Judge's decision 'clobbered Treasury/IRS' Monte Silver tells Steve Mnuchin, other Treasury officials

Two days after a U.S. District Court judge in Washington, D.C. ruled that he could go ahead with a legal challenge of a key component of President Trump's December 2017 tax reform legislation, Tel Aviv-headquartered U.S. tax attorney Monte Silver told U.S. Treasury Secretary Steve Mnuchin and other Treasury officials in an email that their case against him had been "clobbered" by the decision.

  • Tax

U.S. District Court denies IRS effort to get it to dismiss legal Transition Tax challenge – on Xmas Eve

A U.S. District Court in Washington, D.C. said on Tuesday that it "reject[ed]" claims by the Internal Revenue Service that Tel Aviv-headquartered U.S. tax attorney Monte Silver and his fellow plaintiffs  "lacked standing" to challenge a key component of President Trump's December 2017 tax reform legislation, as it applies to controlled foreign corporations. 

Silver called the ruling a "massive win" for him and other small business owners impacted by Trump's Tax Cuts and Jobs Act, because it meant that his potentially "precedent-setting case" can now go ahead. 

  • Tax

Monte Silver counters IRS ‘dismiss’ motion in U.S. Court

Israel-based U.S. tax attorney Monte Silver has formally countered the Internal Revenue Service’s motion earlier this month to dismiss his and his company's ongoing lawsuit that challenges a key component of President Trump's December 2017 tax reform legislation.

  • News

IRS responds to Transition Tax lawsuit with 'Motion to Dismiss'

The Internal Revenue Service has moved to dismiss a lawsuit brought five months ago by Israel-based U.S. tax attorney Monte Silver – which challenged a key component of President Trump's December 2017 tax reform legislation as it applies to controlled foreign corporations – on grounds that Silver and his fellow plaintiffs in the matter "lacked standing."

  • Tax

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

U.S. Treasury finally cuts expat small-biz owners some GILTI slack

Campaigners for fairer treatment for American citizens abroad are claiming a victory this morning, as news emerged that the U.S. Treasury had finally cut owners of small businesses located abroad some slack yesterday, by enabling such individuals to choose to be treated like a corporation for tax purposes, and thus reduce their tax burden.

  • Tax

Treasury official reported to hint at plans to address GILTI concerns

The U.S. Department of the Treasury is planning to address a much-criticised aspect of the Tax Cuts and Jobs Act that currently would see individual American taxpayers facing potentially higher taxes on their overseas income, a report published on Thursday said, citing a Treasury official. 

  • Tax
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Opinion

FBARs (FinCEN Form 114s), Form 8938s and Form 8966s: not just one but three ways Uncle Sam monitors Americans’ overseas holdings

FBARs (FinCEN Form 114s), Form 8938s and Form 8966s: not just one but three ways Uncle Sam monitors Americans’ overseas holdings

More American expats are familiar these days than they used to be with Foreign Bank Account Reports (“FBARs”), aka FinCEN Form 114s – which need to be filed by American...

Apr-07-2022