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

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

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
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Opinion

OPINION: The SEAT approach to residence-based taxation: 'Begin with the end in mind'

OPINION: The SEAT approach to residence-based taxation: 'Begin with the end in mind'

Convincing Congress and the Biden Administration of the need for the U.S. to move to a "residence-based" system of taxation is the No. 1 focus of American expatriate advocacy groups...

Jul-22-2021