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Six Months in Each Country?

Six Months in Each Country?

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Old Feb 24th 2014, 5:15 pm
  #76  
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Default Re: Six Months in Each Country?

Originally Posted by Jsmth321
Are you saying Canadian provinces have no agreements with any state?
Well what was all that fuss about then with the driver compact?

Because yes it does say they have a reciprocal agreement.

I got a ticket in Montana and I asked about it at the registry office and they said no agreement, so no it won't show up. Is it just for offences?
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Old Feb 24th 2014, 5:20 pm
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Default Re: Six Months in Each Country?

Originally Posted by Jsmth321
Are you saying Canadian provinces have no agreements with any state?

I know ICBC can access records of certain states, not all, but they can for some, I saw it happen right in front of me when I traded in my California license.

" B.C. has reciprocal agreements with certain countries, including the U.S."
Ontario had a licence "penalty points" sharing agreement with NY, and I think a few other NE states, more than ten years ago, so I would assume there is also a license exchange agreement too.

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Old Feb 24th 2014, 5:21 pm
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Default Re: Six Months in Each Country?

Hmm, poking around the web they appear to be bilateral agreements between the province and the State, not through the compact.

Very few of them appear to recognize offences, it's just an information exchange on DL information and registration.
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Old Feb 24th 2014, 5:22 pm
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Default Re: Six Months in Each Country?

Originally Posted by Pulaski
Ontario had a licence "penalty points" sharing agreement with NY, and I think a few other NE states, more than ten years ago.
Québec and Ontario seem to have a few agreements with a few States like Michigan, NY and Florida on offences but generally speaking there is no recognition.
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Old Feb 24th 2014, 5:42 pm
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Default Re: Six Months in Each Country?

Originally Posted by Steve_
The US doesn't have any formal reciprocal agreements with the DVLA because they're paranoid about privacy issues.

It's completely bonkers because they don't have any with Canada either, so for example if you get a speeding ticket in the US as a Canadian resident, it doesn't go on your record. They tried to do it with a "compact" a few years back and some States objected to Canada seeing their DMV records so it went nowhere.

Certain States in State law say they'll honour a licence from wherever and swap it with theirs, but that's just something the State has decided to do.

In Canada though provinces actually enter into formal agreements with DVLA or whomever and they can access each other's records.
I obtained an IL state DL , on the basis of a German DL, just picked up a short letter from the German consulate in Chicago. Then Mayor Daley (the IL DMV actually) gave me an IL car and bike DL and I kept my German DL and as that was as a Brit. No test, practical nor theory needed, just any piece of mail posted to my Chicago address as proof of IL residency.
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Old Feb 24th 2014, 5:50 pm
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Default Re: Six Months in Each Country?

Originally Posted by glemo
I obtained an IL state DL , on the basis of a German DL, just picked up a short letter from the German consulate in Chicago. Then Mayor Daley (the IL DMV actually) gave me an IL car and bike DL and I kept my German DL and as that was as a Brit. No test, practical nor theory needed, just any piece of mail posted to my Chicago address as proof of IL residency.
I may be wrong, but US states seem more willing to exchange licences i.e. issue a local license without a road test, from countries that drive on the right (Germany, France, Italy, etc.), than from those that drive on the left (most former British Empire countries, plus Japan). This is just my observation, based mostly on reports on BE.

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Old Feb 24th 2014, 6:04 pm
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Default Re: Six Months in Each Country?

Originally Posted by Pulaski
I may be wrong, but states seem more willing to exchange licences i.e. issue a local license without a road test, from countries that drive on the right, than from those that drive on the left (most former British Empire countries, plus Japan). This is just my observation, based mostly on reports on BE.
Canadian insurance companies seem to charge a lot more premium as well from people who come directly from such countries. I haven't heard of that in the US.
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Old Feb 24th 2014, 6:07 pm
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Default Re: Six Months in Each Country?

I don't think that's true, they just charge a lot, period. Plus several provinces run their own insurance anyway rather than private companies. There are limits on the rates charged in Alberta for basic insurance, never heard that come up before.
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Old Feb 24th 2014, 8:45 pm
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Default Re: Six Months in Each Country?

Originally Posted by Steve_
Why? As I said above it seems to make more sense for you to be resident in Texas. You can access healthcare through a plan you can get as a resident rather than a tourist, which will probably be cheaper, plus a tourist plan would probably go up in a puff of smoke if you ever actually used it. NHS costs as a non-resident are easier to work out and almost certainly lower than the other way around.

Texas certainly has lower taxes as well, say you have investments.

You've still got to file a US tax return either way as a US citizen, so if you're resident in the US you at least get rid of any UK paperwork too.
I've thought a lot about tax resident status and it is possible to argue a domicile of choice in Texas even though I would have a permanent residence in the UK and live there more than 6 months a year, have been born there along with my parents, and be receiving 2 UK private pensions and an OAP. However, we both really identify with England and if our son didn't live here in Texas we would definitely go back permanently.

