Part 2: The Transition Tax: Is “Resistance Futile”? The Possible use of the Canada U.S. Tax Treaty to Defeat the “Transition Tax”


cross-posted from citizenshipsolutions blog

by John Richardson

Beginning with the conclusion (for those who don’t want to read the post) …

For the reasons given in this post, I believe that there are grounds to argue that the imposition of the Sec. 965 “transition tax” on



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