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placnx

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Everything posted by placnx

  1. The problem is that as both the treaty and the technical explanation make clear, the credit is allowed but limited by US law to foreign tax paid on foreign-source income. I have yet to discover how someone without foreign-source income can override US law when the treaty states after article 25(3): "Notwithstanding the preceding sentence, the determination of the source of income for purposes of this Article shall be subject to such source rules in the domestic laws of the Contracting States as apply for the purpose of limiting the foreign tax credit." These are links for the 1996 US Model Tax Treaty and its Technical Explanation: https://home.treasury.gov/system/files/131/Treaty-US-Model-1996.pdf https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-1996.pdf These can be compared to the specific versions for Thailand. I have not done this comparison yet. Anyway, you should read page 31 of the NY Bar report 1313 which addresses the specifics of the Thai and Indian treaties with the US regarding allowable credit.
  2. The problem is that as both the treaty and the technical explanation make clear, the credit is allowed but limited by US law to foreign tax paid on foreign-source income. I have yet to discover how someone without foreign-source income can override US law when the treaty states after article 25(3): "Notwithstanding the preceding sentence, the determination of the source of income for purposes of this Article shall be subject to such source rules in the domestic laws of the Contracting States as apply for the purpose of limiting the foreign tax credit." These are links for the 1996 US Model Tax Treaty and its Technical Explanation: https://home.treasury.gov/system/files/131/Treaty-US-Model-1996.pdf https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-1996.pdf These can be compared to the specific versions for Thailand. I have not done this comparison yet. Anyway, you should read page 31 of the NY Bar report 1313 which addresses the specifics of the Thai and Indian treaties with the US regarding allowable credit.
  3. https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion You can deduct up to $120K of foreign earned income from total income on US taxes. So if you earned that in Arabia for example, then that could be taxable in Thailand besides the other income reported (and taxed) in the US.
  4. France also taxes on worldwide income of residents.
  5. Then what article of the tax treaty allows me to allocate US-source income to foreign-source income in form 1116? I looked through the whole treaty and don't see any clause to cite in form 8833. The quote from the 8833 instructions (see original post) means a tax treaty with a provision for overriding IRS rules, and that would be for example re-sourcing. Other treaty provisions might give the country where the US citizen resides the power to tax some kind of income that would normally be taxed in the US under IRS rules. That is the purpose of form 8833, to cite the relevant provision in the particular treaty in question. It could be that IRS being understaffed does not check back to see whether re-sourcing is provided in the Thai-US tax treaty and thus an 8833 claim is not challenged. Most treaties provide re-sourcing.
  6. Small modular reactors would be a good solution for Thailand. As of 2020 there were many ideas. Some are small enough to fit the modules in shipping containers. There is some construction to prepare the site, of course, but the complications of a major reactor are avoided. SMR_Book_2020 table of contents.pdf SMR_Book_2020.pdf
  7. Americans cannot get a tax credit in the US if they have no foreign income. For them, the alternative would be to get a credit in Thailand for taxes paid in the US. Then Thailand may get nothing. Credit on US taxes is complicated because the Thai-US tax treaty does not contain a provision for what is called re-sourcing, unlike other US treaties negotiated in the same time frame. Strange, since over the years there were model treaties containing these rules. It seems like it is time for overhaul of the Thai-US treaty. Under many US tax treaties this re-sourcing means that for income tax paid to the foreign country under its rules, the income reported on that foreign tax return can be considered foreign income for the purposes of calculating the US foreign tax credit, even though in reality the US taxpayer did not have any income in that country or any other foreign country.
  8. Maybe "unpatriotic". If there were just a few, they would be called "self-hating Jews".
  9. Australia is an example of settler-colonialism. After years of maltreating the aboriginal population, It seems that they are making an effort to make amends. Let's hope that Israel wakes up and puts Smotrich and Ben Gvir and many others in prison for life. Actually, Smotrich should get multiple life sentences and the body should be kept in lockup until all sentences have expired.
  10. “Palestine will be free from the river to the sea” has a non-violent meaning. Many in the movement for Palestinian rights had given up on the two-state solution because there are so many settlers in the West Bank and East Jerusalem. For them, the answer is to end apartheid in Israel and the Occupied Territories and to accept the one-state solution. I think that this is naive. Perhaps they should be saying “Palestine will be free from the river to the sea. End Apartheid Now”, so that Australians and others do not mix this up with true anti-semitism. The founder of Human Rights Watch made an important comment about the anti-semitiam issue in discussing Gaza yesterday: https://edition.cnn.com/videos/world/2024/05/26/gps-0526-icc-charges-against-israel.cnn https://en.wikipedia.org/wiki/Aryeh_Neier
  11. The Home Office should get creative and tow their vehicles. If they don't want to pay, then why don't they use the Underground. But of course they wouldn't want to pay the "tax", must ride for free. Those arrogant colonial scofflaws!!
  12. The Home Office should get creative and tow their vehicles. If they don't want to pay, then why don't they use the Underground. But of course they wouldn't want to pay the "tax", must ride for free. Those arrogant colonials!
  13. Maybe the TM30 dates to 1979, but before it only practically concerned hotels. There was no enforced requirement for foreigners living at home to report themselves until after the last coup.
  14. Living in Chiang Mai, I found that the practical solution is to set up online filing for TM30, then file whenever staying overnight in a hotel or returning from abroad. Online filing is quite easy once you get the hang of it
  15. British Airways is IAG, #23 on the list.
  16. There is a new airline called Starlux. It flies from Chiang Mai and Bangkok to LAX, SFO, SEA. They have a deal with Alaska Airlines for onward flights from Seattle. https://en.wikipedia.org/wiki/Starlux_Airlines Connection time may depend on the days selected. I didn't check RT, OW was Bht 20000 for economy and 40000 for premium economy. The planes are new Airbuses.
  17. As you say, this is from November. Today there's a BBC News program "Eye Investigations: My War". At the end of the program the reporter for BBC Arabic Adnan El Bursh and his team are leaving Gaza on February 10th. This program will run again at 18:30 today. Excellent. The journalist in your clip left Gaza on December 5th, https://www.bbc.com/news/world-middle-east-67592794 He posted this after leaving, in memory: This journalist, Samer al Daqqa, working for al Jazeera, and his team was bombed on December 15th. https://en.wikipedia.org/wiki/Samer_Abu_Daqqa I will now stop reading and commenting on these Gaza war threads until something signficant happens, for example, an indictment of war criminals or a significant ceasefire. The readership of these threads is just too small, and the abusive posting of propaganda makes rational discussion impossible.
  18. No, nobody was being killed until the tank fired and killed them.
  19. BBC seems to have just recently gotten a freelance journalist Gazan to supply video and comment.
  20. They were in the Gulf long before WW 1 https://en.wikipedia.org/wiki/Persian_Gulf_Residency So that part of Arabia is not relevant since Turks were not in control there. Brits never occupied what became Saudi Arabia. They just installed a Hashemite to rule in Mecca to replace the Turk's man.
  21. Not B.S. After the huge number of target identifications, there is only minutes or seconds to authorize the bombing. No need anymore for seniors or legal people to be consulted.
  22. This is Israeli media. Reputation here: https://mediabiasfactcheck.com/972-magazine/
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