Eroding the tax base of other countries by imposing direct US taxation on the residents of those countries

When I hear people say that the IRC 911 FEIE and/or the IRC 901 FTC rules mean that #Americansabroad don't pay taxes to the US, I am reminded of John […]

Part 7 of series: Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways

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 […]

Part 29 – Can the full Canadian tax paid personally on distributions from Sec. 965 income be used to offset the @USTransitionTax

Introduction – As the year of the “transition tax” comes to an end with no relief for Americans abroad (who could have known?) As 2018 comes to and end (as […]

Considering renouncing US citizenship? Meet a person who I suggested NOT commit #citizide

#FATCA is USA is forcing certain #Americansabroad to renounce US citizenship bc of unreasonable demands. @CitizenshipTax may not be per se unconstitutional – but when it reaches point where people […]

Part 25 – Reflections on the "S Corporation" exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn

Beginnings … A recent comment at the Isaac Brock Society includes: It’s too bad I didn’t put my Canadian corporation in an S Corp before I knew I was a […]

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 […]

Canada U.S. Tax Treaty – Article XXVIA: How the 5th Protocol Enhances protection for Canadian citizens

Canada U.S. Tax Treaty – Article XXVIA: How the 5th Protocol Enhances protection for Canadian citizens — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 6, 2018 Introduction […]

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. […]

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 […]

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 […]