Republicans Overseas position On What Pure Residence-based taxation means:
Tax Talk 1 – November 22, 2021
Tax Talk 2 – November 29, 2021
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 for "U.S. persons" abroad (@ExpatriationLaw) February 26, 2018
I have previously written about the confiscatory effect of the “transition tax” on small business owners living outside the United States here and here. This is a “tax” – based on the Subpart F regime – on certain shareholders of “controlled foreign corporations“. For Canadians this “tax” represents a U.S. partial confiscation of their pensions. Interestingly the recent “Tax Cuts and Jobs Act” has significantly increased both the number of “United States Shareholders” and the number of “Controlled foreign corporations”.
All of this is taking place in the context of more countries enacting CFC (“Controlled Foreign Corporation”) rules. For example, Russia recently enacted its own “Controlled foreign corporation rules. In general the worldwide climate toward corporations is becoming more and more hostile.
The advocacy of Republicans Overseas is a welcome development. It is hoped that the leadership of Republicans Overseas will encourage other groups that claim to represent non-U.S. residents to join the fight against “non-resident taxation”.
Their official announcement is here and a copy of their submission is here.
To read a copy of their submission …