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Apple must pay 13B euros in back taxes, EU's top court rules

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Re: Apple must pay 13B euros in back taxes, EU's top court rules

#551
post #387

Earlier quoted context omitted.

what is even crazier, is its not just Americans impacted by this. If you have a green card, but not working in the USA, you're impacted by this mess too.

I'm a non US citizen nor resident, never have been and probably never will be. Because of FATCA, I had to prove to my Eastern European bank (where I actually am a citizen) that I am not a "US person". That designation has no legal meaning, anywhere in my birth country, yet I had to sign a formal written declaration "I, NAME, declare under penalty of penal law, that I am not a US person", to be able to access my funds…

> I'm a non US citizen nor resident, never have been and probably never will be. Because of FATCA, I had to prove to my Eastern European bank (where I actually am a citizen) that I am not a "US person". That designation has no legal meaning, anywhere in my birth country, yet I had to sign a formal written declaration "I, NAME, declare under penalty of penal law, that I am not a US person", to be able to access my funds again.

Your bank was terrified of losing access to US markets, so your bank forced you to prove you're not a US person to be super safe about US tax compliance. Seems like your complaint is with your bank, not the US. You're welcome to bank with a bank that has different policies. I have had European bank accounts before and I've certainly never been asked to prove I am not a US person. (On the other hand, I was asked to sign an absurd amount of paperwork that had nothing to do with the US, because it's Europe, and you need thirty-four forms and a notary public to be allowed to even exist.)

> USA always overreaches.

The US doesn't care about you at all.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#552
post #488

Earlier quoted context omitted.

Many types of income cannot be offset nor or they covered by tax treaties. That's news to me and I've been doing international tax for 15 years. Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? It is not uncommon to pay more taxes in aggregate as an expat than you would pay in either country separately. This is objectively false. For an expat, income taxes paid to a resident…

> Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? I am not a tax person, but selling a house can cause you to owe tax in the US even if you did not owe any tax in the country you are living in (and sold the house in). Famously one of the reasons Boris Johnson tried to give up his US citizenship ( https://www.bbc.com/news/uk-politics-30932891 ).

> selling a house can cause you to owe tax in the US even if you did not owe any tax in the country you are living in

But you’re not being double taxed.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#553

Earlier quoted context omitted.

> Expats aren’t double taxed but you need to file tax returns to offset taxable income that’s already been taxed. This is not correct, it is only practically true in trivial cases. Excess taxation is a very real pain point for Americans living overseas, never mind the other indefensible things the US government does to its expats like FATCA. Many types of income cannot be offset nor or they covered by tax treaties. E…

I once heard a story of a family living abroad feeling quite bent about this extra taxation that they were paying no reason. But the story ends with the family being rescued by a USMC helicopter and airlifted to safety after a natural disaster, at which point they supposed they had been paying for something after all.

> at which point they supposed they had been paying for something after all.

but they would've been rescued regardless of whether they'd been paying their share of taxes, as long as they're a US citizen.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#554
post #521
post #501

Earlier quoted context omitted.

On the other hand, I know someone from the UK who moved away and lived in places like Qatar and Oman for 20-30 years, keeping their UK citizenship and paying zero taxes to the UK (and extremely low taxes in the gulf countries). Then they retired, returned to the UK, sent their kids to subsidized state universities (in the UK), receive free healthcare on the NHS, and receive state benefits for retirees. They receive a…

If I don't do any of the dodgy parts of that story but move to another EU country with children they'll also get free school, Healthcare and so on. For this to be "fair" you'd need some global EU contribution scheme OR nobody can move.

But then do the same people making the argument it's not fair to have paid zero taxes believe that welfare isn't "fair"?

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#555
post #489

Earlier quoted context omitted.

Many types of income cannot be offset nor or they covered by tax treaties. That's news to me and I've been doing international tax for 15 years. Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? It is not uncommon to pay more taxes in aggregate as an expat than you would pay in either country separately. This is objectively false. For an expat, income taxes paid to a resident…

My understanding, despite the fact I'm definitely not an accountant, was that making over $100K abroad meant you would be double taxed on all of it over that amount. I believe I heard many wealthy Americans abandoning their citizenship just due to this fact.

