I don’t see how that’s practical when places like Monaco exist and are happy to welcome people who really don’t like paying taxes. It would have to be a worldwide effort.
US taxpayers must pay tax on global income. If we want to explore a wealth tax, securities ownership and transactions take place within the US jurisdiction. Your brokerage or the clearinghouse can send another form to the IRS for public equity, Carta or whomever manages the cap table can do so for private equity.
Unless you're only going to hold investment assets in Monaco while trying to relinquish US citizenship and not pay an exit tax? I suppose if you pull up stakes, don't pay US income tax, and don't step foot financially in the jurisdiction, you might be able to avoid this depending on your window of time between that decision and death.
What do you mean: Taxing unrealized profits (assets that could be sold at a profit, but haven't been sold)? Or taxing foreign entities without a tax treaty?
Again, it’s just a construct in a system. The rules can be changed at by time, and a piece of paper isn’t going to matter to a nation state political system.
I have a trust (several, actually), and I still know better that it is permitted to exist in its current incarnation, not a perpetual, immutable right or iron clad guarantee.
Yes, sure - but Monaco, Luxembourg, Switzerland, Liechtenstein etc is definitely not going to adopt the rules just because US did.
They will do the exact opposite - triple down, take this new enormous opportunity and develop hundreds of new ways to offer US people safe haven for their assets. Thousands upon thousands of new startup consultancies charging just few % fees will be founded and every wealthy person in the US will have to turn off their phones and stop checking the inbox because of all that cold calling and emailing these people will do.
Switzerland conceded to US FATCA reporting. Whomever has the most force wins. I don’t blame you if you’re wealthy and you take a calculated risk strategy (can’t take the monkey brain out of the human), just don’t cry when you fail at evasion.
Major corporations can’t withstand minor ransomware operators. What makes you think these jurisdictions can withstand superpower nation state efforts?
Reporting is nice but doesn't change anything about the problem. OK so the US knows you are a beneficiary of a trust fund in Switzerland - what can they do about it? It's not you, so they can't tax the wealth. They can tax the income you get from that, but that means the wealth tax mission has failed.
Unless you're only going to hold investment assets in Monaco while trying to relinquish US citizenship and not pay an exit tax? I suppose if you pull up stakes, don't pay US income tax, and don't step foot financially in the jurisdiction, you might be able to avoid this depending on your window of time between that decision and death.