Transition Tax, GILTI, and other Subpart F Issues
Transition Tax, GILTI, and other Subpart F Issues
Start Time: Jan 29th,2020 @ 06:00 pm
End Time: Jan 29th,2020 @ 09:00 pm
The Vault
1 King St. West
Toronto, ON M5C 1T4

Registration: This is a no fee event, however, pre-registration is required. Please RSVP by emailing

Supported by AmCham Canada, Toronto-GTA, the U.S. Professionals Association, Trowbridge Professional Corporation, Hanson Cross Border Tax, Monte Silver, and John Richardson invite you to a discussion on the U.S. Transition Tax, GILTI, and Other Subpart F Issues.

Join this free event to hear from Monte Silver on his continuing lawsuit against the rollout of the Section 965 Transition Tax. The Tax Cuts and Jobs Act of 2017 imposed severe harm to many small (and large) American business owners in Canada. Most (but not all) of this was in the form of the Section 965 Transition Tax and Section 951A GILTI rules. There has been and continues to be significant “push back”. In 2018, Mr. Silver launched a lawsuit against the U.S. Treasury based on the Treasury’s failure to comply with its obligations under the law. Predictably the Treasury argued that Mr. Silver had no standing. On December 24, 2019 a U.S. District Court Judge ruled for Mr. Silver and against Treasury.


Don’t miss the opportunity to hear Mr. Silver’s story and experiences as well as hear from and connect with other professionals who have assisted individuals with Transition Tax and GILTI issues.

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