That is definitely wrong. You are subject to a single level of tax on your personal income (in the US). But you might have to split it up between multiple jurisdictions if some of that income is earned in another country.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#556
post #551

Earlier quoted context omitted.

I'm a non US citizen nor resident, never have been and probably never will be. Because of FATCA, I had to prove to my Eastern European bank (where I actually am a citizen) that I am not a "US person". That designation has no legal meaning, anywhere in my birth country, yet I had to sign a formal written declaration "I, NAME, declare under penalty of penal law, that I am not a US person", to be able to access my funds…

> I'm a non US citizen nor resident, never have been and probably never will be. Because of FATCA, I had to prove to my Eastern European bank (where I actually am a citizen) that I am not a "US person". That designation has no legal meaning, anywhere in my birth country, yet I had to sign a formal written declaration "I, NAME, declare under penalty of penal law, that I am not a US person", to be able to access my fun…

> The US doesn't care about you at all.

of course not - they're a nobody.

They don't mean the US cares about the individual - the post is about the general level of regulation that the US is able to force upon third parties.

But then again, this is what it means to be sovereign. And to be honest, the US's overreach is not as high as it could've been given how much clout they have. Imagine if it was china in the same powerful position - what would've been the overreach then?

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#557
post #387

Earlier quoted context omitted.

what is even crazier, is its not just Americans impacted by this. If you have a green card, but not working in the USA, you're impacted by this mess too.

What's funny is America has some of the longest paths to a Green Card (for Indians and Chinese at least), but is very very happy to tax them as a resident the moment they spend a year in the country. Indians effectively pay taxes as residents without any permanent residency benefits for decades

They chose to do it under the terms that have been laid out by the US - so obviously, it's _still_ benefitial for them to continue despite being taxed without representation.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#558

Earlier quoted context omitted.

> Expats aren’t double taxed but you need to file tax returns to offset taxable income that’s already been taxed. This is not correct, it is only practically true in trivial cases. Excess taxation is a very real pain point for Americans living overseas, never mind the other indefensible things the US government does to its expats like FATCA. Many types of income cannot be offset nor or they covered by tax treaties. E…

Many types of income cannot be offset nor or they covered by tax treaties. That's news to me and I've been doing international tax for 15 years. Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? It is not uncommon to pay more taxes in aggregate as an expat than you would pay in either country separately. This is objectively false. For an expat, income taxes paid to a resident…

There's US state taxes (for those states that have it), which does not get credited with foreign income tax.

There's a lot of VAT (value added tax, aka sales tax) that gets paid when buying goods. If this was higher than the US's in the expat's country, they don't get a credit (but conversely, if it was cheaper, then they also don't have to backpay...).

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#559

Earlier quoted context omitted.

Universal healthcare and welfare systems aren’t free.

The welfare systems (in Europe at least) don't work. They work if you're old right now, but once the young people of today become old they won't get anything meaningful out of it. At least that's the impression I have and everyone else my age has. And healthcare is unavailable anyway. Several month long waits to see a specialist.

Here you have tons of USA citizens living in EU (and around the world) and ask them for first hand expirience on alternative.

https://www.youtube.com/watch?v=D1yT8swtVvg

Dont miss part 2, part 3,... and skip non health care related, you might not want to hear them.

And anyway, believe me that everyone rather waits in line (which is not really the case, if you are an urgent case, you trough the line), that not even go to the line as their medical insurance doesnt support the needed therapy as it would make their family bankrupt.

Funny fact, check the price of insuline.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#560

Earlier quoted context omitted.

If you don't like then... uh... come back?

You can spout off "my way or the highway" as long as you think US citizenship is valuable enough that people are going to put up with it. People not expatriating is obviously the desired outcome of those rules, and the alternative is people renouncing their US citizenship (which is becoming more reasonable as the US passport gets weaker, among other factors). You're missing part of the point, though. Almost no other…

> The US government provides among the lowest level of services for its citizens out of any first-world government, so there's no reason it needs to be that much more strict.

they provide you the world's premier military! That costs a pretty penny.

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