U.S. District Court rules against Monte Silver Transition Tax challenge

In a ruling that has surprised many in the expatriate American community, a U.S. District Court in Washington, D.C. has officially declared Tel Aviv-headquartered U.S. tax attorney Monte Silver and his company "lack constitutional standing to pursue their claims" – thus ending, at least for now, Silver's feisty effort to force the U.S. Treasury to take small overseas businesses owned by Americans into account in its enforcement of President Trump's Tax Cuts and Jobs Act.  

  • Tax

Yue: Meadows said to be 'very interested' in legislative action plan, but 'after the election'

White House chief of staff Mark Meadows did in fact receive a letter sent to him last month by the Republicans Overseas that urged him to call on President Trump to use his presidential authority to issue an "executive order" aimed at fixing certain tax issues expat Americans are currently struggling with, and is "very interested in doing something to end double taxation [for expats] legislatively after the election", according to RO chief executive and vice president Solomon Yue.

Tax webinar: 'What the two recently-published final GILTI regs mean for expat biz owners, tax pros'

Monte Silver, the Israel-based American tax attorney best known recently for his efforts aimed at forcing U.S. officials to fix a number of apparently unintentional but significant consequences for small business owners that were contained in President Trump's 2017 tax reform legislation, will host a free, two-part webinar on the so-called "global intangible low-taxed income" (GILTI) provisions of that tax reform package next Thursday, July 30.  

  • Tax

'Partial' GILTI tax victory seen in latest Treasury regs regarding 'high-tax exceptions' for foreign corporations

The U.S. Treasury Department on Monday issued what it said was a "final regulation" addressing how income earned by foreign corporations that has already been subject to a high rate of foreign tax may declared, in order to "allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis".

  • Tax
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Opinion

SEAT reminder: 'April 7 is deadline for you to tell Senate Finance C'ttee how well U.S. int'l tax regime works for you'

SEAT reminder: 'April 7 is deadline for you to tell Senate Finance C'ttee how well U.S. int'l tax regime works for you'

As we reported here last week, the U.S. Senate Finance Committee held a hearing last month on “How U.S. International Tax Policy Impacts American Workers, Jobs, and Investment." Many in...

Apr-06-2021