Part 33 – US residents bring suit alleging that the Section 965 US Transition Tax is Unconstitutional

A Washington state couple is suing the government arguing a tax on repatriated assets violates the U.S. Constitution. https://t.co/uOKo7AWAO2 — Bloomberg Tax (@tax) September 30, 2019 A lawsuit alleging that the Section 965 transition tax is unconstitutional affords the opportunity to write Part 33 in my series of posts about the U.S. Transition Tax. Part […]

Part 26 – 2018 The @USTransitionTax in Review: As the year winds down lawyer @MonteSilver1 organizes the "Transition Tax" lawsuit – Monte has supported you! It's time for you to help Monte support you!

Jack Russell kept inside it's yard by the "invisible dog fence" is exactly like an individual U.S. citizen who uses a CFC to attempt to carry on a business outside the USA under the new #GILTI regime. Q. What kind of dog are you? A. Ask your tax accountant https://t.co/BQb1RePQ3f — U.S. Transition Tax – […]

Part 14 – Calculating the Transition Tax: The 962 Election – getting credit for the tax the corporation has paid

The first thirteen posts in my “transition tax” series were: Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but “Compliance is impossible” Part 2: Responding to The Section 965 “transition tax”: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax” Part 3: Responding […]

Part 13 – Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One

Continuing with the “Transition Tax” series … The first twelve posts in my “transition tax” series were: Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but “Compliance is impossible” Part 2: Responding to The Section 965 “transition tax”: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to […]

Part 11: Responding to the Sec. 965 “transition tax”: Letter to the Senate Finance discussing the effects of the transition tax on Americans abroad

Full @SenateFinance HearingEarly Impressions of the New Tax LawDate: Tuesday, April 24, 2018 Time: 02:30 PM Location: 215 Dirksen Senate Office Building https://t.co/02uCGBB3FS – My letter about @USTransitionTax @OrrinHatch on behalf of #Americansabroad https://t.co/hicUktgXHH pic.twitter.com/QHVMDkf8q4 — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 5, 2018 This is the eleventh in my series […]

Part 10: Responding to the Sec. 965 “transition tax”: Individuals subject to U.S. state tax jurisdiction, the response of New York State

This is the tenth in my series of posts about the Sec. 965 Transition Tax and whether/how it applies to the small business corporations owned by taxpaying residents of other countries (who may also have U.S. citizenship). These small business corporations are in no way “foreign”. They are certainly “local” to the resident of another […]

Part 9: Responding to the Sec. 965 “transition tax”: From the "Pax Americana" to the "Tax Americana"

Q. What do #MeghanMarkle and the @USTransitionTax have in common? A. They are two news items of 2018 that will draw attention to U.S. policy of imposing "worldwide taxation" on people who have @taxresidency in other countries and do not live in the USA. https://t.co/G8Q7l3KSdQ pic.twitter.com/Co7OmQiXn7 — John Richardson – lawyer for "U.S. persons" abroad […]

Part 8: Responding to the Sec. 965 “transition tax”: This small business thought it was saving to invest in business expansion – Wrong, they were saving to be robbed by America!

RT: The USA Must stop imposing "worldwide taxation" on any individual who has @taxresidency in another country and does not live in the USA. This is NOT a partisan issue. ALL individuals and groups MUST UNITE in achieving this goal! See explanation here – https://t.co/uRbK2IGFX3 — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) […]

Part 7: Responding to the Sec. 965 “transition tax”: Why the transition tax creates a fictional tax event that allows the U.S. to collect tax where it never could have before

Brilliant! @FinMusings explains how @USTransitionTax allows USA to collect tax on income that never would have resulted in U.S. tax payable! By changing timing and "frontrunning" USA creates a "fictional event" to tax CDN income before Canada can tax it! https://t.co/hnDu6x7y5K — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 4, 2018 Introduction […]

Part 6: Responding to the Sec. 965 “transition tax”: A "reprieve" until June 15, 2018

Those with an automatic filing extension until June 15, 2018 appear to have a "reprieve" on the first @USTransitionTax payment until June 15, 2018 – https://t.co/KaDttPII0G pic.twitter.com/pqmqJMQs8V — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 2, 2018 Introduction This is the sixth in my series of posts about the Sec. 965 Transition […]