cross-posted from citizenshipsolutions Introduction – “Indifference being the worst form of abuse” "Indifference and neglect often do much more damage than outright dislike." https://t.co/dxiMjWIltE via @BrainyQuote pic.twitter.com/wi3JS4WCGg — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) November 29, 2018 A quick summary of this post: On November 26, 2018 the House Ways and MeansContinue reading “Part 27 – While addressing some Sec. 965 @USTransitionTax concerns, there is NO EVIDENT CONCERN from @WaysandMeansGOP for the injustice inflicted on Americans abroad”
Tag Archives: CFCs
Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn Part C
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”
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)”
Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn (Part A)
cross-posted from citizenshipsolutions This post is in 3 parts, published over 3 days. Beginnings … A recent comment at the Isaac Brock Society includes: It’s too bad I didn’t put my Canadian corporation in an S Corp before I knew I was a US taxpayer. I must have misplaced my crystal ball at the time.Continue reading “Part 25 – Reflections on the “S Corporation” exemption to the Sec. 965 @USTransitionTax – Hat Tip to @SCorpAssn (Part A)”
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”
Repatriation Tax/GILTI – Negotiate for an Exemption?
(click on the picture for a clearer image) A Letter from Monte Silver Americans against the Repatriation/GILTI taxes – within striking distance of winning and you can help! And what to do with the October 15 filing deadline? Hi Fellow Americans, On August 1, 2018, the Treasury issued proposed regulations that interpret the Repatriation taxContinue reading “Repatriation Tax/GILTI – Negotiate for an Exemption?”
Any Expats from Louisiana?
from American Expatriates FB group: Monte Silver Yesterday at 3:58 PM EXPAT FROM LOUISIANA? YOU CAN HELP get Americans abroad exempted from the Repatriation/GILTI taxes. If you are an expat from Louisiana and impacted by these taxes, or know someone that is, pls contact me. Thx http://www.americansabroadfortaxfairness.org
The Repatriation tax and the 962 Election for Americans with a U.K. corporation
by Monte Silver reprinted with permission of the author The U.S. 2017 tax reform has made it very problematic for an American residing in the UK to conduct business through a UK corporation. Operating through a UK corporation exposes the expat to two new taxes: Repatriation and GILTI. This article will discuss the little knownContinue reading “The Repatriation tax and the 962 Election for Americans with a U.K. corporation”
Interrupting our regularly scheduled programming: It appears that there is a delay to the June 15, 2018 @USTransitionTax payment
cross-posted from Brock by USCitizenAbroad RT Looks like many (but not all) #Ameriansabroad impacted by the Sec. 965 @USTransitionTax will NOT be required to make the June 15, 2018 first payment deadline. But, it is YOUR responsibility to read, understand and see how this applies to your situation! https://t.co/FuZ7ZRJbca pic.twitter.com/CmD3u84WxY — U.S. Citizen Abroad (@USCitizenAbroad)Continue reading “Interrupting our regularly scheduled programming: It appears that there is a delay to the June 15, 2018 @USTransitionTax payment”
Part 8: Responding to the Sec. 965 “transition tax”: This small business thought it was saving to invest in business expansion – Wrong, they were saving to be robbed by America!
by John Richardson RT: The USA Must stop imposing "worldwide taxation" on any individual who has @taxresidency in another country and does not live in the USA. This is NOT a partisan issue. ALL individuals and groups MUST UNITE in achieving this goal! See explanation here – https://t.co/uRbK2IGFX3 — John Richardson – Counsellor for USContinue reading “Part 8: Responding to the Sec. 965 “transition tax”: This small business thought it was saving to invest in business expansion – Wrong, they were saving to be robbed by America!”
Citizenship Taxation 