Freelancers and Small Business Owners

At a summit on Saturday June 4 2021, the G7 group of countries agreed to establish a global minimum corporate tax rate, as well as a common way to tax the biggest international digital services companies. Background In the digital age, companies can sell services online in other countries without having a physical presence there. […]

The US tax system is unusual, in that the US taxes based on citizenship rather than residence. This means that all US citizens have to file US taxes on their worldwide income, even if they have to file foreign taxes too. This includes Americans living abroad, who have the same annual US filing and reporting […]

If you’re an expat business owner, the 962 election is one of several tax provisions you may need to wrap your head around. This is especially true if you earn GILTI, Global Intangible Low Taxed Income.  As a reminder, in 2017, the US government introduced the Tax Cuts and Jobs Act (TCJA), which initiated GILTI. […]

The IRS has released the final GILTI rules, two and a half years after the new tax on Americans with a foreign registered business was introduced as part of the 2017 Tax Cuts and Jobs Act. Initially intended to target large multinationals like Apple that had established offshore subsidiaries so as to pay less US […]

Leading US tax attorney Monte Silver has been locked in a legal action with the IRS for over a year, in defense of American expats with a small business registered abroad. All American citizens, including expats, are required to file US taxes every year, reporting their worldwide income and their offshore financial accounts and businesses. […]

American expats are required to file a US tax return, reporting their global income, even if they file foreign taxes too. When they file, expats can claim either the Foreign Earned Income Exclusion, or the Foreign Tax Credit, to reduce their US income tax bill, most often to zero. The Foreign Tax Credit lets expats […]

A consequence of the Tax Cuts and Jobs Act in 2017 was the introduction of IRS Form 8992: Global Intangible Low Taxed Income (GILTI). While its purpose was to discourage multinational corporations, like Apple,1 from evading US taxes, this legislation inadvertently impacted American expat small business owners worldwide. For US business owners operating as Controlled […]

If you’re a self-employed US expat, understanding your tax obligations is essential. Self-employed US expats are not only subject to income taxes but also Social Security taxes. Unlike working for an American employer (or some foreign employers1), you are responsible for keeping track of Social Security taxes when you’re self-employed. This is best done proactively […]

Good news for American expat small business owners: US tax attorney Monte Silver has won a significant milestone in his lawsuit against the IRS over it’s application of the new Transition Tax (part of the recent Tax Reform, and often referred to as the Apple Tax) to small businesses. Background – Tax Reform and Unintended […]

Last month, the IRS released final proposed guidelines relating to the taxation of GILTI (Global Intangible Low Tax Income) on certain foreign registered businesses. The 318 pages of IRS guidelines contain some welcome news for many US expat business owners. Background Before the Trump Tax Reform (the Tax Cuts and Jobs Act of 2017), Americans […]