Part 5 of series: What does U.S. "citizenship-based taxation" actually mean and to whom does it actually apply?

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of […]

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 […]

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 […]

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 […]

Republicans Overseas asks for hearings on how the @USTransitiontax unfairly impacts Americans abroad

Congratulations to @SolomonYue and Republicans Overseas" for thisceffort on behalf of #Americansabroad "RO requests a House Hearing on the harmful impact of the @USTransitionTax" https://t.co/Nkzok2DTSC — John Richardson – lawyer […]

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 […]

The Internal Revenue Code vs. IRS Form 8854: the "noncovered expatriate" and the Form 8854 Balance Sheet

Introduction: For whom the “Form” tolls … I would not want the job that the IRS has. There are many “information reporting requirements” in the Internal Revenue Code. The IRS […]