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Aug 6th, 2022
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How to Finish flag in the Tax Agreement

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welcome back everyone michael here with offshore citizen today i want to discuss with you what i call the new flag theory and its based on this premise a lot of people are probably familiar with this concept of flag theory sometimes called five flag theory and just really quickly the premise of it is that you should plant different flags uh with different things around the world and they would pay attention to you know where your bank accounts wheres your residency where is your citizenship where is your company i cant remember what the last one maybe wheres your property or your investments something like that and historically they had this idea of kind of spreading out these flags and there were some practical reasons for it i would say it became less practical somewhere around 2015 to 2017 so for example from an asset protection standpoint what we used to do is we would set up a structure that looks approximately like this you would have a trust the trust would have a bank acco

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It means that when it comes to Social Security and other public pensions, they will only be taxed in the first mentioned state. In other words, if the United States pays Social Security to a US person who resides Korea, then only the United States will be able to tax that Social Security income.
Exit tax is not charged out of mean-spiritedness or as a final grab at your personal assets. Instead, exit tax is an attempt by the US government to consolidate your US tax affairs. Exit taxes are relevant because some taxable income such as capital gains on home ownership is not taxed until you dispose of the asset.
A certain amount of gain is excluded from the mark-to-market tax. Note these changes: The income tax threshold for triggering covered expatriate status increases to $178,000 in 2022 (from $172,000). The excluded gain under the mark-to-market tax increases to $767,000 (from $744,000).
How is the exit tax calculated? The American exit tax is calculated by applying a special tax rate to your unrealized capital gains. The tax rate is currently 23.8%.
Tax sparing entails capital-exporting country granting a credit not only for the tax paid but for the tax spared (annulled or reduced) in source countries with the aim of providing incentives for investments. Tax sparing (to the extent of 10% of interest income) is currently there in the existing DTAA.
A certain amount of gain is excluded from the mark-to-market tax. Note these changes: The income tax threshold for triggering covered expatriate status increases to $178,000 in 2022 (from $172,000). The excluded gain under the mark-to-market tax increases to $767,000 (from $744,000).
The exit tax allows former citizens and residents to fulfill their tax duties before permanently removing themselves from the US governments tax jurisdiction. Only US citizens and long-term residents who the IRS considers covered expatriates are subject to this tax.
Once you renounce your US citizenship, you will no longer have to pay US taxes. However, the US government does charge a fee of $2,350 to relinquish citizenship.
The exit tax is an income tax on 1) unrealized gain from a deemed sale of worldwide assets on the day prior to expatriation; and 2) the deemed distribution of IRAs, 529 plans, and health savings accounts (taxed at ordinary income rates).
In order to even be subject to the IRS covered expatriate and exit tax rules, a person must be a U.S citizen or long-term legal permanent resident. Therefore, the easiest way to avoid the long-term resident exit tax trap it is to simply avoid becoming a legal permanent resident.

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