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To become a US citizen or not?

To become a US citizen or not?

Old Jun 1st 2018, 7:52 pm
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Default Re: To become a US citizen or not?

Originally Posted by NYer View Post
This seems to be the average reason for British expats who post here: I'm here for the cash. Sad reason for leaving your own country and burdening this country with that bad attitude.
I wouldn't say it was the average. Well ok - I don't know. Maybe I'm assuming the majority of people actually want to be here to be happy? Or happier than before?
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Old Jun 1st 2018, 8:54 pm
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Default Re: To become a US citizen or not?

Originally Posted by GSH View Post
I've been in the US since 1980 when I was nine. I'm an LPR with a Green Card. Never thought to become a citizen - being British why would you. At this point in my life I have no desire to become a citizen of the US. To stand and take an oath to this country, you've got to be kidding me. Not missing out on much - voting? What's the point. Nothing changes anyway. The politicians do what they want regardless. I'm only here because I work - if they kicked me out tomorrow I wouldn't cry. Sure it would be a bit of a hardship for a while but this isn't my country, England is. My parents went to Europe ten years ago for retirement. They couldn't have survived living here and having to pay rent. I wouldn't expect to retire here myself.
That is some serious passion for someone who barely lived in the UK and remember a whole lot about it. It also appears your experience in the US hasn't been that great since you dont appear to have any allegiance to the US, not any desire to vote. That's pretty sad. I'd be curious to see how "your country" would look after you if you got kicked out of here at age 46. Starting over at that age anywhere is tough
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Old Jun 1st 2018, 8:56 pm
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Default Re: To become a US citizen or not?

Originally Posted by Hawkini View Post
I wouldn't say it was the average. Well ok - I don't know. Maybe I'm assuming the majority of people actually want to be here to be happy? Or happier than before?
Majority of immigrants (not just from UK) DO want to be here and go to great lengths to be here. It's really the immigrant population that continues to inject this society with great work ethic and values. Immigrants are who keep this place vibrant and humming imo...
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Old Jun 1st 2018, 9:25 pm
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Default Re: To become a US citizen or not?

Originally Posted by BigK View Post
Majority of immigrants (not just from UK) DO want to be here and go to great lengths to be here. It's really the immigrant population that continues to inject this society with great work ethic and values. Immigrants are who keep this place vibrant and humming imo...
I agree that's the case today and has been the case for most of our history. I also think the OP may have unrealistic views of his "home" country and will probably be as unhappy there as he is here.
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Old Jun 2nd 2018, 2:52 am
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Default Re: To become a US citizen or not?

A further explanation of the above video:
Don't have a lot of sympathy for their situation tbh. They've been using a CCPC as a retirement savings vehicle, which is not what they're intended for. People typically do this when they max out their RRSP contributions and CCPCs are subject to a lower income tax rate if (and only if) they are legitimate businesses. If you use it purely for investing, the Part IV tax rate is the same as for regular investments. The Canadian govt themselves have been trying to crack down on this because a lot of people are using CCPCs saying they're legitimate businesses when in reality they're being used to avoid tax on investments.

Finance Minister Bill Morneau proposes tax changes to close loopholes for wealthy | CBC News - the bit at the bottom about passive investment income

If you're using a sophisticated tax dodge scheme, don't be surprised if the authorities crack down on it. Been saying for years to accountants that this is stupid and there would be a crackdown.

As far as GILTI mentioned in the article, that's a more legitimate gripe, or at least it would be if the federal corporate tax rate in the US hadn't been dropped so sharply. Essentially they want CFCs to pay the US corporate tax rate. That is a problem for CCPCs engaged in legitimate business as the CCPC rate is lower than the US rate of 21%. A CCPC is intended to do the same thing as an S-corp in the US but they're designed differently, so a CCPC is seen as being an ordinary CFC under US law.

That might be solvable through the regulations though.
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Old Jun 2nd 2018, 3:08 am
  #51  
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Default Re: To become a US citizen or not?

Originally Posted by NYer View Post
This seems to be the average reason for British expats who post here: I'm here for the cash. Sad reason for leaving your own country and burdening this country with that bad attitude.
What??? I don't think I've EVER seen that as the reason put forward by British expats on here. I've seen endless numbers of people decide to become pool cleaners or running a B&B on an E-2 visa earning f all money just so they have the privilege of living in the US! Endlessly on here I try to talk them out of it, because they'll never get LPR status that way let alone US citizenship and all their Medicare tax will never help them because as soon as they retire they have to leave the country. And if they've got kids, they can't work and age out when they're 21.

It's like people are brainwashed from going to Disney World or watching American TV and movies into thinking it's the best place to live so they do all kinds of crazy things to live in the US. We even started a joke thread about it, it's so common.

