[JOAO DO CARMO OLIVEIRA]

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Vinicius,

I follow and appreciate your website very much. I consider it a valuable public service.

Last year I emigrated from Brazil to the USA and then filed a Definitive Exit Declaration (CSD) dated 09/09/2021 (the date I entered the USA with a Permanent Resident Visa). I am now preparing my DECLARAÇÃO DE Saída DEFINITIVA (2022, base year 2021), as required by the RFB. Given that there is reciprocity of tax treatment between the Brazilian Federal Revenue Service (RFB) and the American authority (IRS), I would like to know the correct/legal form that should be given to the following question in the Definitive Exit Declaration (DSD):
I know that I must enter the balance of my financial assets on the date of the CSD in this year's DSD. But I have doubts about the amount of Income and Taxes indicated by Brazilian Financial Institutions in the year 2021 (that is, amounts accumulated only until 09/09/2021, or the amount accumulated in the whole year). My concern has three origins:
1) The first is not to cause any accounting and/or legal inconsistencies that could result from collaboration between the two countries' tax institutions;
2) secondly, since the reciprocal tax treatment between the two countries allows me to deduct the taxes paid in the other from my tax return, I would incur a big loss (double taxation) if I didn't declare the income and taxes actually paid between 09/09/2021 and 31/12/2021.
3) thirdly, which taxes paid should be considered in the DSD: all taxes paid on income (including definitive/exclusive/source taxation and those calculated in the declaration), or only those CALCULATED and paid in the DSD.

Thank you in advance for your attention and guidance, if you can provide your comments on this matter.
Thank you very much,
João do Carmo Oliveira

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