Government concedes virtally all defenses in GILTI case
Government concedes virtally all defenses in GILTI case Clearly this appears to be a small issue inserted innocently by the Treasury in its final brief on the outstanding technicalities. But it is not. The government has made 2 HUGE concessions: It withdraws its AIA (anti-injuction-act) defense. It withdraws its RFA (regulatory flexibilty act) defense. #1 […]
Our fight against Treasury and the courts for simple GILTI justice
Fighting the US treasury is never easy, as we have seen. However I am determined to prevail with the challenge to the GILTI regulations. The goal remains the same: exempt non-US based American small business owners from GILTI. As you may recall, the Federal DC court of appeals reversed the bogus lower court dismissal […]
The problem when people die holding assets in more than one country
What Happens When Someone Dies Owning Assets in More Than One Country? In today’s globalized world, it’s increasingly common for individuals to own property, investments, and financial accounts across multiple countries. But when someone passes away while holding assets in more than one jurisdiction, things can get complicated—especially in terms of international probate and estate […]
How non-US resident beneficiaries can claim their interest in a United States Investment Account After the Owner Dies
How to Claim a United States Investment Account After the Owner Dies: A Step-by-Step Guide for Beneficiaries Living Outside the United States When a loved one passes away and that person owns an investment account in the United States, one important task for beneficiaries is claiming any investment accounts left behind. Understanding the process can […]
Offset Obamacare and NIIT with Foreign tax credits
Key Ruling Supports Treaty-Based Foreign Tax Credit Against NIIT In a significant development for cross-border taxpayers, the US Court of Federal Claims has ruled that a US citizen residing in Canada may use the US-Canada Income Tax Treaty to claim a foreign tax credit (FTC) against the Net Investment Income Tax (NIIT). This decision […]