The Section 965 transition tax tornado - the unintended consequences скачать в хорошем качестве

The Section 965 transition tax tornado - the unintended consequences

Attention Global Entrepreneurs and Investors! Is the IRS dragging you down? Text “Wealth” to 818-938-2231. Anthony's firm, Parent & Parent LLP can help end your tax anxiety and frustration right now! We do it all so you can focus on better things. 20 successful years experience in tax planning, tax resolution (including audits!), bookkeeping, asset protection, and offshore disclosures/FBAR help. Everything you need under one roof. Thousands helped! Joining us: John Richardson, Esq. http://www.citizenshipsolutions.ca/ David Sutherland, CPA https://www.jccscpa.com/people/david-... https://www.irsmedic.com/blog/2018/05... The Section 965 transition tax tornado: What it is and what to do about it For homeland Americans and corporations, the transition tax is a pretty good deal. In order to repatriate money to a US, a tax needs to be paid, which can be paid over 8 years, and voila, those future foreign earnings can now be exempt from US taxation. But for Americans overseas who own businesses, the transition tax is a complete disaster, and compliance will difficult for many, and impossible for a few. Joining our podcast is John Richardson of Citizenship Solutions and David Sutherland, a CPA from Montana, both of whom have in-depth experience helping US taxpayers deal with the insanity of the US tax code. While in this podcast discussed cross-border taxation with Canada is discussed at length, the issues also impact US persons living in other countries as well. This is the heart of the problem: In many countries, every business is done through a corporation. The default rule for any corporation controlled by a US persons is that a Form 5471 needs to be filed. The problem is Form 5471 was designed for large multinationals with the ability to bear huge compliance costs. Yet, a Form 5471 is what say, a US-born dentist working in Ottawa for example would need to file with the US, attached to their Form 1040, in addition to their Canadian tax return. Typically, your 2017 Form 5471 Schedule J determines your retained earnings, thus the base of the transition tax. Year after year, earnings were retained in Canada with a fixed, known, and manageable tax consequences. Individuals have left hundreds of thousands, even millions reinvested in their foreign corporations. But Section 965 changes all of this with deemed repatriation on these undistributed earnings.— even though there was no actual repatriation. Rather, a tax was assessed out of the blue, basically a confiscatory property tax unlike any other. Without warning. These undistributed earnings are usually deployed as investments, say for a dentist office, for example. Yet the transition tax now deems a disposition, meaning a US taxpayer now has a tax bill even though they might have a very difficult time paying for. While Section 965 allows for the transition tax to be paid for over a 8-year period, it still may become impossible for some US taxpayers to come up with a tax bill. Section 965 was written in haste and it clearly shows. If the Congress wants people to comply with the IRS, it has to make it at least possible to do so. If you need help trying to figure out what to do about this transition tax, contact us. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com