Prologue – October 16, 2018 – Monte Silver explains the “Transition Tax” in general …

For those who missed the first interview (October 16, 2018) with @MonteSilver1 about the @USTransitionTax here it is: https://t.co/3eZcZIci2u

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 17, 2018

Internal Revenue Code – Section 965(i) begins with …
https://www.law.cornell.edu/uscode/text/26/965

"All animals are equal, but some animals are more equal…" https://t.co/vPJyQeuOlW via @BrainyQuote

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 17, 2018

(i) Special rules for S corporation shareholders
(1) In general
In the case of any S corporation which is a United States shareholder of a deferred foreign income corporation, each shareholder of such S corporation may elect to defer payment of such shareholder’s net tax liability under this section with respect to such S corporation until the shareholder’s taxable year which includes the triggering event with respect to such liability. Any net tax liability payment of which is deferred under the preceding sentence shall be assessed on the return of tax as an addition to tax in the shareholder’s taxable year which includes such triggering event.

Only “some” individuals are subject to the Sec. 965 US “Transition Tax” – how “some individuals are more equal than others” …

When it comes to @USTransitionTax as Orwell would have said: "All individuals are equal, but some individuals are more equal than others" – those who own their corp through an "S corporation" get continued deferral and NOT subject to Sec. 965 confiscation https://t.co/XldUHlsLcT

— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) November 17, 2018

The complete second interview with Monte Silver – The unfairness to Americans abroad is compounded…