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 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 […]

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!" Well, April 15 is your last best chance! https://t.co/9oPikRay4D — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 15, 2018 Attorney Monte Silver […]

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 — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 9, 2018 Introduction This is the third in my series of posts about the […]

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 the imposition of the Sec. 965 “transition tax” on Canadian resident/citizens DOES violate the Canada U.S. tax treaty. It is my hope that this post […]

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 “fork over” a percentage of the value of their small business corporations to the IRS. Although technically “CFCs” these companies are certainly NOT foreign to […]

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 and Dr. Karen Alpert https://t.co/MfsK7ArrcL — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 13, 2018 Prologue: The United States has a long […]

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. Decision here: https://t.co/X81ShD2oap pic.twitter.com/rCqXILLm6x — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 24, 2019 The judgment is here. To see judgement, go […]

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 — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 9, 2019 This is Part 32 of my series of blog posts about the […]

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 This is Part 31 of my series of blog posts about the Sec. 965 transition tax. It is a “guest post” by Jackie Bugnion who […]

Part 30 – Treasury issues final @USTransitionTax Regs with no relief for #Americansabroad

Treasury issues final regulations on the Sec. 965 @USTransitionTax and (apparently) ignores the rape and pillage of the pensions of Canadians and other #Americansabroad – #YouCantMakeThisUp! https://t.co/ngh8U9DyvO — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 16, 2019 This is Part 30 of my series of blog posts about the Sec. 965 transition […]