The whole time I've been posting on here I've only seen two people who wanted to get an E-2 for the actual reason they were designed for, i.e. trade investment. One was a guy who wanted to start a company in Atlanta and another was a guy in Vancouver who wanted to buy a laundromat in Bellingham.

In Canada we say people live in the US for one of three reasons: work, love or weather but a lot of British people seem to do it simply because of the novelty value. Yeah there are a lot of people on here that get transferred over on L-1, but they don't generally have to, they just want to.

The other thing I've noticed on here is that there are quite a substantial number of people who've lived in the US and Canada and end up living in Canada. And most of them are US citizens. Once the brainwashing dissipates, the result is hmm... okay yeah Canada is a better place to live, if I'm being honest with myself.
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Old Jun 2nd 2018, 3:16 am
  #52  
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Default Re: To become a US citizen or not?

Originally Posted by Rete View Post
As well as my Canadian, now also USC husband, pays both Canadian taxes and US taxes. And this is just on retirement benefits from his respective governments.
Yeah but that's Canadian-source income, you typically pay tax on foreign source income, that's why there are tax treaties. The US actually taxes you on the basis of your citizenship, there might be a way to avoid paying the tax via some exemption (such as the FEIT) but sometimes there isn't. It definitely makes your life more complex.

The 25% non-resident tax on RRSPs for example is designed to level the playing field, because if you lived in Canada you would pay income tax on draw downs. Under the US-Canada tax treaty, that's reduced to 15%. And the US has a 15% non-resident alien tax on US-source income from investments as well - but if you're a US citizen living in Canada and you draw down your 401(k) then you have to actually file a US tax return and report the income.

You Canadian husband shouldn't need to file a Canadian return, he just gets the tax slip and claims a foreign tax credit.
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Old Jun 2nd 2018, 10:55 am
  #53  
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Default Re: To become a US citizen or not?

Originally Posted by Steve_ View Post
Don't have a lot of sympathy for their situation tbh. They've been using a CCPC as a retirement savings vehicle, which is not what they're intended for. People typically do this when they max out their RRSP contributions and CCPCs are subject to a lower income tax rate if (and only if) they are legitimate businesses. If you use it purely for investing, the Part IV tax rate is the same as for regular investments. The Canadian govt themselves have been trying to crack down on this because a lot of people are using CCPCs saying they're legitimate businesses when in reality they're being used to avoid tax on investments.

Finance Minister Bill Morneau proposes tax changes to close loopholes for wealthy CBC News - the bit at the bottom about passive investment income

If you're using a sophisticated tax dodge scheme, don't be surprised if the authorities crack down on it. Been saying for years to accountants that this is stupid and there would be a crackdown.

As far as GILTI mentioned in the article, that's a more legitimate gripe, or at least it would be if the federal corporate tax rate in the US hadn't been dropped so sharply. Essentially they want CFCs to pay the US corporate tax rate. That is a problem for CCPCs engaged in legitimate business as the CCPC rate is lower than the US rate of 21%. A CCPC is intended to do the same thing as an S-corp in the US but they're designed differently, so a CCPC is seen as being an ordinary CFC under US law.

That might be solvable through the regulations though.
You've identified two separate issues.

The first is Canada and it's home grown tax avoidance schemes. It's fairly certain the couple in the video do have a legitimate business. How Canada closes a tax loophole and who that effects is up to Canada (the couple in the video are Canadian citizens, living in Canada, working in Canada, and paying tax in Canada on Canadian income, planning for retirement according to currently recognised Canadian tax planning methods; loophole or not). They'll work that out with Canada.

The Isaac Brock Society Be on the Lookout! Bubblebustin to be on CBC The National- on the #TransitionTax

The second issue, and the one pertinent to this discussion, is their US citizenship. They are dual US/Canadian citizens.

They have been complying with US tax reporting including all the complicated form filing required for those who own a foreign business (Canadian business). They could have structured their business differently (tick the box for US), but instead structured it advantageously for Canada. Nonetheless, through their US reporting, they were also fully compliant in the US.

The rushed Tax Cuts and Jobs Act was passed in mid-December and deemed the foreign business (but more importantly, the USC shareholder personally) to be subject to the Transition/repatriation tax. No business had any forewarning of the final regulations, nor did they have any opportunity to re-structure the business. There is no way to avoid the tax which is retroactive back to 1986. There may be wiggle room on GILTI, but it may require restructuring the business differently in Canada going forward solely due to a US tax.

The large targeted corporations (Google, Facebook, et al) are able to absorb the tax. The small business person is not. When they withdraw funds from the business to pay the US tax they will also be subject to tax in the resident country; and foreign tax credits are not available for the transition tax.

