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.

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2020 Election: Where the candidates stand on the key expat financial, tax, citizenship issues

With the New Hampshire Democratic Primary set for next Tuesday, and, as reported, the Democrats Abroad's Global Presidential Primary scheduled for March 3 to 10, expats are increasingly desperate to know where the candidates stand on such key issues as FATCA, citizenship-based taxation and President Trump's Tax Cuts and Jobs Act.

None of the candidates thus far, however, has shown quite the same level of enthusiasm for going on the record in detail with respect to their positions on such topics...

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Fresh from DC court triumph, tax lawyer Silver unveils plans for road trip

Weeks after a U.S. District Court in Washington, D.C. ruled in his favor by denying a U.S. government effort to prevent him from legally challenging a key component of President Trump's December 2017 tax reform legislation, Tel Aviv-headquartered U.S. tax attorney Monte Silver has unveiled plans to undertake a  global road trip, to "meet all those who have supported the cause".

  • Tax

U.S. District Court denies IRS effort to get it to dismiss legal Transition Tax challenge – on Xmas Eve

A U.S. District Court in Washington, D.C. said on Tuesday that it "reject[ed]" claims by the Internal Revenue Service that Tel Aviv-headquartered U.S. tax attorney Monte Silver and his fellow plaintiffs  "lacked standing" to challenge a key component of President Trump's December 2017 tax reform legislation, as it applies to controlled foreign corporations. 

Silver called the ruling a "massive win" for him and other small business owners impacted by Trump's Tax Cuts and Jobs Act, because it meant that his potentially "precedent-setting case" can now go ahead. 

  • Tax

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.

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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
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Opinion

Karen Alpert: Unforeseen consequences expected as 'Recovery Rebate' is distributed to expats

Karen Alpert: Unforeseen consequences expected as 'Recovery Rebate' is distributed to expats

There has already been much speculation by media organizations, American expat groups and cross-border U.S. tax specialists about how the US$2trn federal stimulus package known as the CARES Act, signed...

Apr-01-2020