Health insurance in the US will not change for us as I have retiree insurance through my previous employer until I get to Medicare age (65).

I hate dealing with the health insurance folks, even though we have good insurance and are fairly fit. Out of pocket last year it cost us ~$9,600, and it is a LOT of paperwork. In fact I still have written appeals pending for my wife and I for $1,500 of charges from a colonoscopy we each had, which turned out to be from false positive results from a routine fecal occult blood test. Even though I checked that the doctor, facility and anesthetist were all "in-network", one of the 2 labs he used were not in-network so we are on the hook for the full charges for those tests of $1,500.

For our situation there won't be a lot of difference in the taxes we pay, judging from the scenarios I have run. This is because our income comes approximately 60/40 from my pensions and joint account investments, so this year I have removed my name from all our joint accounts so that when we file in the UK we will each receive the full tax free allowances and we will each not be outside of the 20% tax bracket, plus each person gets the first ~$17,000 of cap gains, free of tax whereas we pay 15% on all cap gains in the US (with our situation).

Also, by the time we start drawing on our retirement savings it will all be from ROTH accounts which are tax free in both countries.
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Old Feb 25th 2014, 2:38 am
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Default Re: Six Months in Each Country?

Originally Posted by Boiler
US Residency does not preclude a UK DL, you just have to comply with the UK requirements.
First there is no UK DL, Northern Ireland has its own rules different from England.

As a US resident you can hold a British driving licence but you cannot obtain or renew a British driving licence. That is to say if you are a British (England&Wales) resident and obtain a British driving licence you don't lose it when you become a US resident. And they don't need renewing until you reach age 70, only the photo expires at ten years, not the licence. You can't renew the photo as a non-resident, but if you hold an unexpired licence (you are under 70 years of age) you can renew the expired photo when you so become a UK resident again - even if the photo has been expired for years and years, and even if you are only a temporary resident. You do not need to, should not, must not, notify DVLA of any new address unless the address is in the UK.

Unlike England, Florida is totally geared up for seasonal residents. Buying car insurance for the months (part months are same price as whole months) you actually use the car seasonally is very common. And as dual citizen you can change your "permanent" residence twice a year if you like. And hold both UK and Florida DLs perfectly legally.

As to UK car insurance though, because of the "no claims bonus" or whatever they call it then it is cheaper to pay all year round UK car insurance than on and off (which they don't really understand anyway).

If you are going to internationally snowbird your USA place will need to be in a gated community with a proper garage for the car for security reasons (unless you are planning on urban apartment). No problem finding a decent condo bungalow or apartment in Florida for USD100K, or a really nice one for USD200K

Until your wife becomes a UKC she will need to spend her time 51%US/49%UK never staying in UK more than six months continuously AND less than six months in any every tax year (5 April). Do not lose count of the days and screw up on this, the penalties are draconian!

There are couples where one spouse is 51%/49% US/UK and the other is 49%/51% meaning they spend 98% of each year together. So to speak.

So basically the nonsense that works best is that every half year you cross the pond with the declared intention of settling permanently, and after six months you change your mind and declare the other way. There is no law against changing your mind as often as you please (trust me as a woman from the hippie era I know this!). As long as you stick to your story you will be fine. Just don't talk to any British social workers or health visitors (was district nurse), they are nothing but trouble modernly - you may have read the news (warning, don't read this article on a full stomach)
http://www.dailymail.co.uk/news/arti...ck-carers.html

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Old Feb 25th 2014, 4:30 pm
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Default Re: Six Months in Each Country?

Originally Posted by durham_lad
I've thought a lot about tax resident status and it is possible to argue a domicile of choice in Texas even though I would have a permanent residence in the UK and live there more than 6 months a year, have been born there along with my parents, and be receiving 2 UK private pensions and an OAP. However, we both really identify with England and if our son didn't live here in Texas we would definitely go back permanently.
I think the key point is that you're a resident in one country and a visitor in another. You keep saying "resident" in two countries, you can't do that for a variety of legal and tax reasons.

The tax treaty talks about your "centre of vital interests" so if you wanted you could file an 8833 with your 1040 and state under article 4 of the tax treaty you are resident in Texas and list your reasons why - however that could be used against you if you aren't careful what you put on it. Or vice versa, you do the same thing with HMRC if you are resident in the UK.

I hate dealing with the health insurance folks, even though we have good insurance and are fairly fit. Out of pocket last year it cost us ~$9,600, and it is a LOT of paperwork.
But it gets even worse if you're on a travel insurance plan, trust me I have personal experience of it. Ended up in hospital, they tried to defraud the insurance company, got that sorted out eventually and then after the first use they yanked the plan. Which is why I suggest staying resident in Texas. The NHS may charge you but the amount of dicking around will be significantly less.

