מאמרים - Silver & Co.

Uncle Sam's Tax Man & Your Non-U.S. Company
Immigration to the U.S. and Tax Planning
To Give Up or Not Give Up your U.S. Citizenship for Tax Reasons? That is the question
Disputes and U.S. Litigation: Practical considerations and suggestions for foreign entities involved in U.S. business
The Panama fiasco and the death of off-shore accounts
Foreign companies beware: New IRS regulations will allow the IRS to convert your debt to equity.
U.S. Tax Court resolves long-standing issue involving U.S.-Israel tax treaty.
US tax planning for foreign businesses – initial US activity
Relocation to the US – Comprehensive seminar
U.S. constitutional limits on state taxation
U.S. subsidiary or branch: U.S. Tax considerations
Jerusalem Post: U.S. Tax Court rules against Israeli claiming Foreign Earned Income Exclusion
סוגיות פרקטיות במיסוי אמריקאי בשיתוף לשכת עורכי הדין ת"א
Complications relating to US taxes – "The Marker" Feature Article
On Green Cards and Tax traps
Bank Leumi notified customers it will serve as IRS estate tax holding agent for clients holding U.S. Securities – The Marker.
ANNOUNCING: INNOVATIVE ESTATE TAX SOLUTION FOR NON-AMERICANS HOLDING U.S. REAL ESTATE AND SECURITIES.
CONTACT FOR DETAILS
Tax implications of investing in U.S. real estate via an LLC
The dangerous implications of claiming a benefit under the U.S.-Israel tax treaty
FATCA. FBAR. PFIC. Trump, help us!!
On Gifts and Avoiding Estate tax
The Marker: Significant U.S. Tax Court ruling impacts the ways foreigners are taxed on U.S. business activity and investments. (In Hebrew).
Globes: Significant U.S. Tax Court ruling impacts the ways foreigners are taxed on U.S. business activity and investments.
Does a non-US person investing in a US real estate development pay ordinary income tax or capital gains tax?
The ultimate tax trap! IRC 2801
When is an investment entity/fund considered a Financial Institution under FATCA
Bizportal TV Interview – The U.S. tax reform and its impact on Israel and Israelis.
Israeli CPA Association Quarterly Review: The Grecian Ruling and its impact on foreign investors (Hebrew)
WORLDWIDE FIRST IN FINANCIAL TIMES – THE TRUMP REPATRIATION TAX HITS U.S. EXPATS HARD
PRESS RELEASE – MONTE SILVER FIRST IN THE WORLD TO IDENTIFY AND PUBLISH THE IMPACT OF THE 15.5% EXPATRIATION TAX ON EXPATS
Trump tax reform hits US expat business owners hard – On Globes, the #1 Israel Business Daily
יש לכם אזרחות אמריקאית? תוכנית המס החדשה עלולה להשפיע גם עליכם – THE MARKER – a leading Hebrew business daily in Israel
Jerusalem Post Front Page newspaper: Israel-based US expat professionals and business people punished by 15.5% repatriation tax.
Israel National Radio – English news: Interview on the impact of the 15.5% repatriation tax and GILTI on expat business owners.
GILTI !!! – 2 PAGE ARTICLE IN INTERNATIONAL TAX REVIEW MARCH 2018 PRINT EDITION. THE WORLD'S #1 BUSINESS PUBLICATION ON INTERNATIONAL TAX. CO-AUTHORED WITH BAKER MCKENZIE
Expats not GILTI – Yahoo! Finance
Expats win first fight in the battle for exemption from the Repatriation and GILTI taxes. Click here for the specific tax of the IRS notice. For the full 43 pages of the IRS notice, Google IRS Notice 2018-36
How Americans abroad, 30 days after launching a grass-roots campaign for exemption from the Repatriation and GILTI tax, got the US Government to grant initial relief

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