The sheer cheek...

[noggins]

Also if they come back to the UK arent they bringing their millions with them?

[dyqik]

... In my own circle of Friends I know a UK couple that have lived in the USA for over 20 years, have green cards, and have retired having earned millions. Both maintain their UK passports... why? So in the event of declining serious health that isn't covered by their US insurer, they can hot-foot it back to the UK for treatment on the NHS. They can get UK consular assistance if needed. They will benefit from systems they haven't paid into for over 20 years....

Not in principle they won't

Accessing Free State Healthcare
The National Health Service only provides free hospital treatment for people who lawfully live on a settled basis in the United Kingdom. People who do not normally live on a settled basis in this country are not automatically entitled to NHS hospital treatment free of charge – regardless of their nationality or whether they hold a British Passport or have lived and paid National Insurance contributions and taxes in this country in the past.

Source: https://www.essexlmc.org.uk/wp-content/ ... tizens.pdf
This is a concise summary, wordier expressions elsewhere say the same.

All it takes to establish settled status for a UK passport holder/citizen is renting a flat and flying back to live in it for over half a year. That's far cheaper than long term out-of-pocket healthcare in the US.

[TopBadger]

All it takes to establish settled status for a UK passport holder/citizen is renting a flat and flying back to live in it for over half a year. That's far cheaper than long term out-of-pocket healthcare in the US.

I doubt it would even take 6 months for eligibility - in principle and in practice are different things. Turn up with a UK passport and an address to send appointments too and I doubt further checks would be undertaken.
Of course, with NHS waiting lists where they are it may take longer than 6 months for actual treatment depending on the severity of the condition.

[TopBadger]

Also if they come back to the UK arent they bringing their millions with them?

If permanently then possibly, I don't how they have it squirreled away. if temporarily then maybe not.

[dyqik]

Also if they come back to the UK arent they bringing their millions with them?

If permanently then possibly, I don't how they have it squirreled away. if temporarily then maybe not.

Things like Social Security and 401K retirement funds will pay out from the US to UK accounts (and vice versa for pensions etc.)

[Bewildered]

Honestly life is hard and complicated enough working abroad. Please don’t campaign to make it harder.

[TopBadger]

Honestly life is hard and complicated enough working abroad. Please don’t campaign to make it harder.

I get that... I'm imagining a scheme that would impact only the top small percentile and leave the rest unmolested. Perhaps such a thing is pure folly.

[El Pollo Diablo]

I've dumped a little tiff over in the pit.

[dyqik]

Honestly life is hard and complicated enough working abroad. Please don’t campaign to make it harder.

I get that... I'm imagining a scheme that would impact only the top small percentile and leave the rest unmolested. Perhaps such a thing is pure folly.

You could take the US approach, and tax worldwide income for your citizens, with exemptions for the first couple of hundred thousand in income that's also taxed overseas.

[dyqik]

All it takes to establish settled status for a UK passport holder/citizen is renting a flat and flying back to live in it for over half a year. That's far cheaper than long term out-of-pocket healthcare in the US.

I doubt it would even take 6 months for eligibility - in principle and in practice are different things. Turn up with a UK passport and an address to send appointments too and I doubt further checks would be undertaken.
Of course, with NHS waiting lists where they are it may take longer than 6 months for actual treatment depending on the severity of the condition.

It doesn't take 6 months to reach residency for tax purposes. All that's required is intent to reside for more than 6 months. The 6 month rule is applied after the fact to determine tax status for your tax return.

Here it could be applied after the fact to determine if you need to pay. That would get complicated if you didn't survive the treatment though.

[dyqik]

Dan Neidle wrote an article on the subject of citizenship-based taxation a couple of years ago, and was not a fan. His basic point was that the disadvantage of exposing millions of people to complex dual taxation, when they had become expats for perfectly sensible reasons, would outweigh any advantages to be gained by targetting the small minority who leave to avoid tax. I don't feel expert enough to have an opinion myself, but I generally like Dan Neidle's stuff.

Interesting article...

But the main example of the horrors of being a UK/US citizen in particular seem to stem from the US rules being applied. (e.g. USA doesn't view ISA gains as tax free).

A UK citizen tax need not do it exactly the same way...

To target the ultra wealthy you could just set generous thresholds... >£250k income.

The US already does this. The effort of filling isn't really any worse than the effort everyone already has to do to file their tax returns each year in the US anyway (takes me about two hours). Obviously this is way more effort than the average Brit has to put into tax returns (zero).

Lets not also forget that no-one is forced to be a dual national. Don't like the rules, then pick one and renounce the other.

I don't believe it's possible to actually give up British citizenship that you got by birth. You can ditch the passport and tell the home office that you renounce it, but you remain eligible for a passport when you want it.

[dyqik]

Dan Neidle wrote an article on the subject of citizenship-based taxation a couple of years ago, and was not a fan. His basic point was that the disadvantage of exposing millions of people to complex dual taxation, when they had become expats for perfectly sensible reasons, would outweigh any advantages to be gained by targetting the small minority who leave to avoid tax. I don't feel expert enough to have an opinion myself, but I generally like Dan Neidle's stuff.

Interesting article...

