State Department Forms Need to Distinguish Between Relinquishment and Renunciation

These publications do not constitute legal advise.  Further information regarding this notice. Confusion at two US Consulates in Canada during recent relinquishment cases initiated by Flott & Co. clients revealed the need to develop forms and documents for use in establishing the intentional loss of US citizenship in the past. The current form, Form DS-4079,…

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Flott & Co. Suggests Improved Department of State Guidance for Relinquishment of US Citizenship

Flott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. To avoid inconsistencies in the treatment of similar cases across the world by American consulates, more specific guidance and clearer procedural rules are needed for consular officers on the subject…

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Beware: Foreign Shipping Companies Should Use Caution When Applying Treaty Exemptions

Introduction Under Guo Shui Fa (1996)(87), Guo Shui Han (2008)(952) and the revised Business Tax Law, China imposes a 4.25% outbound shiptax—consisting of 1.25% enterprise tax and 3% business tax—on foreign companies’ gross income from transporting goods and passengers out of China. Chinese ship agents are the withholding agents responsible for remitting the shiptax to…

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