cross-posted from citizenshipsolutions Part A is here Part B is here continued from Part B: 5. Why most Americans abroad are like most small business owners in America (and presumably should have similar tax treatment from a U.S. perspective) It’s simple. The vast majority of Americans abroad who carry on business through Canadian Controlled PrivateContinue reading “Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn Part C”
Category Archives: US taxation on non-residents
What if Meghan Markle’s child is born a U.S. citizen? Would the child have any immediate tax and information reporting requirements to the IRS?
-posted from Quora John Richardson Toronto lawyer: FATCA U.S. tax + renunciation of citizenship CitizenshipSolutions John Richardson, Lawyer (1982-present) Answered Mon What if Meghan Markle’s child is born a U.S. citizen? Would the child have any immediate tax and information reporting requirements to the IRS? I note that the question (1) assumes thatContinue reading “What if Meghan Markle’s child is born a U.S. citizen? Would the child have any immediate tax and information reporting requirements to the IRS?”
Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn (Part B)
cross-posted from citizenshipsolutions Part A is here . 1. What exactly is an S Corporation? An “S corporation” is a corporation which elects a specific kind of tax treatment under the Internal Revenue Code. It is NOT a type of corporation. Rather it is the “tax treatment” used by a corporation. (A corporation can beContinue reading “Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn (Part B)”
John Richardson and Monte Silver: The Sec. 965 Transition Tax & Sec. 951A GILTI Taxes – Next steps
The US wants to “raise funds” by imposing taxation on the undistributed earnings of Canadian Controlled Private Corporations. Lawyer Monte Silver needs to “raise funds” to stop them. You can help! this section cross posted from Brock A message from one Canadian resident … @ACAVoice @DemsAbroad @SolomonYue Join Monte Silver and others in stopping theContinue reading “John Richardson and Monte Silver: The Sec. 965 Transition Tax & Sec. 951A GILTI Taxes – Next steps”
Part 5: Responding to the Sec. 965 “transition tax”: Shades of #OVDP! April 15/18 is your last, best chance to comply!
cross posted from citizenship solutions by John Richardson I suggested to John that some might not understand why a similarity between OVDP and the Transition Tax was being made. He asked me to introduce the post to make sure it was clear that the U.S. government has demonstrated that confiscation is the nameContinue reading “Part 5: Responding to the Sec. 965 “transition tax”: Shades of #OVDP! April 15/18 is your last, best chance to comply!”
Comment on “Think You Can Leave U.S. – Think Again”
My comment on the superb article about the plight of #Americansabroad by @Laurasn1000 https://t.co/OPflDEmehD … Calling the other Laura – @Saunderswsj — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 18, 2018 https://platform.twitter.com/widgets.js Recently an excellent article Think you can leave the US? Think again! appeared on the Thom Hartmann site.Continue reading “Comment on “Think You Can Leave U.S. – Think Again””
Citizenship Taxation 