GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

On November 8, 2020, I participated in a podcast with attorney John Richardson. We discussed some of the reasons why the incoming administration was likely to increase the pressure on Americans abroad. The podcast is here. On March 25, 2021 the Senate Finance Committee held a hearing on International Taxation. The hearing discussed changes to … Continue reading GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time.  This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR).  Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”).  My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”.  In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)