#gilti

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 rules. GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly That post was largely based on an interesting expose in the Washington Post. This called attention to the…

Introduction and purpose GILTI – found in IRC 951A – is one of the most problematic manifestations of U.S. citizenship taxation. It has caused huge compliance problems and costs for Americans abroad. The costs are composed of (1) the compliance costs of Form 5471 and (2) the possibility of the payment of U.S. taxes. All businesses understand that taxes are a cost of running a business. GILTI has…

In summary – Monte Silver’s lawsuit against GILTI lives on! On April 19, 2024 the U.S. Court Of Appeals released a decision which included: Plaintiffs had objected before the district court that the Anti-Injunction Act did not apply in light of South Carolina v. Regan, 465 U.S. 367 (1984), because they had no other way to litigate their claims. The defendants argued that the Act barred the suit…

Let There Be Income And There Was Income! The United States has an increasing propensity to create “deemed income” in circumstances where the taxpayer has received no income to pay the tax. In some cases the “deemed income” created is “foreign source” income. In other cases it is purely domestic source. When the “deemed income” is “foreign source” income over which the other country has primary…

Exporting U.S. taxes, forms and penalties to the residents of other countries "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation tax but didn't know to ask. A horrific abuse of #Americansabroad in a @citizenshiptax and #FATCA world! https://t.co/j7v1Asreek — U.S. Transition Tax – Subpart F and #GILTI (@USTransitionTax) June 26, 2023 In the…

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 ask. A horrific abuse of #Americansabroad in a @citizenshiptax and #FATCA world! https://t.co/j7v1Asreek — U.S. Transition Tax – Subpart F and #GILTI (@USTransitionTax) June 26, 2023 “Tell me who you are. Then I’ll tell…

Introduction The Moore’s are U.S. residents who happen to be the U.S. shareholders of a CFC (“Controlled Foreign Corporation”). In basic terms, the Moore’s appeal is based on the fact that (1) although the Moore’s received no distribution from the CFC, they (2) were deemed to have received a distribution and required to treat the “deemed distribution” as U.S. taxable income. In other words, they…

Global Intangible Low-Taxed Income and Canadian Corporations