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bigP

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  1. Joseph, 'Passporting' is the issue at hand here - the mechanism by which a financial service* in one country within the EEA (European Economic Area) can serve a citizen of said country whilst citizen is resident in another EEA member state. The UK ceased to be a 'Contracting Party' to the EEA Agreement back on 31st January 2020, however we are of course in 'transistion' currently so previous rules apply until 31st December 2020. The issue currently lies within the EU solely. The UK has enacted legislation to enable a citizen of an EEA member state to retain access to EEA member financial service* whilst said citizen is resident in the UK post 31st December 2020. Its a bit of a moot legislation from the UK though to be honest, as post 31st December 2020 they could not have stopped the EU from legislating that such EEA citizens could continue to access EEA financial institutions whilst resident in the UK. Sadly, the EU have not yet reciprocated, and so if not resolved a UK Citizen resident in 'Mainland EU' accessing a UK financial service* will have their UK accounts closed as of 31st December 2020. There may be a last minute resolution to this, even in the event of a no deal situation. For a while now the many EU 'family members' of UK banks have been in the process of transferring their UK Citizens' accounts to the recipricol bank in the member state of which the UK Citizen is resident (where possible). Ie HSBC UK transfers your UK account to HSBC France because you are a UK citizen living in Paris. This could just be a 'grab' to get business into the EU before enacting the reciprol agreement. It could be a negotiating tool for the trade agreement. * Financial Service - This is deliberatly vague as I'm still not sure exactly what financial services/institutions are implicated. Is it just current/business banking, savings, credit or everything? I think it is everything, but not 100% sure You can read up on it a bit here... https://www.theguardian.com/money/2020/sep/21/britons-eu-uk-bank-accounts-closed-lloyds-barclays-brexit https://www.theguardian.com/money/2020/sep/29/britons-in-eu-need-sufficient-warning-of-uk-bank-account-closure-warn-mps-brexit https://www.theguardian.com/politics/2020/sep/26/eu-citizens-uk-brexit-settled-status-jobs-banking-healthcare Right now, like the US Taxation issue, the banks are just covering their backsides! This too shall be biting me in the arse in a couple of years unless it is resolved! Good Luck Rapido UK! Paul
  2. The issue you have linked to in that DW article is unconnected to Brexit entirely, and concerns only the Tax obligations of US Citizens resident overseas. US Citizens are subject to domestic US taxation on their earnings made outside of the USA, even whilst residing outside of the USA, and they are required to submit tax returns to the US IRS (Internal Revenue Service) every year. Only two countries tax their citizens like this; the USA and Eritrea. A US Citizen living and working in the UK, earning money only in the UK (for example) is subject to US taxation as well as UK taxation. However, to avoid the 'double taxation' issue the US Internal Revenue Service has certain financial exemption levels for each country. For the UK it is currently circa US $100,000. If the US citizen earns up to the limit they do not pay anything to the IRS. Over the limit then the portion over is subject. The US citizen is, of course, able to take advantage of the tax deductable items to reduce their US tax liability. The issue is a 'hot' at the moment because the US Govt require all banks in all other countries to submit financial information back to the US IRS on customers that the bank knows to be a US Citizen! If the banks don't do it the US Govt issues fines upon the banks' US operation. So the banks are chasing up their US Citizen customers to provide details, and if they don't, they close the account to ensure they don't get a fine from the US. Trouble is there are more than a few 'Accidental Americans' in the world. 'Accidentals' are people who were born in the USA, thus had US Citizenship imposed on them from birth, but after birth resided and worked out of the USA. Typically this happens to people whose parents are non US Citizens but are in the USA at the time of the childs birth. Many 'Accidentals' don't have a Social Security number (it wasn't until 1987 that the US issued one at birth). Others are unaware of their Social Security number, many have never held a US passport, and often the 'Accidental' doesn't realise that they must file tax returns to the US Internal Revenue Service each year. So, if you were born to Non US citizen parents in the USA prior to 1987, never worked or lived in the USA and all of a sudden your bank in the UK tells you they are shutting your UK bank account because you haven't given your UK Bank your US Social Security number (that the US Govt never issued you when you were born and you never applied for because you never worked or lived in the USA) - you can see why these people might be a little bit concerned right now! But then again, this issue is not connected to UK citizens residing in 'Mainland EU' past Brexit Day not being able to hold a UK bank account. Good Luck Rapido UK. Paul
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