TLDR: are there good firms who can advise on international tax strategy or at least comprehensive EU/US tax strategy? I think E&Y may be one to check out tho I don’t know how many E&Y people/departments/offices one may need to engage!
My main focus right now would be where I will likely be spending time over the next few years: US, Germany, UK, Portugal (if I apply for a GV) and keeping abreast of the best EU countries to minimize tax. I am concerned mostly with personal tax (not business) in re: to capital gains, wealth tax or similar, worldwide-income tax & estate taxes.
I am a US citizen and am familiar with the arcane US tax system. This is split between state/local and federal/national (IRS) taxation. Essentially the feds tax you on your worldwide income (with a potential exemption amount) and if you are “resident” elsewhere in some parts of the world there are treaties that help avoid double-taxation in theory. Thus far, this should be straight forward and if you spend 183+ days/year in US you know you owe US taxes…
Now you have some states (CA) that are fighting to introduce their own measures (60 day rule) so presumably you could wind up “double-taxed” without ever leaving the US because you trigger tax in more than one state. And of course it’s a political debate as to how much state tax you can deduct from your federal liability.
The US has been among the few countries to tax its citizens on worldwide income tho some countries (Canada) are proposing similar rules. So presumably there will be a trend to tax worldwide income among citizens and/or permanent residents. Of course rule-makers may also decide to target specifically naturalized folks not natives, as this is more politically tenable in theory. I am thinking the EU might actually be less friendly to this form of taxation because of the complexities of EU denizens moving between countries.
Then you have so-called wealth taxes as a trend, where you are supposed to determine your net worth and pay a tax based on that. I am thinking this is also a trend. How this is implemented I am not sure - and would this only apply when you are “tax resident” in said territory? Only for citizens? I think I saw that only 3-4 EU countries have wealth taxes as of the moment.
I assume estate taxes only apply where you are most recently resident? These can be quite expensive for one’s heirs.
Somewhere I saw a comment that while the US makes it relatively difficult to give up citizenship, some countries like Argentina don’t let you!
So what is the environment like in the EU? Does the EU tax citizens directly like the IRS taxes citizens of states? Is this a potential for the future? Could the EU pressure member-states into implementing more draconian taxation? Do all EU countries have agreements in place to avoid multi-jurisdiction taxation? Are member-countries harmonious in their rules for tax residency? Portugal seems straightforward with their 183 day rule, unless I am ignorant of other triggers. I know the UK fwiw has a whole flow chart about how one triggers tax residency so you can easily trigger it if for example you work for, I think it was, 2 months while in the UK and then spend no more time there.
One thing I do know is you will have tons of work as a tax adviser for many years to come!