An advocacy group representing the interests of American expatriates is calling Treasury out on its global intangible low-taxed income high-tax exclusion rules for what it views as a dereliction of duty owed to small businesses.
In an August 6 release, American Citizens Abroad (ACA) attacked Treasury’s attempts to “tread carefully” around the Regulatory Flexibility Act (RFA) in its July 20 final regs (T.D. 9902) on the exclusion.
Those final regs pertain to rules that allow domestic shareholders of a controlled foreign corporation to elect to exclude from gross tested income amounts taxed at 18.9 percent. The guidance says the regs will not have a significant economic impact on a substantial number of small entities, while noting that the data needed to assess the impact of portions of the guidance is “not readily available.”
For complete article, see https://www.taxnotes.com/tax-notes-federal/global-intangible-low-taxed-income-gilti/expat-group-incensed-over-gilti-regs-small-business-brush/2020/08/10/2ctcd?highlight=andrew%20Velarde