Jack Russell kept inside it's yard by the "invisible dog fence" is exactly like an individual U.S. citizen who uses a CFC to attempt to carry on a business outside the USA under the new #GILTI regime. Q. What kind of dog are you? A. Ask your tax accountant https://t.co/BQb1RePQ3f
— U.S. Transition Tax – Subpart F and #GILTI (@USTransitionTax) January 29, 2018
2018 has been a difficult year for Americans living outside the United States who operate small businesses through corporations. The tax compliance community is still interpreting Section 965 of the Internal Revenue to require them to “turn over” a percentage of their assets to the U.S. government.
For those who don’t understand what the “transition tax” is:
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 5, 2018
Okay, sorry the text in the above image is a little small. But, my point includes, that the “transition tax” is: (1) retroactive taxation (2) on income that was specifically NOT subject to U.S. taxation at the time that it was earned (3) without any triggering event whatsoever (4) that is an attempted tax grab before the host country can tax it (5) in a way that absolutely results in double taxation (6) that is in effect a confiscation of the “pensions” of Americans abroad. Yes, it’s true and NO U.S. TAX PROFESSIONAL HAS EVEN ATTEMPTED TO SUGGEST THAT POINTS 1 – 6 ARE FALSE.
The purpose or this post is to:
1. Review what has happened during the last year; and
2. Strongly encourage you to support Monte Silver (a U.S. tax lawyer based in Israel) in his organizing a lawsuit against U.S. Treasury for not having complied with various statutes in the implementation of this law. See Silvercolaw.com or contact Monte at firstname.lastname@example.org