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IRC Section 965 Transition Tax – Part 7

John Richardson - Transition Tax - Part 7

Why The Transition Tax Creates A Fictional Tax Event That Allows The U.S. To Collect Tax Where It Never Could Have Before

This is the seventh in my series of posts about the Sec. 965 Transition Tax and whether/how it applies to the small business corporations owned by taxpaying residents of other countries(who may also have U.S. citizenship). These small business corporations are in no way “foreign”. They are certainly “local” to the resident of another country who just happens to have the misfortune of being a U.S. citizen. Read more

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