak provision to not be a U.S.
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Resident. And in the case of the United States, it's citizens.
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And in the case of the United States, it's citizens. So what this specifically says is that U.S.
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Citizens are not able to use a treaty tie break to not be treated,
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to avoid being treated as a U.S. tax resident, correct?
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Correct. So, I mean, this claim about, and I've seen this before in a recent
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article by him, this claim that, you know, somehow treaty tie break provisions are available to U.S.
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Citizens is, you know, is flat out wrong as a categorical statement, at least, right?
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Right. If that's what he meant by tiebreak. And that's what most people mean
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by when they talk about tiebreak. Well, Laura, can you read the paragraph there?
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Because, you know, this is not the only time I've seen this.
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Can you read the paragraph where he talks about the tiebreak provision?
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Yeah, there's two short ones. Okay.
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Aviuna believes concerns over double taxation are exaggerated,
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noting that in addition to the income exclusion limit and tax credit, many U.S.
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Citizens live in countries that have a tax treaty with the United States,
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and those treaties often provide, quote, tiebreakers, end quote,
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to ensure there isn't double income taxation.
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Then he says, quote, thus the double taxation argument is spurious.
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There are many more cases where Americans living overseas enjoy double non-taxation
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because of sections 9-1-1 or 9-3-3 than cases of double taxation, end quote.
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Well, I mean, there's a lot packed into that, okay, you know,
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obviously, so it's hard to know where to begin.
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But very, very clearly, the part of that that says that the treaty tiebreak
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is being used to avoid double taxation is a completely false statement.
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It's always false with respect to U.S. citizens because the treaty tiebreak doesn't apply, right?
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Right. Yeah. So, I mean, you know, I think this is a problem.
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And we see this, I think, you know, coming out of the, you know,
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the academic world in general.
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The Wall Street Journal ran an article about the Trump announcement.
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It was quoting Professor Kirsch, you know, where he goes back to his talking
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about, well, citizenship taxation is somehow OK because, you know,
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American citizens abroad are somehow part of the American community or something.
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Oh, wait, I made a mistake earlier. I attributed that to Aviona,
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but that's right. It was Kirsch who said that.
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That's right. that particular part of
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it was curse yeah that particular part but but talking
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about the treaty tie break okay yeah
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that's that's i think all abiona i think that i think that this is this sufficiently
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invites obscuring the issue to an extent where i think and i think that a letter
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to the editor ought to be written to tax notes about this what do you think
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well we can get it together.
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I'd like to make a couple comments, John.
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Aviona is held out as an expert on these issues, both by tax notes and by himself.
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The information, what you and Karen have just discussed, there's nothing new.
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The two of you have discussed that on countless podcasts. It's been written
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about in countless articles.
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Aviona seems impervious to this information. It's as if It doesn't exist or
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he doesn't know about it.
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But then how can you be an expert and how can people refer to you and quote
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you as an expert if you are unwilling to take into account what exists out there
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that is contradictory to what you're saying?
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That that's you're not
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an expert in that case and i'd also like to note that the three of us have written
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numerous articles on the problems that overseas americans face with respect
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to taxation many of them have been published in tax notes but we are not consulted
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no one asks us about this type of thing it's as if we don't exist.
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And going back to Aviona, he, it's as if,
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again, he either doesn't know about or doesn't care,
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both are problems, about the many, many, many people who are constantly complaining
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that they do have what you can throw under a very wide, and I agree,
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not a very good term, double taxation.
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But people are always looking for ways to, you know, speak quickly.
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And they're renouncing their citizenship. and he's
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just just doesn't give a damn about them
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it's as if they either are wrong or not
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really experiencing the problems they say they're experiencing or he doesn't
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care he's never lived well he's he clearly doesn't live outside the united states
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now i would question whether he's lived outside the united states for an extended
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period of time to the point where it he has,
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add the opportunity to experience these problems himself.
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And yet he's constantly turned to as an expert on these issues.
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It's clear he knows nothing.
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Well, tell me what you really think about him.
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You know, yeah, I mean, this is a very, very clear problem.
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Somehow, every time I read something that he writes, it was Will Rogers who
00:17:22.665 --> 00:17:25.545
said, it's not what he doesn't know that's the problem.
00:17:25.665 --> 00:17:28.765
It's what he knows that isn't true. Was that a Will Rogers quote?
00:17:29.725 --> 00:17:34.085
Could be. Yeah, but anyway, whoever, you know, wherever the quote came from,
00:17:34.205 --> 00:17:35.965
I mean, this is a big part of the problem.
00:17:36.225 --> 00:17:40.785
And, you know, first of all, I mean, I wouldn't exaggerate.
00:17:40.905 --> 00:17:44.285
I mean, you know, Tax Notes has published our articles, et cetera.
