#subpart f

Hot to think about the December 5, 2023 hearing in Moore … In Moore @USTransitionTax case, the US Solicitor General urges the Court to NOT read a requirement of "realization" (receipt of income) into the 16th Am. Because a requirement of actual receipt of income would undermine 877A Exit Tax imposed on #citizide. https://t.co/GY2Nc8yTcX pic.twitter.com/2arK8AeClh — John Richardson – lawyer for…

Podcast – @SEATNow_org members @FixTheTaxTreaty, @TAPInternation and @Expatriationlaw discuss: The Moore @USTransitionTax appeal is being heard by the Supreme Court on Dec. 5/23. What to expect for individuals and #Americansabroad in a #FATCA world … https://t.co/awsk7B737S — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) December 3, 2023 December 2, 2023 – Participants…

Moore and Retroactivity – The Readers Digest Version "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 The Supreme Court granted the cert…

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…