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

La Torre Jeker: Impact of TCJA on expats’ overseas properties’ finances

Almost from the moment President Trump signed his Tax Cuts and Jobs Act into law on Dec. 22, 2017, the expatriate American-focused tax advisory industry has focused on its implications for those Americans with an ownership interest in an overseas company, and their consequent new tax obligations.

But that wasn’t the only aspect of the Tax Cuts and Jobs Act that has significant implications for Americans who live outside the U.S., Dubai-based tax expert Virginia La Torre Jeker, pictured above, says. Here, she addresses in detail how the TCJA impacts Americans overseas who own their own homes.

  • News

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
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Opinion

From the front line: How a routine Form 3520 filing can easily go (eye-wateringly expensively) wrong – and did

From the front line: How a routine Form 3520 filing can easily go (eye-wateringly expensively) wrong – and did

It is perhaps not surprising to hear that non-U.S. (or "foreign") trusts with U.S. owners can be tricky...

Jul-09-2019