TaxConnections Member John Richardson Interviews Monte Silver: On Confiscatory Taxation On U.S. Citizen Shareholders Of Small Business Corporations

Gilti Tax - John Richardson

In December 2017 the U.S. Tax Cuts and Jobs Act imposed confiscatory taxation on the U.S. citizen shareholders of many small business corporations located outside the United States. Canadian residents have been severely impacted by this. Monte Silver is a U.S. citizen tax lawyer based in Israel who has been very active in both tax advocacy on behalf of Americans abroad and litigation.

On December 24, 2019 his lawsuit against U.S. treasury achieved a major victory in the ongoing quest for “tax justice” for individuals living outside the United States who are also U.S. citizens. This is the fourth time that John Richardson has interviewed Monte Silver on these issues. This story is far from over!

Watch This You Tube Video

You Should Also Read This Blog By John Richardson.

The Reality of U.S. Citizenship Abroad

My name is John Richardson. I am a Toronto based lawyer – member of the Bar of Ontario. This means that, any counselling session you have with me will be governed by the rules of “lawyer client” privilege. This means that:

“What’s said in my office, stays in my office.”

The U.S. imposes complex rules and life restrictions on its citizens wherever they live. These restrictions are becoming more and more difficult for those U.S. citizens who choose to live outside the United States.

FATCA is the mechanism to enforce those “complex rules and life restrictions” on Americans abroad. As a result, many U.S. citizens abroad are renouncing their U.S. citizenship. Although this is very sad. It is also the reality.

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