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

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

'Partial' GILTI tax victory seen in latest Treasury regs regarding 'high-tax exceptions' for foreign corporations

The U.S. Treasury Department on Monday issued what it said was a "final regulation" addressing how income earned by foreign corporations that has already been subject to a high rate of foreign tax may declared, in order to "allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis".

  • 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
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Opinion

AXFNJ Podcast: Dems Abroad’s Rebecca Lammers discusses the ‘suffocating’ U.S. expat tax situation with AXFNJ’s Richardson

AXFNJ Podcast: Dems Abroad’s Rebecca Lammers discusses the ‘suffocating’ U.S. expat tax situation with AXFNJ’s Richardson

In 2010, when President Obama signed the Foreign Account Tax Compliance Act into law – hidden inside a domestic jobs bill few still remember, called the HIRE Act – Rebecca Lammers had...

Dec-02-2022