# “Mutual assistance in collection” treaty provisions



## underation (Oct 25, 2018)

At present, most US tax treaties don’t have “mutual assistance in collection” provisions, and those that do, don’t provide for assistance where “the revenue claim relates to a taxable period in which the taxpayer was a citizen of the requested State.”

USC expats who are filing US tax returns - should be aware that that situation could easily be changed, if both parties want it to change. The US-Japan Protocol recently ratified does allow for collection from Japanese-US duals under certain specified circumstances.

IMO, there are better options available than relying on residence-country citizenship: renounce, comply fully, or, if you have only residence-country income/assets, don’t file.


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