00:17:44.425 --> 00:17:50.405
But I do think that the presumptive deference to him is, you know,
00:17:50.505 --> 00:17:53.005
ridiculous and kind of a bad idea on this.
00:17:53.225 --> 00:17:56.385
I think it's exactly where you say, well, he hasn't lived out of the country.
00:17:56.525 --> 00:18:00.645
That is likely true. But I think, you know, an even bigger problem is that he
00:18:00.645 --> 00:18:02.885
lives, you know, sort of in the academic community.
00:18:03.725 --> 00:18:09.005
I mean, if he were actually doing tax work, you know, at some major law firm
00:18:09.005 --> 00:18:12.245
or something, I mean, he realized that these statements he's making are, you know.
00:18:13.715 --> 00:18:18.095
Maybe. I mean, maybe it certainly put them in a better position to understand it.
00:18:18.875 --> 00:18:23.115
Yeah, sure. But it's interesting to me that, again,
00:18:23.655 --> 00:18:27.235
you know, the problem is not defined in the sense that, again,
00:18:27.375 --> 00:18:30.735
if you really talk about what's going on here, this is the United States trying
00:18:30.735 --> 00:18:34.415
to impose this tax code on people who don't live in the United States on income
00:18:34.415 --> 00:18:36.155
that's unrelated to the United States.
00:18:36.435 --> 00:18:40.315
I mean, that's what we're talking about here, right? We're not talking about
00:18:40.315 --> 00:18:43.515
some abstract concept here, right?
00:18:43.715 --> 00:18:48.875
But anyway so this has been great thanks for this conversation uh karen any
00:18:48.875 --> 00:18:54.395
closing thoughts on this are you supportive of laura's view of uh the state
00:18:54.395 --> 00:18:56.735
of the state of commentary on this issue,
00:18:57.395 --> 00:19:00.475
i i think yeah they need
00:19:00.475 --> 00:19:04.315
to be talking to people who've actually experienced it
00:19:04.315 --> 00:19:10.135
and and they're not because the people in the ivory tower haven't all of the
00:19:10.135 --> 00:19:16.095
people quoted in this article live in the united states yeah well that that
00:19:16.095 --> 00:19:20.135
is interesting that's what you expect it wasn't ruth mason professor ruth mason
00:19:20.135 --> 00:19:24.255
was when she was quoted wasn't she appeared supportive.
00:19:26.295 --> 00:19:29.035
She's supportive of changes she's been critical of
00:19:29.035 --> 00:19:32.795
the current system and she's been supportive of changes she wrote an article
00:19:32.795 --> 00:19:37.375
i can't remember the title i've been a few years now since she wrote that article
00:19:37.375 --> 00:19:42.975
but again she hasn't written in this area for quite some time there are many
00:19:42.975 --> 00:19:48.815
people who are constantly writing about that this including the three of us that are just ignored,
00:19:49.375 --> 00:19:53.835
well actually the three of us yes but i i think laura you're deserving of a
00:19:53.835 --> 00:19:57.575
very special shot here okay for the work you've done for the last few years
00:19:57.575 --> 00:20:01.775
i mean it's by far the best stuff written on this by far there isn't even a
00:20:01.775 --> 00:20:05.475
close second so you know i think that needs to be acknowledged I mean,
00:20:05.555 --> 00:20:07.955
maybe the problem is, Laura, your work is too good.
00:20:08.055 --> 00:20:09.135
I mean, why would you want to
00:20:09.135 --> 00:20:12.315
consult somebody who knows anything about it when it's easier to consult?
00:20:12.895 --> 00:20:16.115
I don't have professor. I don't have professor next to my name.
00:20:16.335 --> 00:20:21.255
Well, I'm going to add it. This is like a wizard, right out of the Wizard of Oz, okay? A line.
00:20:22.595 --> 00:20:27.855
Laura, I designate you from this point on. You are Professor Laura Snyder.
00:20:29.715 --> 00:20:32.795
There you go. Now you're a professor. All right.
00:20:34.115 --> 00:20:38.855
Well that's how Wizard of Oz why not well.
00:20:41.487 --> 00:20:44.767
So on that note professor snyder thank
00:20:44.767 --> 00:20:48.867
you so much for participating in this today karen well
00:20:48.867 --> 00:20:52.307
actually no you really are professor albert no no
00:20:52.307 --> 00:20:58.307
i'm not i was not did not get that high well i'm going to designate you also
00:20:58.307 --> 00:21:05.027
you're you're albert so professors any final comments otherwise thanks very
00:21:05.027 --> 00:21:10.167
much for the commentary and i think that and i think that tax notes needs to
00:21:10.167 --> 00:21:11.707
hear from us on this issue.
00:21:12.167 --> 00:21:14.387
Karen? Thanks, John.
00:21:15.287 --> 00:21:17.747
Yeah, thanks, both of you. Thanks. Okay.