To punish 100 #GILTI Corporations is to punish millions more individuals

Introduction: As Goes Tax Reform For US Multinationals, So Escalates The Harm To Individual Americans Abroad In the 18th century people were "guilty". In the 21st century people are #GILTI. — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 14, 2021 The Problem: The proposed changes in International Tax (mostly in relation […]

Proposal by @JoeBiden to increase the GILTI tax has particularly vicious implications for #Americansabroad

Well look here, Biden proposes to double the #GILTI tax with no apparent exemption for small business. This is a declaration of war on the tax base of other countries (and of course #Americansabroad). — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 25, 2020 Introduction Proposal of @JoeBiden to raise […]

Seriously now, who’s GILTI? Senators Wyden and Brown attempt to reinforce the punishment of GILTI Americans abroad

Introduction and July 2021 update … If @citizenshiptax continues in ANY form, #expats will always live in fear of unintended consequences like this: "@WydenPress @SenSherrodBrown attempt to reinforce the punishment of #GILTI on #Americansabroad" via @expatriationlaw — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 13, 2021 There is wide agreement that […]

US Treasury proposes that foreign income subject to high foreign tax be excluded from definition of #GILTI

In general – Good News For American Entrepreneurs Abroad … On Friday June 14, 2019 US Treasury proposed in Notice 2019-12436 that any foreign income earned by Controlled Foreign Corporations be (subject to election) excluded from the definition of GILTI income. This will be particularly welcome to Americans living outside the United States, who are […]

Part 31 – "Double Taxation Disguised as Tax Reform": Jackie Bugnion comments in @TaxNotes on @USTransitionTax and #GILTI Even in “retirement” Jackie Bugnion writes the best arguments against citizenship taxation ever 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 […]

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 small businesses was John Richardson, a Toronto-based lawyer at, who specializes in assisting Americans abroad with their tax and citizenship issues. The Treasury, Richardson […]

Punishing you for your past – Presuming you #GILTI for your future

Introduction – Punishing You For Your Past and Destroying Your Future Punishing You For Your Past – Retroactive Taxation And The Sec. 965 Transition Tax The 2017 U.S. Tax Reform AKA – The Tax Cuts and Jobs Act ushered in significant changes for Americans abroad who carry on business through small business corporations. Section 965 […]

Part 23 – It's time for #Americansabroad to support the fight against the @USTransitionTax and #GILTI

Part 1 – Understanding the “Transition Tax” issue and what it means for Americans Abroad As reported at Tax Connections: Understanding the @USTransitionTax issue, what it means for #Americansabroad and why your support is needed NOW: "Letter To The Senate Finance Committee On The Effects Of The Transition Tax On Americans Abroad" via @taxconnections […]

Part 19 – Comments from those with @TaxResidency in other countries about the effects of @USTransitionTax & #GILTI

Designed for Google and Amazon and applied to individual Americans abroad … USA: Hands Off CCPCs! MT @ExpatriationLaw @ADCSovereignty 2 USA: PLS don’t harm CDNs w/retrospective tax on CCPCs — ADCSovereignty (@ADCSovereignty) December 19, 2017 ADCS Press Release on the Transition Tax and GILTI: The Alliance For The Defence Of Canadian Sovereignty issued a […]


This is Part 18 of my series of posts discussing the Section 965 U.S. Transition Tax. This has been reposted with permission from Time out from our regular programming with this special message – A Call To Action – from Attorney Monte Silver: Hi Fellow Americans: On August 1, 2018, the Treasury/IRS issued proposed […]