Q. What do #MeghanMarkle and the @USTransitionTax have in common? A. They are two news items of 2018 that will draw attention to U.S. policy of imposing "worldwide taxation" on people who have @taxresidency in other countries and do not live in the USA. https://t.co/G8Q7l3KSdQ pic.twitter.com/Co7OmQiXn7
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 16, 2018
This is the ninth in my series of posts about the Sec. 965 Transition Tax and whether/how it applies to the small business corporations owned by taxpaying residents of other countries (who may also have U.S. citizenship). These small business corporations are in no way “foreign”. They are certainly “local” to the resident of another country who just happens to have the misfortune of being a U.S. citizen.