But the main example of the horrors of being a UK/US citizen in particular seem to stem from the US rules being applied. (e.g. USA doesn't view ISA gains as tax free).

A UK citizen tax need not do it exactly the same way...

To target the ultra wealthy you could just set generous thresholds... >£250k income.

The US already does this. The effort of filling isn't really any worse than the effort everyone already has to do to file their tax returns each year in the US anyway (takes me about two hours). Obviously this is way more effort than the average Brit has to put into tax returns (zero).

The US exemption is $130k this year, so less than my salary, but then I wouldn't earn nearly as high a salary in the UK. I think a UK university professor would be on the edge, depending on the exchange rate.

[monkey]

I don't believe it's possible to actually give up British citizenship that you got by birth. You can ditch the passport and tell the home office that you renounce it, but you remain eligible for a passport when you want it.

Yeah, you can give it up, but you can ask to have it back again. I imagine there's paperwork involved before you can have a passport again though. And I bet the Home Office can go "Nope, don't like you" if you're a wrongun.

[TopBadger]

I don't believe it's possible to actually give up British citizenship that you got by birth. You can ditch the passport and tell the home office that you renounce it, but you remain eligible for a passport when you want it.

Perhaps I missed something, but it seems anyone can renounce

https://www.gov.uk/renounce-british-nationality

One of the conditions is that you have to have another nationality to use (you can't leave yourself stateless).

You can also resume nationality after renouncing, but there are many checks, and in the case of a citizenship based taxation then it would obviously be prudent to make the rules such that you have to backpay all the taxes you missed out on paying whilst renounced before you can resume.

[IvanV]

Dan Neidle wrote an article on the subject of citizenship-based taxation a couple of years ago, and was not a fan. His basic point was that the disadvantage of exposing millions of people to complex dual taxation, when they had become expats for perfectly sensible reasons, would outweigh any advantages to be gained by targetting the small minority who leave to avoid tax. I don't feel expert enough to have an opinion myself, but I generally like Dan Neidle's stuff.

It is an excellent article, and very nicely written. The point he makes about the potential to tax accrued capital gains on departure is a good one.

I could rant for a long time about the iniquities of capital gains tax in this country, and here is another one.

[snoozeofreason]

<snip>

The US already does this. The effort of filling isn't really any worse than the effort everyone already has to do to file their tax returns each year in the US anyway (takes me about two hours). Obviously this is way more effort than the average Brit has to put into tax returns (zero).

<snip>

I think that nowadays, the only Brits who could legally get away with putting zero effort into their tax returns would be those whose financial affairs are very simple indeed. I am no high-roller, but mine take a certain amount of thought, and I am very grateful that I had the good sense to marry someone who works in tax (although, I suppose that if Mrs Snooze wasn't in that line of work, I might not realise that some thought was needed - and might or might not get caught out on it!).

[shpalman]

Honestly life is hard and complicated enough working abroad. Please don’t campaign to make it harder.

I get that... I'm imagining a scheme that would impact only the top small percentile and leave the rest unmolested. Perhaps such a thing is pure folly.

I'm imagining a scheme in which it's a hassle to prove every year that we're not in the top small percentile, while those who are would find ways to get around it anyway.

My Italian tax return does take some effort to deal with but it's mostly pre-compiled.

I remember when the UK changed the rules on resident non-doms and Valentino Rossi suddenly had to explain why he wasn't actually paying tax anywhere; his public image here took a bit of a knock for that. https://en.wikipedia.org/wiki/Valentino ... dance_case

[shpalman]

Honestly life is hard and complicated enough working abroad. Please don’t campaign to make it harder.

I get that... I'm imagining a scheme that would impact only the top small percentile and leave the rest unmolested. Perhaps such a thing is pure folly.

I'm imagining a scheme in which it's a hassle to prove every year that we're not in the top small percentile, while those who are would find ways to get around it anyway.

My Italian tax return does take some effort to deal with but it's mostly pre-compiled.

I remember when the UK changed the rules on resident non-doms and Valentino Rossi suddenly had to explain why he wasn't actually paying tax anywhere; his public image here took a bit of a knock for that. https://en.wikipedia.org/wiki/Valentino ... dance_case

The EU rules on financial transparency or whatever would have helped with this hypothetical sort of thing, but some rich c.nts did a Brexit to stop the UK having to follow those.

[noggins]

The US foreign earned income exclusion only applies to wages.

Not pensions, dividends, interest, currency fluctuations or capital gains.

CG threshold is 250,000 USD / 500,000 USD for a couple. ie a few years appreciation of a modest london suburban house.
Trying to claim the couples amount will enmesh your non-US spouse in the US tax system for life. The wider point is that the whole UK housing market is set up around the fact that normal people dont pay CGT on normal house sales, but the yanks don't care.

Furthermore the US rules and forms are written by a patriotic imbecile who cant really grasp that someone might not want to live in the USA.
It should take 5 minutes to fill in, instead its a multi-hour pain in the arse exacerbated by the w.nkers changing it every year.

There are even points that nobody actually understands - eg Its arguable that every citizen US abroad with a foreign currency mortgage should be reporting theoretical currency gains as income.

In conclusion, anyone holding up the US as evidence that citizenship based taxation is desirable and simple is a f.cking imbecile.