Monte Silver counters IRS ‘dismiss’ motion in U.S. Court

Israel-based U.S. tax attorney Monte Silver has formally countered the Internal Revenue Service’s motion earlier this month to dismiss his and his company's ongoing lawsuit that challenges a key component of President Trump's December 2017 tax reform legislation.

  • News

IRS responds to Transition Tax lawsuit with 'Motion to Dismiss'

The Internal Revenue Service has moved to dismiss a lawsuit brought five months ago by Israel-based U.S. tax attorney Monte Silver – which challenged a key component of President Trump's December 2017 tax reform legislation as it applies to controlled foreign corporations – on grounds that Silver and his fellow plaintiffs in the matter "lacked standing."

  • Tax

Monte Silver: TCJA still a major problem, but some progress seen in recent GILTI revisions

President Trump's Tax Cuts and Jobs Act 2017, which took effect on Jan. 1, 2018, has been a huge issue for many Americans who own as little as 10% of a small overseas business. Caught up in a clumsy legislative effort aimed at such large multi-national American companies as Google and Apple, these small business owners are, as has been frequently reported by this media organization and others, being forced to pay a 17.5% transition tax on income from their small business entities that dates back as far as the 1980s. 

  • Tax

U.S. Treasury finally cuts expat small-biz owners some GILTI slack

Campaigners for fairer treatment for American citizens abroad are claiming a victory this morning, as news emerged that the U.S. Treasury had finally cut owners of small businesses located abroad some slack yesterday, by enabling such individuals to choose to be treated like a corporation for tax purposes, and thus reduce their tax burden.

  • Tax

Treasury official reported to hint at plans to address GILTI concerns

The U.S. Department of the Treasury is planning to address a much-criticised aspect of the Tax Cuts and Jobs Act that currently would see individual American taxpayers facing potentially higher taxes on their overseas income, a report published on Thursday said, citing a Treasury official. 

  • Tax
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Taxpayer Advocacy Panel's expat rep to expats: 'Let's work together'

Taxpayer Advocacy Panel's expat rep to expats: 'Let's work together'

Last week, National Taxpayer Advocate Nina Olson retired from the role she held for 19 years. During this time, the IRS, of which the National Taxpayer Advocate's office is a...