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!”
Tag Archives: CCPCs
Part IV-Sec 965 Transition Tax – Comparing Treatment of Homeland Americans to the Treatment of Non-Residents
cross posted from citizenshipsolutions by John Richardson CLICK TO ENLARGE Great presentation! Lawyer Monte Silver explains how the @USTransitionTax is very much like the 2011 #OVDI program! Do you remember: "This is your last best chance to come into compliance!" Well,Continue reading “Part IV-Sec 965 Transition Tax – Comparing Treatment of Homeland Americans to the Treatment of Non-Residents”
Part 3-Responding to the Sec 965 Transition Tax- They Hate you for Your Pensions!
cross posted from citizenshipsolutions by John Richardson The discussion around the @USTransitionTax and it's possible applicability to #Americansabroad shows why U.S. @nonresidenttax must end – Dangerous to be American if you don't live in America! https://t.co/00Sm2xc8Kl pic.twitter.com/ub0cQz1SkY — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) March 9, 2018 Introduction This is the thirdContinue reading “Part 3-Responding to the Sec 965 Transition Tax- They Hate you for Your Pensions!”
Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax”
cross-posted from citizenshipsolutions blog by John Richardson Beginning with the conclusion (for those who don’t want to read the post) … For the reasons given in this post, I believe that there are grounds to argue that the imposition of the Sec. 965 “transition tax” on Canadian resident/citizens DOES violate the Canada U.S. taxContinue reading “Part 2: The transition tax: Is “resistance futile”? The possible use of the Canada U.S. tax treaty to defeat the “transition tax””
Part 1: Responding to The Section 965 “Transition Tax”: “Resistance is Futile” but “Compliance is Impossible”
Cross-posted from the citizenshipsolutions blog by John Richardson Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but “Compliance is impossible” https://t.co/HMUi0Nw1rU — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 2, 2018 https://platform.twitter.com/widgets.js Introduction and background … “This legislation is being interpreted by a number of tax professionalsContinue reading “Part 1: Responding to The Section 965 “Transition Tax”: “Resistance is Futile” but “Compliance is Impossible””
It’s Happening Again – Enough is Enough is Enough
NB: STAY TUNED – a 7-part video on the Transition Tax, with John Richardson & Karen Alpert will be posted in the next couple of days. NB: For anyone with time to spare/the interest/needing specifics to make the point regarding the “intention” of the law, here are some of the relevant House/SenateContinue reading “It’s Happening Again – Enough is Enough is Enough”
ACA: TAX REFORM BILL AND AMERICANS ABROAD: WHAT HAPPENED? WHAT’S NEXT?
NB: While ADCT respects ACA’s positions and appreciates their lobbying efforts, this post in no way serves as an endorsement of their submission regarding RBT. It bears repeating that no group approached Congress during the tax reform process and specifically requested RBT. Many chose to support RO’s effort (TTFI) assuming it more likely toContinue reading “ACA: TAX REFORM BILL AND AMERICANS ABROAD: WHAT HAPPENED? WHAT’S NEXT?”
It’s the Subpart F Rules, Stupid
There is a very good discussion going on over at Brock regarding the “Transition Tax” and the unintended consequences that may be passed on to expats. Fortunately, this cross-posted comment by USCitizenAbroad demonstrates how we have moved from the complicated verbiage of statutes/IRS Code to something understandable. (!!!!!) @Plaxy First, there has neverContinue reading “It’s the Subpart F Rules, Stupid”
Seven Simple Points to be Made Re: Transition Tax and CFCs
This comment from the Isaac Brock Society makes basic points to be made with regard to the proposed “Transition Tax” in both the House and Senate Tax Reform Bills. Every expat who knows there are private individuals who are incorporated in their country should be contacting relevant government representatives giving them theContinue reading “Seven Simple Points to be Made Re: Transition Tax and CFCs”
ADCS-ADSC & ADCT Letter to U.S. Congress
— In this press release we ask United States Congress to fix a problem in the present House/Senate tax bills that targets certain Canadian citizen/residents who own an incorporated business — and more broadly — to “stop imposing worldwide taxation on any Canadian resident”. The press release is being sent in part to membersContinue reading “ADCS-ADSC & ADCT Letter to U.S. Congress”
Citizenship Taxation 