As you know, U.S. taxation of its citizens in other continues is a vexing issue. The US Federal Tax Cuts and Jobs Act of 2019 (the “TCJA”) imposed severe harm to business owners of all sizes throughout Canada through the imposition of a Transition Tax (which adversely affected the retained earnings of small business corporations owned by Americans abroad) and rules regarding Global Intangible Low-Taxed Income (or GILTI – this was designed to prevent individuals from using foreign corporations to defer income).
There is an ongoing effort to try to convince Washington to ease the burden on US citizens living abroad. One of the persons who is leading this effort is Monte Silver. He commenced a legal action against the U.S. Department of the Treasury for failing to consider the effect the regulations it promulgated under the TCJA would have on small businesses; the Treasury Department is required to make this consideration anytime it issues new tax rules.
Mr. Silver is scheduled to speak on this matter and on other related tax matters affecting US citizens in Canada at a seminar entitled “Onward and upwards – Mr. Silver’s lawsuit against the roll out of the Section 965 Transition Tax Continues”. This will take place on Wednesday January 29, 2020 from 6:00PM until 9:00PM at the Vault located at 1 King Street West in downtown Toronto.
There is no fee to attend this event but pre-registration is required. You may register by contacting John Richardson of Citizenship Solutions at email@example.com.
This will be a great opportunity to join Chapter members Trowbridge, Hanson Crossborder Tax and others in meeting Monte and others who have assisted individuals with Transition Tax and GILTI issues. This looks to be a stimulating and timely tax policy event.
If you would like more background on this issue please click here.
Upcoming Seminar in Vancouver: February 6. Monte Silver’s perspective on Transition tax/GILTI tax planning, the status of the Transition tax lawsuit and what comes next!
As many of you are aware, Monte Silver, a Canadian/US/Israeli citizen recently won a significant ruling against Treasury for its Sec 965 (Transition Tax) regulations as they affect small businesses. More info here:
Monte is advocating on fixing both the Transition Tax and GILTI on behalf of small businesses and their owners and is inviting tax professionals and the public to his information seminars globally, including Vancouver. Please circulate to anyone you know who’d be interested in attending.
Vancouver Seminar: Transition/GILTI Tax planning & Tax advocacy
A. Latest updates on GILTI/Transition tax planning from a US & Canadian perspective
B. The latest from the DC courtroom – status of the Transition tax lawsuit and the upcoming GILTI lawsuit
DATE: Thursday, February 6, 2020
TIME: 8:30AM – 11AM
VENUE: Ceperley & Walker Room – Terminal City Club, 837 West Hastings St., Vancouver
The event is free and open to both the public and tax professionals. To register, send email to firstname.lastname@example.org
Did anyone attend either of these two seminars? I do hope so because Monte Silver has been and continues to be a great advocate against all the vexing tax issues affecting Americans abroad, particularly TT and GILTI.
Thanks for asking, as I went. There were about a dozen people in attendance, mostly accountants. I sent a notice out to the Pacific Chapter on the Canadian-American Chamber of Commerce, but they never bothered to get back to me. Apparently, Toronto’s Chamber made an appearance at theirs. According to Dan, the host those who do US taxes in Vancouver are a closely knit group that share information. I asked Dan if he’d miss the income from doing the Transition Tax and GILTI filings if Monte were to be successful, and he said that he’d rather do without it as he too finds the regulations impenetrable (or something to that effect).
It would have been nice if there were more in attendance, but I know few people in the area who file US tax, let alone are affected by the Transition Tax and GILTI. Monte did a great job with the presentation and offered a Q & A at the end. Someone asked if he could see the US getting rid of CBT, and he said the US never will in that it’s too imbedded. I asked if a carve-out, such as expanding the FEIE is possible and he said possibly. Advocating for RBT is not on his radar at this moment, and as I’ve said before, Monte plays to win. In his opinion that’s not winnable, but did say who knows what might happen down the road. He is proud that he has been selected to the AARO board and is now chairman of its Tax Committee.
He needs more donations to cover the further legal costs at this juncture, but he’s confident he’ll get a verdict in his favour by summer. Here’s hoping!
Thanks for that summary. Here’s hoping too!