Monte Silver’s Lawsuit Opposing The Procedural Aspect of #GILTI Regs Lives On

In summary – Monte Silver’s lawsuit against GILTI lives on! On April 19, 2024 the U.S. Court Of Appeals released a decision which included: Plaintiffs had objected before the district […]

To punish 100 #GILTI Corporations is to punish millions more individuals

Introduction: As Goes Tax Reform For US Multinationals, So Escalates The Harm To Individual Americans Abroad In the 18th century people were "guilty". In the 21st century people are #GILTI. […]

Proposal by @JoeBiden to increase the GILTI tax has particularly vicious implications for #Americansabroad

Well look here, Biden proposes to double the #GILTI tax with no apparent exemption for small business. This is a declaration of war on the tax base of other countries […]

Seriously now, who’s GILTI? Senators Wyden and Brown attempt to reinforce the punishment of GILTI Americans abroad

Introduction and July 2021 update … If @citizenshiptax continues in ANY form, #expats will always live in fear of unintended consequences like this: "@WydenPress @SenSherrodBrown attempt to reinforce the punishment […]

US Treasury proposes that foreign income subject to high foreign tax be excluded from definition of #GILTI

In general – Good News For American Entrepreneurs Abroad … On Friday June 14, 2019 US Treasury proposed in Notice 2019-12436 that any foreign income earned by Controlled Foreign Corporations […]

Part 31 – "Double Taxation Disguised as Tax Reform": Jackie Bugnion comments in @TaxNotes on @USTransitionTax and #GILTI Even in “retirement” Jackie Bugnion writes the best arguments against citizenship taxation ever via @ExpatriationLaw — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) May 27, 2019 […]

US Treasury interprets Section 962 Election to mean that individual shareholders are entitled to 50% exclusion of #GILTI income when calculating income attributed

On March 4, 2019 as described by Helen Burggraf at American Expat Finance: My comment included: Also welcoming the news of the changes in the tax treatment of Americans’ overseas […]

Punishing you for your past – Presuming you #GILTI for your future

Introduction – Punishing You For Your Past and Destroying Your Future Punishing You For Your Past – Retroactive Taxation And The Sec. 965 Transition Tax The 2017 U.S. Tax Reform […]

Part 23 – It's time for #Americansabroad to support the fight against the @USTransitionTax and #GILTI

Part 1 – Understanding the “Transition Tax” issue and what it means for Americans Abroad As reported at Tax Connections: Understanding the @USTransitionTax issue, what it means for #Americansabroad and […]

Part 19 – Comments from those with @TaxResidency in other countries about the effects of @USTransitionTax & #GILTI

Designed for Google and Amazon and applied to individual Americans abroad … USA: Hands Off CCPCs! MT @ExpatriationLaw @ADCSovereignty 2 USA: PLS don’t harm CDNs w/retrospective tax on CCPCs […]