This is a prime example of tax laws passed by the US, intending to target US citizens/companies resident in the US, but which have unintended consequences on USCs resident abroad. We may all have opinions concerning tax avoidance schemes in our home/resident countries, but to have a foreign country (the US) impose a tax out of the blue which has major financial consequences on income in the resident country can only be associated with USCs resident abroad.
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Old Jun 3rd 2018, 10:24 pm
  #54  
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Default Re: To become a US citizen or not?

Maybe it's my natural paranoia, but I don't think I'll ever really feel safe and secure here until I naturalize. Just the knowledge I could get kicked out if I did something really stupid, or if I had to leave the country for a while and didn't come back in a timely manner, is enough to want to naturalize. I'll be very happy when I finally attend that citizenship ceremony. It won't make me less English, because you can take the girl out of England, but you can't take the England out of the girl. You can, however, bribe her (me) with powerful showers, huge apartments, even bigger washer/dryers, home aircon and tanks as cars. It's the simple things that make me happy.
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Old Jun 4th 2018, 11:27 pm
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Default Re: To become a US citizen or not?

I still identify strongly with being English and am also proud to be American. There really aren’t any disadvantages unless you want out and are certain you’ll never want to live here again.
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Old Jun 6th 2018, 1:54 am
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Default Re: To become a US citizen or not?

Originally Posted by theOAP View Post
You've identified two separate issues.
They both relate to CCPCs, in fact there's three, two US issues and one Canadian issue. I always cringe when people tell me they use CCPCs as some sort of retirement investment vehicle, it's so obvious you're going to be caned by the Govt. at some point. Read that article closely you linked to.

"You can't let another country come in and raid the country's pension plans."
Says some lawyer who probably has made money out of advising clients to use CCPCs in way they are not designed to be used. They're NOT pension plans, it's a type of corporation not intended for passive investment.

​Some of those being hit are like retired Queens University professor and doctor Brian Arthur — professionals or small business operators who were using corporations to save for retirement.
Specifically says, "for retirement".

Others are looking at tax bills that run into the millions, said Beth Webel, a partner in tax services with the accounting firm PwC Canada.
Who also gave crappy advice to her clients, "put it into a corporation" the standard tax advice from PwC worldwide it seems.

If you were using it the way it was intended to be used, your retained earnings would be very little, generally people don't keep that much money in a corporation because then it gets hit with corporation tax, best to pay it out with the payroll (which is a legitimate business expense). Ergo, the US tax would probably be a non-issue. There are ways of using CCPCs to pay less tax on investment and not casually, it requires quite a lot of complex tax planning to do it (deferring, using complex stock buyback schemes, playing silly buggers with the dividend tax credit etc.) Normal investment income in a CCPC is taxed at the normal corporate rate which is higher than the new US 21% rate - so not taxed, in other words.

People typically do this because they max out their RRSP contribution room - and even then, a corporation can set up an individual pension plan if it wants, both protected under Article 18 of the tax treaty. "Ordinary" people who use a CCPC as a retirement plan tend to be professional people like doctors, but no-one says they couldn't have used an IPP which was frankly a more sensible option. IPPs can be quite expensive to operate - but PwC fiddling with your CCPC isn't?

If you need PwC and/or a lawyer to explain how to use your pokey little private corporation to save a bit of tax (it isn't much) and you get buggered by the CRA and/or IRS, that's karma, imo. According to the CRA, 84% of CCPCs have no passive investment income at all. But yet, 1.6% of CCPCs earn 80% of all passive investment income earned by a CCPC: https://www.fin.gc.ca/n17/data/17-099_1-eng.asp

And how many of those 1.6% CCPCs are controlled by US persons? Roughly 2.5% of the Canadian population are US citizens, so assuming even distribution that works out to 0.04% of CCPCs. Wow.

Cry me a river. Boo hoo. "I tried a tax dodge and it failed" should be the title of that article. I have more sympathy with the complaints about GILTI, but the name of the corporation is "Canadian Controlled Private Corporation" so I would have thought it could be sorted out in a regulation because by definition you have to be tax resident in Canada to have one, it's not a CFC in the ordinary sense of the term.
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Old Jun 6th 2018, 2:06 am
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Default Re: To become a US citizen or not?

Originally Posted by GSH View Post
I've been in the US since 1980 when I was nine. I'm an LPR with a Green Card. Never thought to become a citizen - being British why would you. At this point in my life I have no desire to become a citizen of the US. To stand and take an oath to this country, you've got to be kidding me.
You sound like the friend I alluded to earlier who participates in voter registration drives but refuses to naturalize.

By definition, the only people who are paid a salary to care whether you are a US citizen or not are immigration authorities, the relevant one being Immigration and Customs Enforcement. When you get convicted for manslaughter for running someone over (or whatever the offence is), get picked up by ICE and then spend months in removal proceedings (possibly while sitting in a detention centre) and then get put on a plane back to the UK, you can explain to your fellow passengers your principled stand against becoming a US citizen and see if they care.

