dbd33

You can renounce US citizenship.

BristolUK

Don't you have to click your heels together three times or something?

MarylandNed

Yes, there used to be restrictions on multiple citizenship for US citizens but all remaining restrictions were struck down by the US Supreme Court in 1967 in Afroyim v. Rusk (Afroyim v. Rusk - Wikipedia, the free encyclopedia).

You can't lose it involuntarily. However, there are a number of ways you can lose it voluntarily e.g. by renouncing it, by taking up arms against the US, by an act of treason, etc. The US has to prove you committed these acts with the intention of giving up US citizenship. The renunciation one is voluntary by definition but your intention to give up US citizenship in the others is harder to prove. You can also lose it if you are a naturalized US citizen and it is later discovered that you were ineligible at the time of your application (e.g. you lied about something on your citizenship application).

The US taxes its citizens on worldwide income regardless of where they live. All US citizens (regardless of where they live) are therefore liable to file a US tax return every year if they meet certain income requirements. However, the US also has tax treaties with many countries (including Canada) to prevent double taxation on the same income. For example, my daughter has Canadian and US citizenship and worked last year in Canada. She filed US and Canadian tax returns for 2014 but owed nothing on the US tax return because she was able to claim a credit for tax paid in Canada. However, she still had to file the US return because she met the minimum income level (the fact that the income was earned outside the US is irrelevant as the US taxes worldwide income). Your friends are actually in a common situation and should consult a tax expert to find out what they need to do to file missing US tax returns.

All of this raises a very important point about moving to other countries and taking up citizenship (including the kids who may acquire multiple citizenships through birth or naturalization of their parents). You need to be be continuously aware of the various laws that you are subject to as someone who has multiple citizenships. I say "continuously" because laws change over time. Also, some are applied retroactively and some are not.

JonboyE

Only if you are tax compliant in the five preceeding years.

scilly

So why are they chasing people who left the US 30, 40 or 50 years ago, have never earned any income in the US in that time, have paid taxes in Canada (or another country), and the IRS are demanding that back taxes be paid in excess of 5 or even 6 figures?

All of the people I know had the understanding that they did not have to file US tax returns when they didn't have any US income, whether they were US citizens or not. Some of them even had legal advice from tax lawyers dating back years that they did not have to file in the US

Most everyone I think understands that if you earn income in another country then you usually have to file a tax return in that country as well as in the country in which you reside.

This has been an issue in Canada for about the last 4 or 5 years. The IRS want to get all the tax that they say people should have paid during their working life ............. you have to submit all your documentation, evidence of taxes paid, etc etc. Then the IRS comes back with a demand for payment of back taxes owing.

One couple we know came up here to work the same month that we did, and never went back to the States to work. She became a Canadian citizen and renounced her American citizenship, her husband did not renounce his.

She was declared to not owe American taxes. Her husband has been told by the IRS that they consider he will owe US taxes in the 5 figures.

These people are having to employ taxation lawyers to prove that they a) have paid all taxes owing in this country, b) that none of the money was earned in the US, and c) to over-turn the IRS decisions.

Not what you need as a Senior Citizen.


I do have a very good idea what the IRS is doing ...... they ignored all these people who left the US to work in other countries until fairly recently and are now busy attempting to claim back that is not owed to them. It has not endeared them to many people ........... and that dislike spills over to a greater dislike of the US government, and people saying "I'm glad we got out"!

MarylandNed

They chase you if you should have filed tax returns but didn't. Even if you don't actually owe anything, you still have to file the tax return if your income is above a certain level. I don't know the details of individual cases but the fact remains that where the money was earned is completely irrelevant. As I said before, US citizens are liable to pay tax on worldwide income regardless of where they live.

That understanding was wrong. It's worldwide income that counts - not just US income. Sounds like they received bad advice from the tax lawyers.

But this isn't the case that we're talking about - we're talking about US citizens living and earning only in Canada. Again, US citizens are liable to file tax returns on worldwide income (assuming the income is above a certain level) regardless of where they live. That includes Canadian income, Chinese income, Botswana income, etc. Worldwide means anything earned on planet Earth and it doesn't matter if you live in Canada or Timbuktu.

Yes, that's what the IRS does. That is its job.

Right - she doesn't owe US taxes because she's not a US citizen. But her husband is a US citizen and so is subject to US tax law even though he lives in Canada.

Hopefully this message is now getting through - it doesn't matter WHERE the money was earned. Again, US citizens are liable to file tax returns on worldwide income (assuming the income is above a certain level) regardless of where they live. Proving that none of the money was earned in the US doesn't help them.


