QUESTION: Mr. Ingram
Subject: Dual citizenship & taxes
If one obtains dual German citizenship (and Canadian) yet still work, reside
and earn all income in Canada do they still have to file a German tax
return?
Is this the same for dual German and US citizens?
Thanks,
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david ingram replies:
Under Article IV of the US Canada Tax Convention, you would only be taxable
in Canada. Germany does NOT require its citizens to file returns when they
do not live in the country. An exception would be if the source of the
money was from Germany in which case there would be withholding in Germany
and a foreign tax credit in Canada.
The same would be true if one were a dual citizen German American living in
the USA.
If the German American were living in Germany, they would have to file a US
return because US citizens are required to file a return no matter where
they live and no matter what the source of their money is.
Foreign tax credits and exemptions mean that most US citizens do not have to
pay US tax but if the income is high enough, there will be US AMT to deal
with. (alternative minimum tax).
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