As goes the number of “Controlled Foreign Corporations“, so goes the size of the U.S. tax base. The “messaging” was that the United States was moving to a system of […]
Update – June 27, 2025 – The 899 Penalty Tax has been removed from the “Big Beautiful Bill”: Although the removal of the proposed 899 #penaltytax is a good thing, […]
Punishing U.S. citizens who live outside the United States As Tax Residents Of Canada "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation […]
Prologue – The “Take Away” And Summary For Americans Abroad A Mexico Land TRUST, is not a FOREIGN TRUST for IRS purposes – ("cannot be what it isn't"). But, a […]
Synopsis: The power to regulate is the power to destroy! That's why the regulatory process should require careful consideration of how and to whom regs apply. It's time for Treasury […]
In general – Good News For American Entrepreneurs Abroad … On Friday June 14, 2019 US Treasury proposed in Notice 2019-12436 that any foreign income earned by Controlled Foreign Corporations […]
Introduction I have previously written about the “Worldwide trend of attacking the use of corporations as a way to reduce or defer taxation for individuals“. This is a continuation of […]
Update November 9, 2017 Today Chairman Brady concluded the “Mark Up” period of his proposed tax legislation. The “Mark Up” period contained NO move to “territorial taxation” for individuals. It […]
Introduction – The war against corporations and the shareholders of those corporations Corporations as entities that are separate from their shareholder/owners As every law students knows, a corporation is a […]
Introduction and purpose: The Big Beautiful Bill (“BBB”) Contains many surprises. Yesterday, I wrote a first post about a section of the BBB that addressed the application of the GILTI […]