In fact I still have written appeals pending for my wife and I for $1,500 of charges from a colonoscopy we each had, which turned out to be from false positive results from a routine fecal occult blood test. Even though I checked that the doctor, facility and anesthetist were all "in-network", one of the 2 labs he used were not in-network so we are on the hook for the full charges for those tests of $1,500.
I put down I had insurance, so the ER dumped the entire day's charges on my insurance company for uninsured people, thinking I would never see the bill - I did because it was travel insurance and I had to make the claim personally, so their accounts dept. sent the bill to my US address. Ooops.

Also, by the time we start drawing on our retirement savings it will all be from ROTH accounts which are tax free in both countries.
Are Roth IRAs recognized as tax shelters in the UK? Hmm... didn't know that.
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Old Feb 25th 2014, 4:34 pm
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Default Re: Six Months in Each Country?

Originally Posted by holly_1948
Unlike England, Florida is totally geared up for seasonal residents.
Yes I'm bemused by the fact that Canadians can get a one-year DL in Florida with no evidence other than to prove they're Canadian and have an address in Florida. It says in 8 CFR 214.2(b) that Canadians can stay for a year, which 99.99% of Canadians and CBP inspectors don't know, but apparently Florida knows this.

If you are going to internationally snowbird your USA place will need to be in a gated community with a proper garage for the car for security reasons (unless you are planning on urban apartment). No problem finding a decent condo bungalow or apartment in Florida for USD100K, or a really nice one for USD200K
I think the more typical way is to buy a condo apt. I know people who have RVs and they just leave stuff in storage down there too or take the valuables out of their house and put them in storage.
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Old Feb 25th 2014, 5:02 pm
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Default Re: Six Months in Each Country?

Originally Posted by Steve_
I think the more typical way is to buy a condo apt. I know people who have RVs and they just leave stuff in storage down there too or take the valuables out of their house and put them in storage.
While not in Florida, my mom is in Palm Springs which see's a lot of Canadian's as well, and that seems to be what most do. Her neighborhood goes from a bustling community full of people, to a virtual ghost town by end of June, but she lives there year round (american) and the others that do, keep a good eye out on the area and report anything odd or out of place.
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Old Feb 25th 2014, 5:20 pm
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Default Re: Six Months in Each Country?

Originally Posted by Jsmth321
While not in Florida, my mom is in Palm Springs which see's a lot of Canadian's as well, and that seems to be what most do. Her neighborhood goes from a bustling community full of people, to a virtual ghost town by end of June, but she lives there year round (american) and the others that do, keep a good eye out on the area and report anything odd or out of place.
A couple I know live in a condo in Fort Lauderdale and their building is very quiet from May to October because many, perhaps more than half, of the owners are Canadians.
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Old Feb 26th 2014, 2:44 am
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Default Re: Six Months in Each Country?

Originally Posted by Steve_
I think the key point is that you're a resident in one country and a visitor in another. You keep saying "resident" in two countries, you can't do that for a variety of legal and tax reasons.

The tax treaty talks about your "centre of vital interests" so if you wanted you could file an 8833 with your 1040 and state under article 4 of the tax treaty you are resident in Texas and list your reasons why - however that could be used against you if you aren't careful what you put on it. Or vice versa, you do the same thing with HMRC if you are resident in the UK.
I said I would choose to be domiciled in the UK, but whatever the terminology, I will be taxed as a UK resident for the "tie-breaker" reasons I gave above.

http://www.treasury.gov/resource-cen...ts/teus-uk.pdf

If, however, a person is resident in both Contracting States under their respective taxation laws, the Article proceeds, where possible, to use tie-breaker rules to assign a single State of residence to such a person for purposes of the Convention

Originally Posted by Steve_
But it gets even worse if you're on a travel insurance plan, trust me I have personal experience of it. Ended up in hospital, they tried to defraud the insurance company, got that sorted out eventually and then after the first use they yanked the plan. Which is why I suggest staying resident in Texas. The NHS may charge you but the amount of dicking around will be significantly less.
Originally Posted by durham_lad
Health insurance in the US will not change for us as I have retiree insurance through my previous employer until I get to Medicare age (65).
I don't understand why you keep going on about travel insurance. I won't need it. My Health Insurance through my former employer in Louisiana will still be in force, regardless of where I am resident as it is a PPO plan out of Louisiana that has world wide coverage with "in-network" doctors and hospitals in all the countries I'm likely to visit, including Texas.


Originally Posted by Steve_
Are Roth IRAs recognized as tax shelters in the UK? Hmm... didn't know that.
Yes, they are, I'm certain of that.


http://www.treasury.gov/resource-cen...ts/teus-uk.pdf

page 63 states,

Thus, for example, a distribution from a U.S. "Roth IRA" to a U.K. resident would be exempt from tax in the United Kingdom
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