This algorithm is similar to the method often used to find an entry in a paper dictionary. For example, matrix chain ordering can be solved in polylogarithmic time on a parallel random-access machine.
It is good to see someone addressing the special problems of Australian-resident US taxpayers, as normal financial planning is exceedingly difficult for taxpayers caught between two very different systems.
With super, however, there is a ray of hope. The introduction to the article states: Absent bilateral treaty renegotiations, US expats, who are obligated to pay US taxes on their worldwide income, have no other recourse except to trundle through the byzantine tax laws of both countries in order to arrive at a defensible though uncertain position on why Australian superannuation funds should not subject to US taxation.
If there is a defensible position that superannuation accounts are not subject to US tax then, a our Australian government ought to be exhausting every possible avenue to ensure that this position prevails and is publicised among the affected community; and b US taxpayers in Australia should seek out US tax practitioners who are willing to take this position.
As stated in the article, one remedy for this situation is to re-negotiate the tax treaty. After that glimmer of hope, however, the rest of the article is then written from the premise that superannuation is taxable on a US return.
First, the requirement to reduce a balance held in pension mode applies only to account based pensions; those with defined benefit income streams will have their transfer balance cap reduced, but are not required to commute an income stream in excess of the limit.
Under the current rules in Australia I am not required to pay any tax on the earnings or monthly distributions. Glad you found us. The US tax treatment of superannuation is far from clear.
There are tax professionals who take the position that superannuation should be treated as the equivalent of social security — and not taxed on a US return.
The only one I have found is castroandco. Are there any others? I think there is another category of tax professional — the PFIC maximalists. A very important resource would be a list of tax preparers categorised by their approach to super issues.
However, if someone wants to volunteer to construct a list of tax preparers, we would be willing to arrange hosting that list on this site.
Unfortunately, deferred compensation and retirement income streams do not qualify for the Foreign Earned Income Exclusion. I suppose I could always file returns for the last years instead of 3 in order to carry forward my surplus tax credits?
The people who are hurt most by US citizenship-based taxation are those who are trying to comply. Obviously, the choice must be yours. And it is a good idea to collect as much information as possible before you even think about talking to an accountant or tax professional.
I highly recommend reading through the expat tax thread at Isaac Brock. If you do decide to comply, excess foreign tax credits can only be carried forward for 10 years. The whole issue came up for me when I read on my passport renewal document that my details would be sent to the IRS, and I went from there.
Does anyone have a view on the credibility of this position? It appears that a number of people may have taken this position based on the advice.OVERVIEW. With all of the data and tools at their disposal and unprecedented levels of sophistication, criminals are engaging in complex identity fraud schemes .
Check out The Unriddled Complexity of It All by Mark Torgeson on Amazon Music. Stream ad-free or purchase CD's and MP3s now on plombier-nemours.com There is much uncertainty in the “correct” way to include superannuation on a US tax return.
This uncertainty affects not only US citizens and green-card holders living in Australia, but also any Australian citizen or permanent resident currently living in the US who accumulated Superannuation .
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