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”

If you Decide to Comply, DON’T choose a Homelander Tax Compliance Professional

I was very surprised to receive the following email on Friday evening. I cannot recall ever getting anything like this before. I will not identify the author because it is not proper to publicly share an email without the permission of the sender. It is not anyone I have ever heard of before and IContinue reading “If you Decide to Comply, DON’T choose a Homelander Tax Compliance Professional”

Solving U.S. Citizenship Problems – London U.K. – March 7, 2018

  WEDNESDAY MARCH 7, 2018 LONDON UK 7:00 – 9:00 pm Are you a US citizen living abroad? Should the U.S. be able to tax the residents and citizens of other countries? What factors are involved; how do I make a reasonable decision about what to do? How will recent Tax Reform affect my situation?Continue reading “Solving U.S. Citizenship Problems – London U.K. – March 7, 2018”

What is Tax Residency? – Episode 2 with John Richardson & Olivier Wagner

  “Tax residence American style” AKA : Imposing “worldwide taxation” on those with @taxresidency in other countries The issue of tax residence has gained so much attention since the “crackdown” on non-resident US Persons began in 2009. It is commonly understood that you pay taxes to the country/state/city-town that you reside in. (For an interestingContinue reading “What is Tax Residency? – Episode 2 with John Richardson & Olivier Wagner”

What is Tax Residency? – Episode 1 with John Richardson & Olivier Wagner

                                The issue of tax residence has gained so much attention since the “crackdown” on non-resident US Persons began in 2009. It is commonly understood that you pay taxes to the country/state/city-town that you reside in. (For an interesting comparisonContinue reading “What is Tax Residency? – Episode 1 with John Richardson & Olivier Wagner”

NO Evidence of Intent to apply the “”Transition Tax” to Small Business Corporations of #AmericansAbroad

  It appears that we are very likely at a breaking point in this intolerable situation faced by expatriates as regards U.S. application of citizenship-based taxation. Tax reform does not happen often. It is critical that relief for expats occur in the current legislation. Many of us simply will not be around in 30 yearsContinue reading “NO Evidence of Intent to apply the “”Transition Tax” to Small Business Corporations of #AmericansAbroad”

Testimony: Green Card Holder Victim Of FATCA After Failing To Return Expired Card

cross posted from Tax Connections Original Statement on April 9, 2015 Submission to the United States Senate Finance Committee International Tax To anyone who doesn’t really understand the fear and frustration of FATCA and the insanity of the US tax system:   I am not and never have been American. I don’t live in theContinue reading “Testimony: Green Card Holder Victim Of FATCA After Failing To Return Expired Card”

After Five Decades of Abuse, Enough is Enough!

  cross-posted from Brock Posted on February 12, 2012 by Just Me   Forget about the notion that CBT has been with us since the Civil War. Forget about the absurd conclusion of Cook v Tait. The real beginning of our story started 55 years ago on October 16, 1962. This was the beginning ofContinue reading “After Five Decades of Abuse, Enough is Enough!”

Why is the United States imposing an “Exit Tax” on the Canadian pensions of Canadian citizens living in Canada?

cross-posted from citizenshipsolutions by John Richardson This post is based on (but is NOT identical to) a July 17, 2017 submission in response to Senator Hatch’s request for Feedback on Tax Reform “Re the impact of the S. 877A “Exit Tax” on those “Americans living abroad” who relinquish U.S. citizenship: Why is the United StatesContinue reading “Why is the United States imposing an “Exit Tax” on the Canadian pensions of Canadian citizens living in Canada?”

Topsnik 2 : Green Card Expatriation And The Exit Tax

  reposted from Tax Connections Blog Written by John Richardson | Posted in International John Richardson     Introduction – Introducing Gerd Topsnik “This case will be seen as the first of an (eventual) series of cases that determine how the definition of long term resident applies to Green Card holders. The case makes clearContinue reading “Topsnik 2 : Green Card Expatriation And The Exit Tax”

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