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Australians who take out citizenship in another country . . .

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Old Jun 10, 2004, 2:34 am
  #46  
 
Join Date: Nov 2000
Location: Sydney, Aus
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Originally Posted by davistev
You should be fine but if you bring the little ones over to Australia when they are older (say 16 years old), then they may not be granted the youth study allownce because of the 2 year residency rule.
HA ! Who is actually elligible for these days anyway ? The kid's parents have to earn a very low salary ...
ozzie is offline  
Old Jun 10, 2004, 2:52 am
  #47  
 
Join Date: Apr 2004
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And lets not forget that once this mini dual citizenship holder starts working he has to pay US taxes whereever he is in the world. US citizens pay US tax on their worldwide income, there is no such thing as a residency test like in Aust or the UK.
747sardine is offline  
Old Jun 10, 2004, 4:45 am
  #48  
 
Join Date: Apr 2002
Location: Sydney
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Originally Posted by alect
Thanks eamus. Exactly the situation we are facing. I am Aus citizen, mrs alect is seppo, and mini-alect due to arrive in Dec will have both - in fact we will have to get mini-alect both passports within 6 months of birth as he/she will be accompanying us on our RTW and will need US passport to exit/enter US and Aus passport for easier/cheaper entry into Aus.
heh - we are facing only a slightly different one: mini-aura will (soon) be born in syd... hmm, i guess there'll be no fee for joining up mini-alect to QFFF, but a fee for mini-aura... sigh.
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Old Jun 10, 2004, 4:52 am
  #49  
 
Join Date: Aug 2000
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Originally Posted by 747sardine
And lets not forget that once this mini dual citizenship holder starts working he has to pay US taxes whereever he is in the world. US citizens pay US tax on their worldwide income, there is no such thing as a residency test like in Aust or the UK.
True however there are some countries (including Australia) that have tax treaties with the US so you don't have to pay double taxes... of course there are alot more that don't have treaties...
ANDREWCX is offline  
Old Jun 10, 2004, 5:53 am
  #50  
 
Join Date: Nov 2000
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Originally Posted by ANDREWCX
True however there are some countries (including Australia) that have tax treaties with the US so you don't have to pay double taxes... of course there are alot more that don't have treaties...
That's correct. And it only applies to federal taxes, not state. The US has much lower federal income tax than in either the UK or Australia. The biggest issue comes with two things:

1. Capital Gains Tax

In the US, your PPR (principal place of residence) is not exempt from capital gains tax. Therefore, as you've not paid tax on selling your house in Australia or the UK (as the case may be), you would be liable for CGT in the US.

2. Pensions / Superannuation

This is the biggy, and is a right pain in the a*se. The US does not recognise any international pension / superannuation funds. Therefore if you say have a UK pension, they will EACH YEAR asses CGT on the increase in value of your UK pension fund from the last year. B*stards. Reason enough alone to give up US citizenship IMHO.
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Old Jun 10, 2004, 6:33 am
  #51  
NM
 
Join Date: Aug 2001
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Originally Posted by ozzie
1. Capital Gains Tax

In the US, your PPR (principal place of residence) is not exempt from capital gains tax. Therefore, as you've not paid tax on selling your house in Australia or the UK (as the case may be), you would be liable for CGT in the US.
Yes, but the interest paid on the loan for you PPR is deductable against your income tax, so it is a bit of swings and roundabouts. In the US you gain each year you pay interest on your loan, and then get hit with capital gain. In Australia you can't claim the interest deduction, but are exempt from CGT.
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Old Jun 10, 2004, 7:29 am
  #52  
 
Join Date: Dec 2003
Location: Nashvegas
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Taxes

Originally Posted by NM
Yes, but the interest paid on the loan for you PPR is deductable against your income tax, so it is a bit of swings and roundabouts. In the US you gain each year you pay interest on your loan, and then get hit with capital gain. In Australia you can't claim the interest deduction, but are exempt from CGT.
In the US you can not only deduct mortgage interest from Federal income tax, you can also carry forward a certain amount of the capital gains on the property ($500K or thereabouts I think) more or less endlessly to your new PPR. Well, until you die, but that is still a significant benefit by deferral. Not as good as the exemption in Oz, but better than an upfront kick in pants. On a cash basis the US system makes home ownership considerably more affordable.

I am a bit surprised by ozzie's comment about US non-recognition of foreign super/pension funds. I asked my tax accountant about this specifically and he said there was nothing to declare (or claim by the way of losses).
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Old Jun 10, 2004, 9:02 am
  #53  
 
Join Date: Nov 2000
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Originally Posted by eamus
In the US you can not only deduct mortgage interest from Federal income tax, you can also carry forward a certain amount of the capital gains on the property ($500K or thereabouts I think) more or less endlessly to your new PPR. Well, until you die, but that is still a significant benefit by deferral. Not as good as the exemption in Oz, but better than an upfront kick in pants. On a cash basis the US system makes home ownership considerably more affordable.

I am a bit surprised by ozzie's comment about US non-recognition of foreign super/pension funds. I asked my tax accountant about this specifically and he said there was nothing to declare (or claim by the way of losses).
I am no tax expert This is just what I was told by my own tax adviser when we were discussing the issue .... it's not currently an issue for me, but it may be in the future so I guess I'll seek further advice then .....
ozzie is offline  


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