Cross-posted from the citizenshipsolutions blog
Part 1: Responding to The Section 965 “transition tax”: “Resistance is futile” but “Compliance is impossible” https://t.co/HMUi0Nw1rU
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 2, 2018
Introduction and background …
“This legislation is being interpreted by a number of tax professionals to mean that individual U.S. citizens living outside the United States are required to simply “fork over” a percentage of the value of their small business corporations to the IRS. Although technically “CFCs” these companies are certainly NOT foreign to the people who use them to run businesses that are local to their country of residence. Furthermore, the “culture” of Canadian Controlled Private Corporations is that they are actually used as “private pension plans”. So, an unintended consequence of the Tax Cuts Jobs Act would be that individuals living in Canada are somehow required to collapse their pension plans and turn the proceeds over to the U.S. government” -John Richardson
