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Monte Silver, Tax lawyer

May 18
1 min

Harvard files its position paper (amicus brief) in favor of our summary judgment motion

Very interesting https://drive.google.com/file/d/1-BsApOW6SOK1fzfVOudmOTGd0UnL0TWr/view?usp=sharing

Monte Silver, Tax lawyer

May 18
3 min

Tax360 on our Transition Tax lawsuit

The Internal Revenue Service must stop enforcing a tax on overseas profits because the agency wrongly concluded that the burden of calculating the tax would ...

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Monte Silver, Tax lawyer

May 16
5 min

Silver looking to make the kill shot in Motion for Summary Judgment

Tax Notes: May 15 2020 By Andrew Velarde A taxpayer is looking to make the kill shot in his suit challenging the transition tax regulations, which he asserts...

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Monte Silver, Tax lawyer

May 15
1 min

Motion for summary judgment filed in Transition Tax lawsuit

Five days before the deadline, and in what is the final step of this lawsuit, today we filed a motion for summary judgment (or in simple language, a request ...

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Monte Silver, Tax lawyer

May 11
1 min

Tax Notes Feature Article: Will Americans Abroad Try to Claim CARES Act Monetary Relief?

I believe this article effectively summarized the tax/FATCA situation of Americans abroad generally, and as it specifically plays out as to the coronavirus r...

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Monte Silver, Tax lawyer

May 10
1 min

Harvard Law School Tax Clinic to file a brief in support of our motion for summary Judgment!!!

The Harvard Law School Tax Clinic (HLSTC) to file a brief ("Amicus brief") in support of our motion for summary Judgment!!! WOW, is all I can say!!!! What i...

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Monte Silver, Tax lawyer

May 1
1 min

Find the email you sent to Treasury/IRS in the administrative record

Remember you sent Treasury/IRS an email asking that they exempt you from the Transition tax and GILTI? Well, it did not go down the drain. It is part of th...

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Monte Silver, Tax lawyer

Apr 28
1 min

Webinar: Coronavirus benefits - updates

Given (i) the US government’s rapid passing of the 2 Trillion-dollar Corona-relief package, and (ii) the need for Treasury/IRS to rapidly adjust on the fly, ...

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Monte Silver, Tax lawyer

Apr 28
1 min

The Banking Industry failed. The Insurance industry failed. Our Transition tax lawsuit succeeded.

According to Bloomberg yesterday, our case and one other pending before the US Supreme Court are the only two games in town. It has always been practically i...

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Monte Silver, Tax lawyer

Apr 24
4 min

OUCH!!!!!!!!!!! The naked king has been exposed to the world and it is going to hurt!

Today in Tax Notes: Completeness of Administrative Record Challenged in Silver www.taxnotes.com/tax-notes-today-international/accumulated-earnings/completene...

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Monte Silver, Tax lawyer

Apr 22
1 min

Weeks before we file motion for judgement, Treasury/IRS get caught with pants down

Just weeks before we file our motion for judgment, we caught Treasury/IRS hiding documents that were damaging to them. Dirty tricks. Their conduct looks ve...

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Monte Silver, Tax lawyer

Apr 19
1 min

Israeli/US tax webinar: Coronavirus-relief available to Israel-based small businesses under Israeli

Monday April 27, 2020 11:00 AM in Jerusalem The event fill focus primarily on relief available under Israeli law, presented by the prominent Israel firm of S...

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Monte Silver, Tax lawyer

Apr 1
1 min

Participate by phone in high profile Washington DC event of Federalist Society involving our Transit

Participate by phone in high profile Washington DC event of Federalist Society involving our Transition tax lawsuit. Our lawyer speaking When: Friday April ...

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Monte Silver, Tax lawyer

Mar 31
1 min

Webinar: Coronavirus Relief Act and monetary relief for Americans overseas.

AARO, Monte Silver and Bright!Tax invite you to a webinar on The Coronavirus Relief Act (CARES) and how Americans abroad can receive the monetary relief it o...

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Monte Silver, Tax lawyer

Mar 28
1 min

Clarifications on the final Coronavirus Stimulus law

As a public service, I reviewed the final law that was finalized yesterday. I clarify the following: 1. The cash available under the law is NOT an advance. ...

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Monte Silver, Tax lawyer

Mar 27
1 min

Major advocacy win: Americans abroad win big with the Coronavirus Relief Law.

Major advocacy win: Americans abroad win big with the Coronavirus Relief Law. Yes, you and your family can get meaningful monetary relief! Our advocacy has ...

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Monte Silver, Tax lawyer

Mar 25
3 min

Do Americans abroad get until July 15 to file their US returns & pay taxes due?

US Treasury/IRS recently postoned the 2019 deadlines for filing returns and paying taxes - from April 15 till July 15. Does this apply to expats? Summary: ...

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Monte Silver, Tax lawyer

Mar 19
2 min

No virus will stop us -AARO and Monte launch tax video portal

Hi All Crazy times and I hope you are weathering the storm. The virus crisis has brought the world to a standstill. But if all you have are lemons, why no...

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Monte Silver, Tax lawyer

Feb 26
1 min

IRS moves to dismiss lawsuit challenging the CONSTITUTIONALITY of the retroactive Transition tax

The constitutionality of the Transition tax has been challenged in the Moore vs. IRS case. The lawsuit claims that the retroactive nature of the tax is unco...

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Monte Silver, Tax lawyer

Feb 25
2 min

Summary update from the trenches

Lots has transpired since Christmas eve, when the Federal DC judge in our Transition tax lawsuit issued a one-sided ruling denying the Treasury/IRS motion to...

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