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Income Tax
Digital Nomad Tax Questions Answered by a U.S. Tax Attorney
FEIE requires 330 days in a foreign country in a 12 month period. Self-employed person still have to pay self-employment tax (15.3%).
Some states such as California does not recognize FEIE.
Self Employment
Self Employment Tax Deduction
If you pay selfâemployment tax on your net earnings from selfâemployment, you deduct one half of the tax as an adjustment to gross income, even if you do not itemize your other deductions
The deduction for oneâhalf of your selfâemployment tax is not a business expense, but a personal one. It does not reduce your profits on which you pay income taxes. The deduction reduces qualified business income for purposes of the QBI deduction (explained earlier in this chapter). If you opted to defer part of your 2020 selfâemployment tax, 50% of the deferred amount must be paid by December 31, 2021; the other 50% is due by December 31, 2022.
First year expense
To qualify for the election, your total equipment purchases for the year cannot exceed a set dollar amount. For 2021, you can claim the expensing deduction only if your total purchases are no more than $3,670,000. The dollar limit phases out on a dollarâforâdollar basis for total purchases over $2,620,000.
Retirement Planning
401K match -HSA -401K max -Traditional IRA -Roth IRA
Brokerage
Non-US investorâs guide to navigating US tax traps
Avoid either/both US/non-US domiciled ETFs. They are taxed heavily due to PFIC. QEF election is complex.
There are no unlimited marital exemption for NRA spouse ($60,000).
Solo 401K
Employee contribution is fixed and adjusted based on inflation which is $23K for 2024. Employer contribution is up to 20% of salary up to $69K for 2024.
Balance above 250K has an additional filing requirement.
Solo 401(k) Contribution Calculator
Traditional 401K/IRA
Some countries treat traditional IRA distributions as capital gains as if it was a taxable brokerage account.
Roth 401K/IRA
Countries that regonized Roth are the followings: Belgium, Canada, Estonia, France, Latvia, Lithuania, Malta, United Kingdom, United States.
Even if one is absolutely planning to retire in one of those countries, the complications from declaring and maintaining the Roth accounts will be non-negligible.
Income from Roth could still count for the qualifying income or a portion of net-worth that affects health-care surcharge or a form of wealth tax, which would likely result in double taxation.
Technically, US-France tax treaty does not mention Roth at all. In other words, it does not formally recognize the Roth.
Most, like Belgium, do not tax the Roth IRA withdrawals but it still uses the income to calculate the tax rate one pays on other sources of income.
Roth provides some flexibility around social security and Required Minimum Distribution (RMD). However, this requires about $10M in the tax deferred accounts. For the most common scenarios, a traditional retirement account is better than a brokerage account and both are better than a Roth IRA account.
For Canada, CRA requires a one-time Treaty Election by including a letter detailing the Roth IRA account balance.
Health Savings Account
HSA is touted as the âTax Trifectaâ. However, it is not recognized by any other country in the world. The yearly contribution is relatively small and it requires lifetime commitment to archiving medical receipts.
Treated as a regular brokerage account, so it will be subject to capital gains tax and exit tax.
Social Security
U.S. International Social Security Agreements
How Early Retirement Affects Social Security
10 years (40 credits) to qualify for free Medicare Part A coverage at age 65 (which would otherwise cost $400+ per month).
In 2016 it takes $1,260 of income to earn one credit (up to four credits maximum per year).
Even if you donât have the 40 credits, it might not matter since you can qualify on a spouseâs (or ex-spouseâs) record if they have the required 40 credits.
By back-calculating things a bit, the lifetime earnings to max out that 90% payout space is $359,520 (for 2016). This could be $35,952 of earnings per year for ten years or roughly $72,000 for five years or around $18,000 for 20 years.
Non-resident Alien
Europeans with us retirement plans
If a non resident aliens withdraws from a 401k without a tax treaty, 30% withholding will be applied. Form 1040NR must be filed to claim the amount that was withheld due to the contributions being ECI.
Even if one is covered by a tax treaty, a broker might not lower the withholding to 0%.
US retirement accounts are always considered US Situs for the US Estate tax, which means that if you die holding more than 60k of assets in a US retirement account, you are looking at up to 40% tax on the account without an Estate tax treaty.
Non-ECI is subject to 30% tax. (Non Effectively Connected Income: gains to a retirement account). EIC is subject to gradual tax bracket rates. (Effectively Connected Income: contributions to a retirement account).
Forms 1040NR takes a long time to process (+6 months)
Non-resident does not have access to the standard deduction.
Tax Treaties
Income Tax
Most developed countries do tax foreign income of residents. United States is the only developed country that taxes foreign income of non-resident citizens.
IRS - United States Income Tax Treaties
US citizen or US permanent resident is to be US resident only if one has substantial presence in the US and/or oneâs habitual abod is in the US.
Pensions and other payments made under the social security legislation of France to a resident of France who is a citizen of the United States shall be taxable only in France.
Estate & Gift
Utilizing Treaties to Eliminate or Reduce the Foreign Investorâs Exposure to the U.S. Estate Tax
The US has estate tax treaties with Australia, Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Netherland, Norway, South Africa, Switzerland, and the United Kingdom.
The US has gift tax treaties (some of which are combined with the estate tax treaty) only with Australia, Austria, Denmark, France, Germany, Japan, and the United Kingdom.
The US had an estate tax treaty with Canada. Although the U.S.-Canada estate tax treaty ceased to have effect with respect to estates of persons dying on or after January 1, 1985, a protocol in the U.S.-Canadian bilateral income tax treaty has far reaching effects upon Canadian individuals owning U.S. situs assets for U.S. estate tax purposes.
US-Canada Tax Strategy and Planning
Income Tax
US company cannot directly employee a Canadian tax resident.
Income tax after deductions are paid to Canada, which is credited against US taxes via FTC. Or, income tax after deductions are paid to US, which is credited against Canada and the rest of the tax is paid to Canada.
One must obtain the certificate of CPP coverage from Canada to be exempt from US FICA taxes
Thereâs no married joint filing for Canada.
Retirement Planning
Employee portion of 401K is not counted towards RRSP contribution limit. Only employer portion of 401K is counted.
RRSP shares contribution limit with employer 401K contribution, which likely means that employer portion of the 401K contribution cannot exceed RRSP limit.
Up to 31,560 for 2024 or 18% of previous year income. Contribution limit can be accrued and it can be withdrawn anytime.
The contribution is not tax deductible in US and it requires FBAR filing because it is a foreign trust for US taxes. Some US states taxes interest income and capital gains from RRSP.
US does not recognize TFSA.
For non-residents of Canada, thereâs a withholding of 25% for the lump sum withdrawal.
Incorporation in US
Both LLC and S-Corp are not recognized in Canada and they are treated as foreign entities which would lead to double taxation. S-corp could avoid double taxation, but compliance is expensive.
Incorporation in Canada
A corporation with a single contractor working for a single client in employer-employee like relationship is considered a Personal Service Business in Canada. This eliminates any benefit of incorporation in Canada. PSB applies to a client rather than the company as a whole. So, having multiple clients doesnât prevent it.