Part 5: Responding to the Sec. 965 “transition tax”: Shades of #OVDP! April 15/18 is your last, best chance to comply!

Introduction This is the fifth in my series of posts about the Sec. 965 Transition Tax and whether/how it applies to the small business corporations owned by tax paying residents […]

Part 4: Responding to the Sec. 965 “transition tax”: Comparing the treatment of "Homeland Americans" to the treatment of "nonresidents"

Great presentation! Lawyer Monte Silver explains how the @USTransitionTax is very much like the 2011 #OVDI program! Do you remember: "This is your last best chance to come into compliance!" […]

Part 3: Responding to the Sec. 965 "transition tax": They hate you for (and want) your pensions!

The discussion around the @USTransitionTax and it's possible applicability to #Americansabroad shows why U.S. @nonresidenttax must end – Dangerous to be American if you don't live in America! https://t.co/00Sm2xc8Kl pic.twitter.com/ub0cQz1SkY […]

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"

Beginning with the conclusion (for those who don’t want to read the post) … For the reasons given in this post, I believe that there are grounds to argue that […]

Part 1: Responding to The Section 965 "transition tax": "Resistance is futile" but "Compliance is impossible"

Introduction and background … “This legislation is being interpreted by a number of tax professionals to mean that individual U.S. citizens living outside the United States are required to simply […]

U.S. Tax Reform and the "nonresident" corporation owner: Does the Sec. 965 transition tax apply?

Understanding the @USTransitionTax – the possible implications for small for small business owners who do NOT reside in the United States – A 7 part video series with John Richardson […]

Renunciation is a process of transitioning from US citizen to nonresident alien. How does this affect your tax situation?

On June 25, 2020 Dr. Karen Alpert and I did a series of podcasts where we discussed how renunciation will affect your interaction with the US tax system. The key […]

Part 34 – 2019: Treasury Fails To Prevent @MonteSilver1 lawsuit against @USTransitionTax From Proceeding – Case To Be Heard On The Merits

What Happened Excellent! Congratulations to @MonteSilver1 for successfully resisting the US Treasury attempts to end his Section 965 @USTransitionTax lawsuit. Onward! Upward! Happy Holidays to US Person small business owners. […]

Part 32 – So, you have received a letter saying that your @USTransitiontax is also subject to the 3.8% NIIT

Look here – Canadians may be required to fiance Homelander Health Care! "Distributions from Canadian RRSPs are subject to #Obamacare surtax while distributions from US plans exempt" https://t.co/EK32yVbRO3 via @ExpatriationLaw […]

Part 31 – "Double Taxation Disguised as Tax Reform": Jackie Bugnion comments in @TaxNotes on @USTransitionTax and #GILTI

https://twitter.com/worldnewsreader/status/1132961693598986241 Even in “retirement” Jackie Bugnion writes the best arguments against citizenship taxation ever https://t.co/unONPqdv0S via @ExpatriationLaw — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 27, 2019 […]