Today Treasury issued final regs related to GILTI. These regs relate directly to American expats and US based Americans that operate businesses overseas via a non-US corporation.
The regs provide us small business owners with three meaningul, permanent forms of relief. These forms of relief are 100% the result of our advocacy!
The IRC 250 deduction is available to a taxpayer doing a 962 election.
The 962 election is retro to Jan 2018, thus making the availablility of the IRC 250 deduction available from the beginning of GILTI
A company can do a 962 election in an amended return
I am aware of no other expat advocacy EVER ever that achieved a final permanent fix!