Monte Silver, a well-known expert on – and critic of – President Trump’s Tax Cuts and Jobs Act, and the so-called GILTI tax it contains, will host a live webinar on that controversial legislation next Thursday.
In order to reach an audience that he notes is “global,” and therefore to also enable more people to call in during the Q-and-A portion of the event, Silver says he is actually planning to host two different webinars, “one for Asia and Europe, and one for Europe and the Americas.”
The format for both, though, will be the same, and both will last around an hour, Silver, pictured above, said.
Silver added that there are no plans to record and re-broadcast either session, meaning that those wishing to view them will need to register and watch them as they take place.
As reported, Silver, who is a partner and founder of the Tel Aviv-headquartered U.S. tax law firm Silver & Co., earlier this year brought a legal challenge over the TCJA in U.S. District Court in the District of Columbia that challenges key elements of the legislation as it applies to “controlled foreign corporations,” a category that includes small businesses own by expatriates.
According to Silver, next Thursday’s webinar is aimed at “U.S. shareholders of controlled foreign corporations and their U.S. tax professionals.”
It will address, he said, the three different regulations having to do with the TCJA’s so-called global intangible low-taxed income (GILTI) tax.
Unveiled as a component of the TCJA in late December, 2017, the GILTI tax was intended to encourage large multi-national entities to repatriate in the U.S. corporate profits that they had been holding offshore for decades, in order to avoid paying U.S. tax on them. However, it ended up also affecting individual shareholders, members of partnerships and other American expatriates and “U.S. persons” who typically own and run small overseas businesses. Among other things it has imposed a harsh and controversial one-off tax on the previously-untaxed foreign earnings of such businesses, dating all the way back to 1986.
Silver said the format for both editions of his webinar will consist of an introduction to the GILTI tax, and how it is structured and calculated, followed by a review of three recent GILTI regulations, and how they are seen as affecting the typical American expatriate business owner.
According to Silver, those wishing to view the webinar who are located in Asia, or Europe will be able to do so on Thursday, June 27, at 6pm Australian Eastern Standard Time (Sydney); 5pm Japan/Korea Standard Time; 4pm China Standard Time (Beijing); 11 am, Israel Daylight Time; 10am, Central European Summer Time; and 9am, British Summer Time.
To register for this edition, click here.
Those wishing to view the webinar who are located in the Americas – (or Europe, but who would rather watch it in the evening than the morning) – may do so by watching the second edition of the webinar, at 9am Pacific Daylight Time; noon, Eastern Daylight Time; 5pm British Summer Time; 6pm Central European Summer Time; and 7pm Israel Daylight Time.
To register for this edition, click here.
Silver, who is doing the webinar on his own, noted that to be of maximum use to viewers he will seek to ensure that it goes into “as much depth as possible, given the dense subject matter and time constraints.”
He added that viewers should understand that “nothing in the webinar should be construed as legal advice applicable to any specific case.”
To listen to a recent American Citizens Abroad Global Foundation webinar series on a related expat tax matter, the proposed Tax Fairness for Americans Abroad Act, click here. The three sessions took place in March and June, and featured a number of experts, including Matt Stross, tax counsel for Congressman Holding, the North Carolina Republican sponsor of the Tax Fairness legislation.
- Dems Abroad seeks expat American biz owners for GILTI push
- Opinion: Some questions expat small-biz owners might ask their elected reps, while replying to GILTI survey
- Expat small-biz owners reminded: Deadline for major Dems Abroad GILTI survey is Friday
- ACA to Treasury: 'de minimis rule' needed for GILTI and Transition Tax (and btw, RBT is needed too)
- Transition Tax challenger Silver hails U.S. Supreme Court ruling on 'Anti-Injunction Act'