TCJA and Expanding the definition of and number of "Controlled Foreign Corporations" subject to Subpart F

As goes the number of “Controlled Foreign Corporations“, so goes the size of the U.S. tax base. The “messaging” was that the United States was moving to a system of […]

Green card holders: the "tax treaty tiebreaker" rules and taxation of Subpart F and PFIC income

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of […]

Part 53 – Debriefing The December 5, 2023 – Moore @USTransitionTax Hearing – WHAT The Court Must Do And HOW It Will Do It

Slicing and dicing the issues – WHAT the Court must do and HOW will the Court do it … Podcast – @IRS_Medic + @Expatriationlawdiscuss SC hearing in Moore: The @USTransitionTaxand […]

Americans Abroad Aren’t Denouncing Because They Want To. They Are Renouncing Because They Feel They Have To

Introduction/background: Denunciation of U.S. Citizenship – From the perspective from a U.S. Senator .@SenGillibrand thinks Americans "Denounce" US citizenship in order to "escape taxes". As JFK once said the great […]

Beyer, Titus Introduce Tax Simplification for Americans Abroad Act – September 2023

Introduction and initial reactions Join us for the discussion tomorrow! How the party of #FATCA promises to make life easier for US expats. Join us for the discussion live at […]

Part 45 – “Some” examples where the U.S. creates unrealized “foreign income” before a realization event in the source country

Let There Be Income And There Was Income! "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation tax but didn't know to ask. […]

Part 43 – The 1996 Treasury Regs, 2017 TCJA And The Looting Of Canadian Controlled Private Corporations

Punishing U.S. citizens who live outside the United States As Tax Residents Of Canada "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation […]

Part 42 – In Moore The Supreme Court Should Consider The Retroactive Nature Of The Transition Tax

Prologue – Taxation, Fairness And “The Man On The Street” Something I think is sometimes lost in tax policy debates: public perceptions do not equate fairness to diminishing inequalities. Not […]