ACA to Treasury: 'de minimis rule' needed for GILTI and Transition Tax (and btw, RBT is needed too)

The American Citizens Abroad has written to seven top U.S. Treasury officials, including Treasury Secretary Janet Yellen and IRS Commissioner Charles Rettig, to urge it to "revisit" the way President Trump's 2017 Tax Cuts and Jobs Act is affecting the small- to medium-sized businesses owned by Americans overseas – in addition to urging them to take other actions, including "the true corrective measure" of switching the U.S. to a residence-based tax (RBT) regime.

  • Tax

Silver makes good on his vow to continue his TCJA challenges, with new DC court filings

Monte Silver, the Israel-based U.S. tax attorney who recently saw his and his company's legal attempt to challenge the Transition Tax and GILTI elements of former Donald Trump's 2017 Tax Cuts and Jobs Act dismissed on a technicality, has made good on his vow to continue to pursue the matter "to the very end," with the filing of two motions in a U.S. District Court on Friday. 

  • News

Monte Silver vows to pursue his Transition Tax, GILTI lawsuits 'to the very end'

Monte Silver, the Israel-based U.S. tax attorney who recently saw his and his company's legal attempt to challenge the Transition Tax element of former Donald  Trump's 2017 Tax Cuts and Jobs Act dismissed on a technicality, says he's now decided to appeal the March 28 decision, and is inviting supporters and other expat small-business owners to help him finance it.  

  • News

Court hearing set for Monday in Monte Silver 'Transition Tax' case

A major and potentially precedent-setting legal challenge to a key component of President Trump's December 2017 tax reform legislation, as it applies to "controlled foreign corporations", will move at last to a U.S. district courtroom in Washington, D.C. on Monday, more than two years after it was launched.

  • News

Democrats Abroad responds to RO letter to Meadows; Biden camp still silent

The Democrats Abroad has forcefully rebutted arguments contained in a letter its Republican counterpart organization sent last week to President Trump chief of staff Mark Meadows, in which the Republicans Overseas called on Meadows to use an executive order to address some of the key tax issues U.S. expats have been struggling with.

  • News

Concern among American expat small-business owners over proposed GILTI law tweak by U.S. lawmakers

American expatriates who own small- and medium-sized small business corporations outside the U.S. are expressing growing concern over what they say is a move by two Washington lawmakers to legislatively reverse a 2019 interpretation by the U.S. Treasury of elements of President Trump’s Tax Cuts and Jobs Act, which had been meant to help such individual owner/operators of such small, non-U.S. businesses, who had originally been hard-hit by the Trump legislation.

  • News

Monte Silver: TCJA still a major problem, but some progress seen in recent GILTI revisions

President Trump's Tax Cuts and Jobs Act 2017, which took effect on Jan. 1, 2018, has been a huge issue for many Americans who own as little as 10% of a small overseas business. Caught up in a clumsy legislative effort aimed at such large multi-national American companies as Google and Apple, these small business owners are, as has been frequently reported by this media organization and others, being forced to pay a 17.5% transition tax on income from their small business entities that dates back as far as the 1980s. 

  • Tax
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Opinion

The AXFNJ podcast: 'The impact of the proposed Warren Wealth Tax (and how it would interact with FATCA) on Americans abroad'

The AXFNJ podcast: 'The impact of the proposed Warren Wealth Tax (and how it would interact with FATCA) on Americans abroad'

On Wednesday (June 16), viewers of a "virtual" three-hour, full Senate Finance Committee hearing on the subject of President Biden's Fiscal Year 2022 budget were witness to a rare, 6...

Jun-17-2021