How you "feel" about it is irrelevant, as a matter of law if you live in a country it makes sense to become a citizen of it. Look at all the British people living elsewhere in the EU who never paid any attention to it and are now being forced to.

The only real issue to my mind is the tax issue, and frankly you've already crossed that line once you've been an LPR for more than 8 years (the expatriation tax deadline) anyway.
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Old Jun 21st 2018, 7:06 pm
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Default Re: To become a US citizen or not?

Originally Posted by Steve_ View Post
What??? I don't think I've EVER seen that as the reason put forward by British expats on here. I've seen endless numbers of people decide to become pool cleaners or running a B&B on an E-2 visa earning f all money just so they have the privilege of living in the US! Endlessly on here I try to talk them out of it, because they'll never get LPR status that way let alone US citizenship and all their Medicare tax will never help them because as soon as they retire they have to leave the country. And if they've got kids, they can't work and age out when they're 21.

It's like people are brainwashed from going to Disney World or watching American TV and movies into thinking it's the best place to live so they do all kinds of crazy things to live in the US. We even started a joke thread about it, it's so common.

The whole time I've been posting on here I've only seen two people who wanted to get an E-2 for the actual reason they were designed for, i.e. trade investment. One was a guy who wanted to start a company in Atlanta and another was a guy in Vancouver who wanted to buy a laundromat in Bellingham.

In Canada we say people live in the US for one of three reasons: work, love or weather but a lot of British people seem to do it simply because of the novelty value. Yeah there are a lot of people on here that get transferred over on L-1, but they don't generally have to, they just want to.

The other thing I've noticed on here is that there are quite a substantial number of people who've lived in the US and Canada and end up living in Canada. And most of them are US citizens. Once the brainwashing dissipates, the result is hmm... okay yeah Canada is a better place to live, if I'm being honest with myself.
LOL! Gotta love that Canadian chauvinism!

Most of what I read here concerning America is that it has an out-of-date Constitution, very bad sweets and dreadfully expensive Bisto granules. And that's not necessarily in any order of concern.
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Old Jun 21st 2018, 8:00 pm
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Default Re: To become a US citizen or not?

Originally Posted by NYer View Post
LOL! Gotta love that Canadian chauvinism!

Most of what I read here concerning America is that it has an out-of-date Constitution, very bad sweets and dreadfully expensive Bisto granules. And that's not necessarily in any order of concern.
And the most important concern of all is GUNS!!
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Old Jun 21st 2018, 10:48 pm
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Default Re: To become a US citizen or not?

Originally Posted by Steve_ View Post
What??? I don't think I've EVER seen that as the reason put forward by British expats on here. I've seen endless numbers of people decide to become pool cleaners or running a B&B on an E-2 visa earning f all money just so they have the privilege of living in the US! Endlessly on here I try to talk them out of it, because they'll never get LPR status that way let alone US citizenship and all their Medicare tax will never help them because as soon as they retire they have to leave the country. And if they've got kids, they can't work and age out when they're 21.

It's like people are brainwashed from going to Disney World or watching American TV and movies into thinking it's the best place to live so they do all kinds of crazy things to live in the US. We even started a joke thread about it, it's so common.

The whole time I've been posting on here I've only seen two people who wanted to get an E-2 for the actual reason they were designed for, i.e. trade investment. One was a guy who wanted to start a company in Atlanta and another was a guy in Vancouver who wanted to buy a laundromat in Bellingham.

In Canada we say people live in the US for one of three reasons: work, love or weather but a lot of British people seem to do it simply because of the novelty value. Yeah there are a lot of people on here that get transferred over on L-1, but they don't generally have to, they just want to.

The other thing I've noticed on here is that there are quite a substantial number of people who've lived in the US and Canada and end up living in Canada. And most of them are US citizens. Once the brainwashing dissipates, the result is hmm... okay yeah Canada is a better place to live, if I'm being honest with myself.
Um, no. I'm a multiple citizen who chooses the US over Canada (though, I'm in neither right now). Roughly the same number of US Citizens live in Canada as Canadian Citizens who live in the US . . . and considering the population difference between the two countries it's a telling statistic. That isn't to take a dig at Canada but there are a lot of reasons why this happens. That's also why there will not be anything like a North American version of Schengen in our lifetimes.

Your first paragraph, however, are all excellent reasons to dissuade someone from trying to come to the US and to consider Canada instead. I think four of the last five immigration situations I've commented on, on BE, were from people with no shot whatsoever at getting a visa (generally, not limited to the US), but who wanted to talk about suburbs to buy a house in, schools etc. It seems we get a lot more like that on the Forum these days than some years ago.
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