cross-posted from citizenshipsolutions blog
Beginning with the conclusion (for those who don’t want to read the post) …
For the reasons given in this post, I believe that there are grounds to argue that the imposition of the Sec. 965 “transition tax” on Canadian resident/citizens DOES violate the Canada U.S. tax treaty. It is my hope that this post will generate some badly needed discussion on this issue.
If you are an individual who believes you may be impacted by the “transition tax”, you should consider raising this issue with the Competent Authority. I would be happy to explore this with you.
Need some background on the Sec. 965 “U.S. transition tax”?
The following tweet references a 7 part video series about the Internal Revenue Code Sec. 965 “Transition Tax” created by John Richardson and Dr. Karen Alpert.
Understanding the @USTransitionTax – the possible implications for small for small business owners who do NOT reside in the United States – A 7 part video series with John Richardson and Dr. Karen Alpert https://t.co/MfsK7ArrcL
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 13, 2018
(Video 6 gives examples of what various approaches to “Transition Tax Compliance” might look like.)
