ACA to Treasury: 'de minimis rule' needed for GILTI and Transition Tax (and btw, RBT is needed too)

The American Citizens Abroad has written to seven top U.S. Treasury officials, including Treasury Secretary Janet Yellen and IRS Commissioner Charles Rettig, to urge it to "revisit" the way President Trump's 2017 Tax Cuts and Jobs Act is affecting the small- to medium-sized businesses owned by Americans overseas – in addition to urging them to take other actions, including "the true corrective measure" of switching the U.S. to a residence-based tax (RBT) regime.

  • Tax

Silver makes good on his vow to continue his TCJA challenges, with new DC court filings

Monte Silver, the Israel-based U.S. tax attorney who recently saw his and his company's legal attempt to challenge the Transition Tax and GILTI elements of former Donald Trump's 2017 Tax Cuts and Jobs Act dismissed on a technicality, has made good on his vow to continue to pursue the matter "to the very end," with the filing of two motions in a U.S. District Court on Friday. 

  • News

Monte Silver vows to pursue his Transition Tax, GILTI lawsuits 'to the very end'

Monte Silver, the Israel-based U.S. tax attorney who recently saw his and his company's legal attempt to challenge the Transition Tax element of former Donald  Trump's 2017 Tax Cuts and Jobs Act dismissed on a technicality, says he's now decided to appeal the March 28 decision, and is inviting supporters and other expat small-business owners to help him finance it.  

  • News

Court hearing set for Monday in Monte Silver 'Transition Tax' case

A major and potentially precedent-setting legal challenge to a key component of President Trump's December 2017 tax reform legislation, as it applies to "controlled foreign corporations", will move at last to a U.S. district courtroom in Washington, D.C. on Monday, more than two years after it was launched.

  • News

Democrats Abroad responds to RO letter to Meadows; Biden camp still silent

The Democrats Abroad has forcefully rebutted arguments contained in a letter its Republican counterpart organization sent last week to President Trump chief of staff Mark Meadows, in which the Republicans Overseas called on Meadows to use an executive order to address some of the key tax issues U.S. expats have been struggling with.

  • News

Concern among American expat small-business owners over proposed GILTI law tweak by U.S. lawmakers

American expatriates who own small- and medium-sized small business corporations outside the U.S. are expressing growing concern over what they say is a move by two Washington lawmakers to legislatively reverse a 2019 interpretation by the U.S. Treasury of elements of President Trump’s Tax Cuts and Jobs Act, which had been meant to help such individual owner/operators of such small, non-U.S. businesses, who had originally been hard-hit by the Trump legislation.

  • News
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Opinion

You really know you're an American expat when...

You really know you're an American expat when...

Like folks everywhere, Americans are often surprised to discover how different things can be when they live abroad. Sometimes the differences are small; sometimes they're hilarious. In recent years, as...

Nov-25-2021