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“Mutual assistance in collection” treaty provisions

597 views 0 replies 1 participant last post by  underation 
#1 · (Edited)
At present, most US tax treaties don’t have “mutual assistance in collection” provisions, and those that do, don’t provide for assistance where “the revenue claim relates to a taxable period in which the taxpayer was a citizen of the requested State.”

USC expats who are filing US tax returns - should be aware that that situation could easily be changed, if both parties want it to change. The US-Japan Protocol recently ratified does allow for collection from Japanese-US duals under certain specified circumstances.

IMO, there are better options available than relying on residence-country citizenship: renounce, comply fully, or, if you have only residence-country income/assets, don’t file.
 
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