Monte Silver, the Israel-based American tax attorney best known recently for his efforts aimed at forcing U.S. officials to fix a number of apparently unintentional but significant consequences for small business owners that were contained in President Trump's 2017 tax reform legislation, will host a free, two-part webinar on the so-called "global intangible low-taxed income" (GILTI) provisions of that tax reform package next Thursday, July 30.
In particular, Silver, pictured left, says he plans to focus on two recently-published "fixes" that deal with at least some of the worst elements of the GILTI provisions.
Silver plans to conduct both webinar sessions himself.
"The bottom line is that these two regulations have the effect of either retroactively, completely exempting a large number of small businesses from GILTI compliance and tax liability from 2018 or, in the worst case, exempting many others from GILTI tax liability, but still requiring them to comply with it, from a filing standpoint, annually," Silver said, in explaining some GILTI thoughts he intends to expand upon next week.
"This webinar will discuss the substance of the two recent and final GILTI regulations, as well as things such as effective dates, retroactivity, amending past returns, elections required to enjoy the benefits, etc."
Silver said the webinar is intended for an audience of "U.S. business owners, their U.S. CPAs, and relevant U.S.-based associations which serve small businesses."
The first session of Silver's webinar, for those in Asia and for European participants who would prefer an earlier time, will take place at 7pm in Japan and Seoul, 6pm in Perth and Beijing, 1pm in Israel, 12 noon in France and Germany, and 11am in London. To register for this one, click here.
The second session will begin at 9am Pacific (Los Angeles) time, in the U.S.; 12 noon Eastern (New York) time; 5pm in London; 6pm in France and Germany; and 7pm in Israel.
To register for this one, click here.
As reported, Silver – who has noted that advocacy by expat individuals and groups, including himself, was "a major factor" in getting the Treasury to issue the two regulations in their less-harsh-to-small-business-owners-than-originally-written form – last month filed a legal action in U.S. District Court in the District of Columbia that seeks to prove that the GILTI regulations are procedurally invalid because the government failed to take into account their effects on small businesses before bringing them into force. As Silver points out in his filing, it is required to do under the Regulatory Flexibility Act (RFA).
Silver said that the fixes made by the Treasury to the GILTI regulations over the last week had no bearing on the issues in his case, which he still intends to go ahead with.
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