Part 42 – In Moore The Supreme Court Should Consider The Retroactive Nature Of The Transition Tax

Prologue – Taxation, Fairness And “The Man On The Street” Something I think is sometimes lost in tax policy debates: public perceptions do not equate fairness to diminishing inequalities. Not […]

Part 41 – The Six Faces Of The 965 Transition Tax – The Ugliest Face Applies To Americans Abroad

Part I: Introduction – What Is The Transition Tax? "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation tax but didn't know to […]

Part 38 – The § 965 Transition Tax Caused The Moore’s To Pay $14,712 Moore In Double Taxation

Huge news!! The US Supreme Court has agreed to consider the constitutionality of the IRC S. 965 @USTransitionTax. The issues include whether real tax can be imposed on deemed income […]

Part 33 – US residents bring suit alleging that the Section 965 US Transition Tax is Unconstitutional

A Washington state couple is suing the government arguing a tax on repatriated assets violates the U.S. Constitution. — Bloomberg Tax (@tax) September 30, 2019 A lawsuit alleging that […]

Part 26 – 2018 The @USTransitionTax in Review: As the year winds down lawyer @MonteSilver1 organizes the "Transition Tax" lawsuit – Monte has supported you! It's time for you to help Monte support you!

Jack Russell kept inside it's yard by the "invisible dog fence" is exactly like an individual U.S. citizen who uses a CFC to attempt to carry on a business outside […]

Part 14 – Calculating the Transition Tax: The 962 Election – getting credit for the tax the corporation has paid

The first thirteen posts in my “transition tax” series were: Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but “Compliance is impossible” Part 2: Responding to […]

Part 13 – Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One

Continuing with the “Transition Tax” series … The first twelve posts in my “transition tax” series were: Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but […]

Part 11: Responding to the Sec. 965 “transition tax”: Letter to the Senate Finance discussing the effects of the transition tax on Americans abroad

Full @SenateFinance HearingEarly Impressions of the New Tax LawDate: Tuesday, April 24, 2018 Time: 02:30 PM Location: 215 Dirksen Senate Office Building – My letter about @USTransitionTax @OrrinHatch on […]

Part 10: Responding to the Sec. 965 “transition tax”: Individuals subject to U.S. state tax jurisdiction, the response of New York State

This is the tenth in my series of posts about the Sec. 965 Transition Tax and whether/how it applies to the small business corporations owned by taxpaying residents of other […]