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

Frustration across Expatland as ‘final Transition Tax’ regs published

American owners of small businesses who are resident outside of the U.S. are reacting with frustration, and in some cases dismay, to the news that the U.S. government has published its final draft of the so-called Transition Tax element of Donald Trump’s Tax Cuts and Jobs Act without taking into account concerns about what the legislation would do to them.

  • News

George Holding TTFI bill ‘now set for 2019 vote’

Legislation that its proponents have said would significantly improve the lot of America’s 5.1 million to 9 million expatriates – which had been expected to appear before the end of the year, after failing to materialize in September – is now unlikely to be presented to the House of Representatives for a vote until next year, sources report.

  • News

Call for U.S. Treasury to fix 'Transition Tax' problems with 'de minimis rule'

The American Citizens Abroad, the main non-partisan Washington lobbying group representing American expats around the world, today urged the U.S. Treasury Department to introduce a so-called de minimis rule to its latest draft of new tax regulations, in order to address what it said were problems inherent in the legislation that, if not changed, would cause major problems for many U.S. citizens living abroad.  

  • News

George Holding’s bill: What we know so far

Over the last few months, details have begun to emerge about soon-to-be-introduced legislation aimed at making the U.S. tax regime less unforgiving for the 9 million Americans estimated to live overseas, growing numbers of whom say they feel they now have no choice but to renounce their U.S. citizenships.

  • Tax
Subscribe to this RSS feed

Opinion

INSIGHT: First it was FATCA, now MiFID II has U.S. investors in Europe facing nightmares

INSIGHT: First it was FATCA, now MiFID II has U.S. investors in Europe facing nightmares

First, U.S. investors living in Europe had to face FATCA. Now it’s the EU’s Markets in Financial Instruments Directive (MiFID II).  Here, Jonathan Lachowitz, of Lexington, Massachusetts-based White Lighthouse Investment Management...

Nov-20-2019