Liberty and justice for all United States persons abroad

The Isaac Brock Society

Posted on by Posted in Issues regarding US persons abroad, Transition Tax 46 Comments

Update – November 16, 2018 – Here is the November 15, 2018 interview with Monte Silver:

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A message from one Canadian resident …

More info after the jump …

When life is stranger than fiction …

It’s true! As far as the U.S. Congress is concerned:

1. A U.S. resident (the type the actually lives in the United States) is free to run a business incorporated in the United States and NOT be subject to the U.S. Transition Tax and GILTI rules; but

2. Certain Canadian residents (the type that actually lives in Canada that the USA claims to be a U.S. citizen) is NOT free to run a business incorporated in Canada without being subject to the U.S. Transition Tax and GILTI rules.

In other words, the United States of America (that great Citadel of Freedom of Justice) is in effect imposing a separate and more punitive tax system on Canadian residents than on U.S. residents.

In Canada, Canadian Controlled Private Corporations play the social role of being private pension plans.

Bottom line is this: The United States is (via the Transition Tax) attempting to confiscate the pensions of Canadian residents as explained in this recent article at Tax Connections:

Elizabeth Thompson of CBC has written a series of articles about this outrage:

U.S. Extra-territorial taxation is a direct attack on Canada’s Sovereignty …

This may not affect you personally but it is an attack on Canada. I suggest that this is an important cause and I suggest that consider donating to it! Thanks to Monte Silver for taking this initiative!

Support Canadian Sovereignty! Donate to Monte Silver’s “Transition Tax Fundraiser!”

46 thoughts on “The US wants to “raise funds” by imposing taxation on the undistributed earnings of Canadian Controlled Private Corporations. Lawyer Monte Silver needs to “raise funds” to stop them. You can help”

  1. I started a small business in 2006 here in the canton of Vaud, Switzerland. My business account was with UBS. They actually treated me quite well and fronted me two short term loans which greatly helped at the time. By 2008 it was pretty much over and I had to fold. I was fairly depressed about it but today I consider the failure as a blessing.

    I can only imagine what sort of accounting and paperwork hell I’d be going through had I been able to keep things running and turn a profit. I’m sure UBS would have dropped me like a bag of dog poo as soon as FATCA was a done deal.

    Thanks dems, you corrupt s.o.b.’s, and special thanks to that counterfeit facsimile of a president, Barack Hussein Obama, who never let a bill promoting state theft and tyranny go by without his signature

  2. @Eric in Switzerland

    It’s a pretty sad state of affairs when Americans can rejoice in the failure of their businesses!

    There’s no point in blaming at this point. My new philosophy is to support those who choose to support us, and fight those who choose not to – regardless of party affiliation once they know the issues.

    @USCA

    Thanks for the post. Monte’s got “skin in the game” and hates to lose. A good combination for success.

    @all

    Please, let’s try to keep this thread focussed on Monte’s efforts for those affected by the Transition Tax and GILTI. There’s nothing more uninspiring than skipping over pages of topics unrelated to the main post for any nuggets of value. Thanks!

  3. @ BB
    Yesterday I watched John’s interview with Monte (That Channel) re: the Transition Tax. I was particulary impressed with how he challenged Mnuchin. That clause about not hurting small businesses when writing legislation for or against large corporations seems like it could be the key to fixing this mess. Unfortunately I can’t find that video today. Do you have the link? If so would you post it here?

  7. Monte Silver says on Facebook (7 hours ago):

    In 24 hours, we are at $6500 including some that came in via paypal. And I am providing services to several business owners who will be donating nice amounts in exchange for my work. If you know small business owners who are stuck and face the Dec 15 deadline, tell them to contact me

  9. @Bob

    There have been a few similar stories on this subject over the past year.

    Fortunately, law-abiding taxpayers who happen to have US citizenship are not “offshore structures and financial instruments… used to commit tax crime and money laundering.”

  11. The rules have changed. Presumably a small foreign corporation owned by a US citizen will no longer have US tax “deferred until repatriated”, so the transition tax won’t recur.

    GILTI will presumably apply.

  14. Indeed.

    The IRS isn’t launching an attack on dual citizens residing in non-US countries.

    What would be the point, given that taxation (and penalties and liens etc) cannot be enforced?

  15. Please, let’s keep the focus on Monte and his efforts and those affected by the TT and GILTI, rather than going down the enforcement rabbit hole (yet again).

  16. Hardly a rabbit hole, since

    the inability to enforce

    (coupled with the fact that the income that the transition tax applies to

    (a) hasn’t been received and (

    (b) if it had been received would be non-US-source and therefore not US-taxable)

    means the transition tax can’t be collected.

  17. Non-compliance is an option for some but not all. This post focuses on the efforts to get the laws changed prior to the date the taxes are due. Discussing non-compliance ad-nauseum when the focus is on rallying support for legal action is not helpful to the purpose of this post.

  18. Easy, easy!

    Although Bob’s mention of the article about the J5 was off-topic for the thread, I don’t think his comment, or USCAbroad’s reply, was intended to be unhelpful, and I know mine wasn’t. Nobody was discussing non-compliance, until you began.

  19. @All

    I completely agree with BB.

    This post has NOTHING whatsoever to do with compliance and enforcement. This post has to do with the efforts of those who are trying to get this ridiculous law changed – so that compliance and enforcement would not be necessary.

    As the author of this post, I respectfully request that the comments relate to the purpose of the post. For some time now the comments on every post at Brock sooner or later revert to the same compliance theme.

    Those of you who want to obsess over the compliance, enforcement and collection issue should sit this one out please.

  20. But who are you addressing, and why?

    You commented, I agreed with you. Neither of us was commenting about non-compliance.

  21. @ BB
    Once again I’ve gone to That Channel but I can’t find John’s second interview with Monte. Do they take a few days to get posted? TT and GILTI (utterly insulting acronym) are so absurd and so complex I know both men have more to say. Time is tick-tocking away so quickly. This has to get fixed fast and I really think the key has been discovered but it might not work until it’s tested in a court of law. I hope affected business owners/shareholders will rally behind Monte’s efforts. I’d like to help but we are still a one pension couple until Mr. EmBee applies for OAS (waiting until age 70). Imagine being grateful for a failed business like Eric — too sad! We’re grateful we never had a small business in Canada, as we often thought about it.

  23. @USCA
    Thanks. However the video won’t play at the moment and the error message says to try again later. More patience needed. (I’m so bad at patience. 🙁 ) I’m sure the technical problems will resolve but meanwhile I can try our other computer to see if it works there.

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