The IRS is trying to force US citizens to comply with US tax laws. They may or may not owe money since they can claim credits for taxes paid to Canada. However, all US citizens have to file US tax returns if their income is above a certain level regardless of whether they actually owe anything to the US govt.

scilly

thank heavens we are not US citizens ................ and were only Resident Aliens for a year

JuneSpring

One of the Facebook guys renounced his US citizenship after the stockmarket launch to save on his taxes

Shard

Was it the case that in the distant past the IRS did not enforce the worldwide earnings rule or was the rule only implemented twenty years ago or something?

MarylandNed

The law was implemented in 1864 during the American civil war in an attempt to prevent wealthy Americans going abroad to avoid their military and tax obligations. However, the IRS has definitely been stepping up enforcement in recent years as the amounts involved are now huge.

scootb

Roberto,we made the move 2 years ago and are now residents.
I think were you move to and are coming from plays a HUGE role in how you feel about the place.
I lived in Glasgow(Scotstoun) in the 80's,if you know Glasgow well then you know how bad that area was back then lol,we moved there from a then small town called Stewarton in Ayrshire it was a HUGE culture shock for me.
We are glad that we came to Canada and it was as much for the kids as it was for me,if I never had the kids I would not have had the motivation to get out of the UK!!!!

I was never a city person and have always preferred living in smaller towns,I am now in Edmonton and it is the only city I have lived in that I actually like!
Yes people from nice areas of rural England tend to complain about Canadian culture,how its not as nice as England etc... us Scot's seem to be the opposite for some reason,all the Scot's I have spoken to love Canada,as do most of the English I have spoken to that have come from cities.

My kids love it here,it is safer than the UK I feel,we do a lot more outdoor activities even in the winter as powdery snow beats months of rain and black clouded skies for us anyday.

DandNHill

I'm from rural south east England. The only thing I do miss at times is the rolling hills on the south downs... but that's no way enough to make me move back there.
I'm in Ontario and quite happy with things as they are

scootb

It's good to hear from people who are positive about the move!
There is a lot of negativity on these forums for some reason,personally I can only be positive about our experience and would hate for anyone not to give it a shot due to the negative posts.

scilly

Here's positive for you

We left the UK a week after our wedding in 1967, and spent 1 year in the US (Texas) and would not return to live there again.

We've moved up to Vancouver in 1968, and have been here ever since ...... and are perfectly happy and content.

We have spent holidays in every province and 1 territory in Canada, missing only NWT, Nunavut and Labrador

Our only child has lived in Halifax, NS since her marriage in 1999, and enjoys it. I think they would like to return to the West Coast, but accept they can't afford it so set themselves to enjoying what is to offer on the East Coast.

They do both have good jobs, but have a house that is a little more expensive than they should have bought ....... so will having camping holidays in NS, NB and PEI for the next several years.

We try to take the train across Canada when we go to visit ...... that is one huge eyeopener of a trip if you can ever manage to make it. It really brings home how vast this country is, and how different is every province and region.

Neither of us has ever had an urge to return to live in the UK, we went back for holidays and to see family at about 5 or 6 year intervals. We could usually find somewhere else to visit, especially after the parents all died and that pressure was gone.

There is very little that we miss about the UK ..... I sometimes think of a small village in southern England that we love. But then, I realise that a) it will most definitely have changed in the last 40+ years, and b) I probably could no longer live in a small village.

Nor do we yearn for English food ..... except for Lea & Perrins Worcestershire sauce, HP Sauce, Heinz Salad Dressing, and Branston Pickle. All of which we can buy in our local Safeway store.

If we had to move from Canada, we would have gone across the Pacific, to NZ or certain parts of OZ ...... we spent almost a year in Australia and loved it, and OH and daughter spent about 10 months in NZ.

I was born and raised in a cotton mill town in Lancashire, OH was raised in Cheshire, and we met at Liverpool Univ ...... so between us we come from grimy mill town and rural areas.


In other words .............. we've never been sorry that we came here, and have no regrets about leaving the UK

Decisive moment

Thats good to hear! Its a shame there is so much negativity as you said it does make the doubts creep in when reading all this stuff.
Anyone who has kids and plans to move them thousands of miles away from friends and family to a new country is bound to feel nervous and confused.

I don't expect this journey to be a bed of roses, but I think positive thinking and attitude goes a long way and there are good and bad things about each country I'm sure.

We are lucky to live in a beautiful part of the UK and some people might question our motivation to leave it, but life is so short and if you get an opportunity to experience a different country and culture, then I personally think (and am doing so) that you should go for it.

Yes things will be different, some will will be better, some evidently worse, but I would rather find this out than spend my time wondering 'what if'.

I'm hopeful that this will be a great experience for my whole family, I wouldn't be doing it if I didn't.